Treasury General Management and 

Infrastructure Support: 

Records Management at 

Departmental Offices 

OIG-02-036 January 30, 2002

Office of Inspector General

******* 

The Department of the Treasury 
Contents 

Records Management at DO (OIG-02-036) Page 1

Audit Report................................................................................................ 3 

 Results in Brief........................................................................................... 4 

 

 Background................................................................................................ 6 

 Findings and Recommendations.................................................................... 8 

Records Management Policies and Procedures ........................................... 8 

 Recommendations.................................................................................. 10 

 Records Management Program ................................................................ 11 

 Recommendation ................................................................................... 15 

 Records Schedules ................................................................................. 16 

 Recommendation ................................................................................... 18 

 Disposition of Records............................................................................ 19 

Appendices

 Appendix 1: Objectives, Scope, and Methodology...................................... 23 

 Appendix 2: Management Comments ....................................................... 25 

 Appendix 3: Major Contributors To This Report ........................................ 33 

 Appendix 4: Report Distribution............................................................... 34 

 

Abbreviations 

 BPD Bureau of the Public Debt 

 CFR Code of Federal Regulations 

 DASIS/CIO Deputy Assistant Secretary for Information Systems/Chief 

 Information Officer 

 CMAPO Chief Management and Administrative Programs Officer 

 Department Department of the Treasury 

 DO Departmental Offices 

 DO/MAP Departmental Offices/Management and Administrative Programs 
Contents 

Records Management at DO (OIG-02-036) Page 2

Abbreviations (continued) 

 FOIA Freedom of Information Act 

 FMS Financial Management Service 

 FRC Federal Records Center 

 FY Fiscal Year 

 GRS General Records Schedules 

 NARA National Archives and Records Administration 

 OASIA Office of the Assistant Secretary for International Affairs 

 OASM/CIO Office of the Assistant Secretary for Management/ 

 Chief Information Officer 

 OGC Office of the General Counsel 

 OIG Office of Inspector General 

 OMB Office of Management and Budget 

 OITPS Office of Information Technology Policy and Strategy 

 RIPT Records Improvement Project Team (also referred to as RIPTeam) 

 RMRB Records Management and Resources Branch 

 SF Standard Form 

 TD Treasury Directive 

 TD P Treasury Directive Publication 

 TreasNet Treasury Department-Wide Intranet 

 USC United States Code 
OIG Audit 

Report

The Department of the Treasury 

Office of Inspector General 

Records Management at DO (OIG-02-036) Page 3

 January 30, 2002 

 James J. Flyzik 

 Acting Assistant Secretary for Management/ 

 Chief Information Officer 

 Departmental Offices 

The Department of the Treasury (Department) manages records 

throughout their life cycle to facilitate accomplishment of the 

agency's programmatic and administrative missions, to preserve 

official agency records in accordance with statutory and regulatory 

requirements, and to ensure access to information by Treasury 

officials and the public, as appropriate. The Department plans and 

establishes a framework for managing and overseeing a 

comprehensive agency-wide records management program. All 

records of the Department should be listed, and accounted for, in 

records schedules, and their disposition should be in accordance 

with the schedules. 

The Federal Records Act requires agencies to create and preserve 

records containing adequate and proper documentation of their 

functions, policies, procedures, and essential transactions. The 

Federal Records Act also requires that agencies establish and 

maintain a program for the efficient management of their records 

and management programs. In addition, the Paperwork Reduction 

Act of 1995, with respect to records management, requires each 

agency to implement and enforce applicable policies and 

procedures, including requirements for archiving information 

maintained in electronic format, particularly in the planning, design, 

and operation of information systems. 

The objectives of the audit were to determine whether 

Departmental Offices (DO) had implemented applicable records 

management policies and procedures in accordance with regulatory 
Records Management at DO (OIG-02-036) Page 4 

guidance, and to evaluate whether DO components1 had controls 

that would allow for authorized, timely, and appropriate disposition 

of records. In addressing the first objective, we also considered 

whether procedures regarding litigation activities would enable 

program staff to appropriately communicate the need for records 

information and to retrieve documents required for litigation and for 

Freedom of Information Act (FOIA) and congressional requests prior 

to disposition. With reference to litigation, it should be noted that 

the Department has been under Court Order to preserve all 

documents relating to the Individual Indian Monies Trust Fund.2

As part of this multi-bureau review of controls over records 

management, we conducted audit work at the DO components, at 

the Financial Management Service (FMS), and at the Bureau of the 

Public Debt (BPD), from April 2000 to January 2001. This report 

reflects the results of our work at DO. We plan to issue separate 

reports for FMS and BPD. A more detailed description of our 

objectives, scope, and methodology is provided as Appendix 1. 

Results in Brief 

We found that, at the time of our review, DO had completed 

work towards developing the appropriate records management 

policies and procedures. For example, during Fiscal Year 

(FY) 2000, the Deputy Assistant Secretary for Information 

Systems/Chief Information Officer (DASIS/CIO) implemented 

Treasury Directive (TD) 80-05, Records and Information 

Management Program, and the accompanying Treasury Directive 

Publication (TD P) 80-05, Records and Information Management 

 

1

 In this report, the term DO components refers to all of the individual organizational units within 

Departmental Offices. At the time of our audit, DO components included twelve Offices at the 

Assistant Secretary or equivalent level, which reported either to one of the Under Secretaries or directly 

to the Deputy Secretary of the Treasury. DO components also included all of the units that reported to 

these twelve Offices, some of which also have the title of Office. For example, seven major units 

reported to the Office of the Assistant Secretary for International Affairs, including the Office of Trade 

Finance and the Office of Multilateral Development Banks. 

2

 Cobell, et al, v. Norton, Civ.No. 96-01285(RCL)(D.D.C.), addressing the Federal government’s 

management of the Individual Indian Monies Trust Fund (referred to as Cobell in this report). 
Records Management at DO (OIG-02-036) Page 5 

Manual.3 The manual included guidance for specific categories of 

records, detailed organizational responsibilities, and guidelines for 

DO components and the bureaus to develop the appropriate 

records management programs. We concluded at that time, 

however, that further action should be taken to strengthen the 

records management program. 

Our report presents four recommendations to the Acting Assistant 

Secretary for Management/Chief Information Officer. The first 

recommendation addresses a function of the DASIS/CIO, whose 

office has records management policy-setting responsibilities for 

the Department. The other three focus more on DO’s bureau-level 

records management requirements, which are the responsibility of 

the Chief Management and Administrative Programs Officer 

(CMAPO). 

Additional action has been taken since the time of our field work. 

A November 15, 2001, response to our draft report provides 

detailed information on steps that have been taken, including the 

development of a comprehensive Project Improvement Plan. In 

addition, the DASIS/CIO developed a 2-year no-cost memorandum 

of understanding with the National Archives and Records 

Administration (NARA) for records management assistance, 

revitalized the bureau records management officers working group, 

and conducted evaluations of bureau programs. The CMAPO 

established a DO Records Improvement Project Team (RIPT), for 

which the DASIS/CIO provided a resource to participate. 

These serve as some examples of actions taken by management in 

its ongoing efforts for program improvement. A summary of other 

actions taken or planned is included under each of the four Findings

in this report, while Appendix 2 contains the complete response. 

We believe that the actions taken or planned by DO address the 

intent of our recommendations. 

 

3

 In this report, the term Treasury Directives is used to refer to TD 80-05 and TD P 80-05 collectively. 

In instances where a statement applies to only one of the two documents, the specific reference is 

shown. 
Records Management at DO (OIG-02-036) Page 6 

Background 

When conducting business, every Federal agency creates a large 

number of records in a variety of media. Numerous laws, 

regulations, and directives have been formulated to address records 

management practices, including the following that apply to 

Treasury and DO. 

• The Federal Records Act, 44 United States Code 

(USC) 3105.

• The Paperwork Reduction Act of 1995, 44 USC 3506.

• The Freedom of Information Act, 5 USC 552. 

• Office of Management and Budget (OMB) Circular A-130, 

Management of Federal Information Resources, dated 

February 8, 1996. 

• NARA Regulations, 36 Code of Federal Regulations 

(CFR) 1220 and following.

• NARA General Records Schedules.

• TD 80-05, dated February 23, 2000.

• TD P 80-05, issued during March 2000.

• Records Management Self-Evaluation Guide, issued by 

NARA, revised/adopted by Treasury during August 1999. 

Since it was originally established in 1789, Treasury's functions 

have expanded to include the numerous DO components and 

bureaus that now comprise the Department. Currently, Treasury 

performs varied functions, such as (1) formulating, recommending, 

and administering financial, economic, and tax policies; 

(2) managing the public debt; and (3) serving as financial agent 

for the United States government. 

Records management responsibilities for Treasury reside within two 

offices in the Office of the Assistant Secretary for Management/ 

Chief Information Officer (OASM/CIO), that of the DASIS/CIO, and 

that of the CMAPO, which was formerly the Office of the Deputy 

Assistant Secretary for Administration. 
Records Management at DO (OIG-02-036) Page 7 

The office of the DASIS/CIO is responsible for leadership, planning, 

overall policy, and general oversight of the records and information 

management program in Treasury and its incorporation into the 

broader information technology policy management framework. 

Within the Office of Information Technology Policy and Strategy 

(OITPS), which reports to the DASIS/CIO, is the Department's 

Records and Information Management Officer. This Officer is 

responsible for managing and coordinating the Treasury-wide 

records and information management program. Responsibilities also 

include serving as the Department’s liaison with NARA and with 

the General Services Administration; providing leadership and 

guidance to the DO components and to the Treasury bureaus on 

training, seminars, conferences, and workshops; and providing 

Intranet website information. The Officer coordinates reviews and 

evaluations of DO components, and of bureau programs, to ensure 

conformance with government-wide and Department records and 

information management standards. The Officer also partners with 

NARA on evaluations of Treasury programs. 

The CMAPO has responsibility for the records management 

programs for the DO components. The Records Management and 

Resources Branch (RMRB) within this office administers the records 

management programs for all DO components. At the time of our 

review, the staff of this branch consisted of one Records 

Management Officer and two staff analysts, one of whom was 

a part-time employee. 

The Records Management Officer within the RMRB is assigned to 

act as liaison to the DASIS/CIO, to oversee the records 

management program, and to serve as a point of contact for the 

Department Records and Information Management Officer. The 

Records Management Officer is also responsible for managing and 

ensuring the implementation of an appropriate records management 

program tailored to the organization’s requirements. 

The Office of the General Counsel (OGC) furnishes legal advice to 

the Secretary of the Treasury with respect to his responsibilities as 

chief financial officer of the Government and overseer of the 
Records Management at DO (OIG-02-036) Page 8 

operating functions of the Department. As such, OGC also has 

a role in records management issues. 

Findings and Recommendations

Finding 1 Records Management Policies and Procedures 

We found that the DASIS/CIO had taken action to improve records 

management policies and procedures in accordance with regulatory 

guidance. At the time of our review, the Treasury Directives did 

not appropriately address recordkeeping when litigation is involved. 

In addition, we felt that the process used to communicate litigation 

actions and FOIA or congressional requests should be improved. 

We also found that CMAPO, at the bureau level, had not 

implemented procedures that complied with the Treasury 

Directives. Enhanced procedures would mitigate the potential for 

inappropriate disposition of records. 

Records Management Policies 

We found that while the Treasury Directives generally complied 

with regulatory requirements and addressed the findings in NARA’s 

1994 report, they did not include provisions for litigation-related 

requirements. Such provisions should be incorporated to further 

improve processes used by DO components to communicate 

litigation actions and FOIA or congressional requests. Also, 

although TD 80-05 included a requirement that bureau records 

management officers review all records triennially, and stated that 

the process for the reviews is included in the manual, we found 

that this was not the case. 

Section 3102 of the Federal Records Act requires each agency to 

establish and maintain an active, continuing program for the 

economical and efficient management of records. Further, OMB 

Circular A-130 requires that, with the establishment of records 

management programs, agencies should ensure the ability to 

access records regardless of form or medium. 
Records Management at DO (OIG-02-036) Page 9 

There were no specific references in TD 80-05 regarding 

litigation-related retention requirements. TD P 80-05 does contain 

several sections that mention legal requirements for records 

disposition, but these references provide limited information 

regarding when and how to retain records required for litigation. 

We were informed that when TD P 80-05 was initially drafted, 

such litigation information was included as a separate section. 

However, according to OITPS staff, on January 4, 2000, 

OGC instructed them to delete the section. OGC stated that, at 

that time, it was impossible to accurately summarize information of 

this nature because of the complexity of the law and pending and 

future litigation. 

We found that, when communicating about litigation actions, 

OGC and the DASIS/CIO had taken measures to emphasize the 

importance of records management and preservation to the 

DO components and to the bureaus. OGC used memorandums, 

including some referred to as taskers, and global electronic 

messages to transmit information about litigation-related matters. 

For example, OGC sent a memorandum on December 8, 1999, 

with reference to specific litigation, instructing supervisors to 

inform employees to retain potentially responsive documents. 

Actions taken by OGC and the DASIS/CIO on the importance of 

records management and preservation during a February 2000 

forum, and actions again during July 2000 with global electronic 

messages, were efforts towards improving controls over 

communicating records management initiatives. 

Records Management Procedures

We also found that, at the time of our review, the CMAPO RMRB 

staff had not started to revise its internal records management 

procedures to comply with the Treasury Directives. Procedures in 

the branch were implemented during August 1995, prior to the 

issuance of the current Treasury Directives, which occurred during 

FY 2000. 

At the time of our review, the Records Management Officer stated 

that, because of limited staff and low priority at a Departmental 
Records Management at DO (OIG-02-036) Page 10 

level, revising procedures had not been given a high priority 

within RMRB. Revisions to the RMRB procedures issued during 

August 1995 were needed to address current records management 

practices, including litigation and electronic recordkeeping. 

OMB Circular A-130 states that agencies shall ensure that records 

management programs provide adequate and proper documentation 

of agency activity and ensure the ability to access records 

regardless of form or medium. Additionally, NARA issued General 

Records Schedule (GRS) Number 20, Electronic Records, during 

1995 to provide disposal authorization for certain electronic 

records and specified hard-copy (paper) or microform records that 

are integrally related to the electronic records. 

Recommendations 

1. The Acting Assistant Secretary for Management/Chief 

Information Officer should implement revisions to the Treasury 

Directives (TD 80-05 and TD P 80-05), to include provisions for 

litigation-related retention requirements in both and to include 

the process for triennial reviews in TD P 80-05. These policies 

and procedures, once implemented, should be incorporated as 

references and authorities by DO components and by the 

Treasury bureaus. 

Management Response

The Information Technology Policy and Records Management 

Staff has been reviewing the Treasury Directives for update, 

with specific emphasis on electronic records management. 

The DASIS/CIO is also piloting a NARA-endorsed electronic 

recordkeeping system. Plans are to assess guidance on 

litigation-related retention requirements, and to post 

supplemental guidance on the triennial review process on the 

Treasury Intranet (TreasNet). These actions are expected to be 

completed by June 30, 2002. 
Records Management at DO (OIG-02-036) Page 11 

Office of Inspector General (OIG) Comments

The OIG believes that the actions being taken and planned 

address the intent of the recommendation. 

2. The Acting Assistant Secretary for Management/Chief 

Information Officer should require the Chief Management and 

Administrative Programs Officer to implement revised records 

management procedures in accordance with the Treasury 

Directives. Procedures should also address current records 

management practices, including litigation references and 

electronic recordkeeping guidance. 

Management Response

The DO RMRB is developing a Records Management Handbook 

for DO and plans to issue it by September 2002. The 

Handbook will address current practices, including electronic 

recordkeeping and general litigation information, and will be 

made accessible on the Treasury Intranet. 

OIG Comments

The OIG believes that the actions being taken and planned 

addresses the intent of the recommendation. 

Finding 2 Records Management Program 

We concluded at the time of our review that CMAPO RMRB should 

take additional action to comply with the Treasury Directives in 

developing an effective records management program. 

In general terms, an effective records management program, as 

defined in the Records Management Self-Evaluation Guide, would 

include clear definitions of objectives, responsibilities, and 

authorities; sufficient resources to administer the program; training 

and guidance for staff; and periodic internal program evaluations to 

monitor compliance and program efficiency. Section 3102 of the

Federal Records Act requires an agency to establish and maintain 
Records Management at DO (OIG-02-036) Page 12 

an active, continuing program for the economical and efficient 

management of its records. Moreover, OMB Circular A-130 states 

that records management programs should provide adequate and 

proper documentation of an agency’s activity, ensure the capability 

to access records regardless of form or medium, and provide 

training and guidance to program staff regarding their records 

management responsibilities. 

Discussed below are three areas for which we believed additional 

action was warranted at the time of our review, i.e., staffing 

levels, training and guidance programs, and internal program 

evaluations. Contributing reasons cited for the lack of action in 

these three areas at that time were the low priority given to 

records management initiatives by the Department and the limited 

resources assigned to RMRB. 

With reference to the level of priority, for example, it was not until 

1999, when staff was notified of records retention requirements 

for several lawsuits that had been filed in prior years, that 

Departmental management seemed to increase emphasis on 

records management issues. Without an appropriate records 

management program, the integrity of a records management 

system could be compromised. Also, without adequate training 

and guidance, the potential exists for staff who are accountable for 

records to keep incomplete or inaccurate records, or to 

inadvertently discard records that should be retained. 

Staffing Levels

At the time of our review, RMRB had not implemented an 

appropriate records management program because of limited 

resources and low priority. 

The 1994 NARA study recommended, in part, that senior 

management make the appropriate staffing level changes in RMRB 

to effectively administer DO component records management 

practices. During 1997, DO created a task force that concurred 

with NARA’s finding that RMRB was understaffed. The number of 

staff had not increased in the three years since the NARA study, 
Records Management at DO (OIG-02-036) Page 13 

continuing to consist of a records officer/manager and three 

subordinate staff members. 

Although there had been several attempts to address the NARA 

recommendations in the past, staffing shortages had not been 

addressed. When we began our review, RMRB staff consisted of 

a Records Management Officer and two staff assistants, one of 

whom was a part-time employee. Thus, staffing had actually 

decreased since the NARA study was conducted. In addition, 

Departmental priorities with reference to several lawsuits required 

the RMRB Records Management Officer's attention, such that 

other records management operations could only be performed as 

time allowed. 

Training and Guidance Programs

At the time of our review, we felt that DO should enhance its 

training and guidance program. While there were opportunities 

for seminars, conferences, workshops, and briefings, we found 

that of the eighteen program staff members we interviewed, 

seven (39 percent) had not received training on the regulations 

and Treasury policies and procedures. Eight (44 percent) had 

received training from external sources, such as NARA; and 

three (17 percent) had received internal training, but not until 

June or July 2000. The training during these two months occurred 

because of a shift in priority by senior management and because of 

litigation that involved the Department. Further, a small percentage 

of the staff members interviewed had only limited awareness of 

records management policies and procedures, and were not aware 

of when records should be scheduled for retention or disposal. 

In general terms, the Records Management Self-Evaluation Guide

states that an effective management program requires the inclusion 

of timely and continuing training and guidance for program or 

records officers, and for others with regular records management 

duties. The guidance also requires that records management 

liaisons, secretaries, file clerks, and those program staff with 

regular records management duties receive guidance and training in 

records maintenance and filing procedures and records disposition. 
Records Management at DO (OIG-02-036) Page 14 

Although at the time of our review DO, in the context of lawsuits 

that had been filed, had made some efforts to train its responsible 

staff, we believed that the Department should make records 

management a higher priority and hold managers and supervisors 

accountable for implementing and administering an effective 

records management program.

Internal Program Evaluations

NARA has conducted several studies of DO's records management 

practices and responsibilities, with the latest report issued during 

October 1994. That report recommended that the Department 

implement an effective records management program with 

adequate staff to conduct internal program evaluations. 

At the time of our review, however, periodic internal program 

reviews had not been conducted. The RMRB Records Management 

Officer told us that, along with assisting the program offices in 

preparing their records schedules, inventories, and file inventories, 

some attempts were starting to be made to conduct assessments 

of program office records. 

Recommendation

3. The Acting Assistant Secretary for Management/Chief 

Information Officer should require the Chief Management and 

Administrative Programs Officer to establish an effective 

records management program that complies with regulatory 

requirements and with the Treasury Directives, by taking 

actions such as (a) allocating adequate resources, including 

sufficient staffing; (b) providing appropriate training and 

guidance; and (c) conducting periodic internal program 

evaluations. 

Management Response

The CMAPO initially addressed staffing by detailing experienced 

staff to the Records Office. Then, during July and August of 
Records Management at DO (OIG-02-036) Page 15 

2001, the CMAPO appointed a Chief Records and Information 

Manager (GS-15) and a Senior Records Analyst/Agency Records 

Officer (GS-14) to lead the Records Management Team. 

DO management believes that the program is better staffed to 

work at instituting controls and techniques to help ensure a 

more effective and efficient records management program. 

Among the many other actions taken to strengthen the records 

management program are providing records-related briefings and 

assistance to departing political appointees and their staffs; 

facilitating sessions on records management for Treasury and 

bureau executives, managers, and employees; designating staff 

members to serve as Customer Service representatives for each 

DO component; and developing a comprehensive Project 

Improvement Plan for FY 2002. 

In addition, the DO Management and Administrative Programs 

(DO/MAP) Records Office held a Records Coordinators 

Symposium during April 2001, and hosted a briefing for all 

DO records managers and coordinators during November 2001, 

as part of its newly-instituted series of briefings or workshops 

to keep staff aware of changes in recordkeeping practices. 

NARA and CIO-sponsored training was also provided to all 

DO/MAP records management staff. 

DO continues to enhance its approach to internal program 

evaluations, in part by working to develop specific measures 

that benchmark past performance, expectations, and 

accomplishments. In addition, the NARA Records Management 

Self-Evaluation Guide, which is on the Treasury Intranet, was 

introduced at the Records Coordinators Symposium to allow 

each office to assess its records management program and 

procedures. Plans are for the initial evaluation process to be 

completed within the year, and annual evaluations to be 

conducted thereafter. 
Records Management at DO (OIG-02-036) Page 16 

OIG Comments

The OIG believes that the actions taken address the intent of 

the recommendation. 

Finding 3 Records Schedules 

At the time of our field work, the Requests for Records Disposition 

Authority, Standard Forms (SF) 115, referred to as records 

schedules, were not current and needed revision. For example, 

since NARA had approved one office’s last SF 115, that office had 

stopped using some of the types of records listed in its records 

schedule. Another office had changed retention periods for some 

of its records and did not have some records scheduled on the 

SF 115. Additionally, one office did not have an SF 115 in place 

at the time of our review. 

NARA, 36 CFR 1222.20, Agency responsibilities, states that each 

Federal agency shall review recordkeeping requirements, as part of 

the periodic information resources management reviews required 

by 44 USC 3506, or the periodic records-management evaluations 

required by 36 CFR 1220.54, in order to validate that they are 

current and to ensure that recordkeeping requirements are being 

implemented. Also, 36 CFR 1228.22, Developing records 

schedules, states that agencies should prepare an inventory of 

records, including a description of their medium, location, volume, 

inclusive dates, informational content, and use. Furthermore, 

36 CFR 1228.24, Formulation of agency records schedules, states 

that an SF 115 shall include only new records not covered by the 

GRS, deviations from the GRS, or previously scheduled records 

requiring changes in retention periods or substantive changes in 

description. 

TD 80-05 states that the bureau records management officers 

shall review all records schedules triennially to ensure that new 

categories of records are scheduled, that discontinued categories 

of records are eliminated, and that retention periods are altered 

where appropriate. In addition, TD 80-05 states that triennial 

reviews should be made to determine compliance with Federal 
Records Management at DO (OIG-02-036) Page 17 

records management regulations and provide the Department’s 

Records and Information Management Officer the required 

documentation to conduct DO reviews. 

We found that two of the four SFs 115 that we reviewed were not 

current and needed revision. In addition, one office needed to 

prepare an SF 115. 

First, the SF 115 for the Office of the Assistant Secretary for 

International Affairs (OASIA) was not current. The OASIA Office 

of Trade Finance informed us that it no longer used some of the 

records included on the existing SF 115. Also, the OASIA Offices 

of Trade Finance and of Multilateral Development Banks had not 

prepared inventories of their program records. These offices had 

not been given guidance on preparing the file inventories until 

August 2000. 

Second, the SF 115 for the Office of the Under Secretary for 

Enforcement was not current. The Office of Enforcement 

Correspondence Unit had reassessed some of the retention 

periods used in its 1979 SF 115 and decided to change a few. 

36 CFR 1228.32, Request to change disposition authority, states 

that agencies proposing to modify the retention period of a series 

or system of records shall submit with the SF 115 an explanation 

and justification for the change. Also, the Correspondence Unit’s 

FOIA and Reports and Publication files were not scheduled on the 

1979 SF 115. 

Additionally, we found that OASM/CFO did not have an SF 115 in 

place at the time of our review. The Records Management Officer 

was working with the office to assist it in developing an SF 115. 

In addition to the required revisions and/or the need for new 

records schedules previously discussed, we believed at the time of 

our review that DO should determine how electronic records would 

be scheduled, to ensure proper disposal of records maintained in 

electronic media. Since the last SFs 115 were approved for DO 

components and the August 1995 issuance of GRS 20, DO had not 

revised the SFs 115 for these offices to include electronic records. 
Records Management at DO (OIG-02-036) Page 18 

GRS 20 provides disposal authorization for certain, but not all, 

electronic records and for specified hard-copy (paper) or microfilm 

records that are integrally related to the electronic records. If DO 

decides to apply a different retention period for any series of 

electronic records covered by GRS 20, DO should revise or prepare 

new SFs 115, as applicable.

At the time of our field work, the Records Management Officer 

had not conducted reviews of the SFs 115 to identify new 

records series that should have been scheduled or changes in 

recordkeeping practice that would have required records schedule 

revisions, the aforementioned offices had not updated current, 

and/or prepared new, SFs 115. The Records Management Officer 

informed us that staffing shortages prevented reviews from being 

conducted to identify records schedule changes and to provide 

guidance on preparing file inventories. 

Recommendation

4. The Acting Assistant Secretary for Management/Chief 

Information Officer should ensure that the Chief Management 

and Administrative Programs Officer continues efforts to 

prepare file inventories, to update existing SFs 115 and/or to 

prepare new SFs 115, and to conduct triennial reviews of the 

SFs 115. 

Management Response

New and revised records schedules were drafted and sent to 

NARA for review and appraisal on March 12, 2001. The RIPT 

is working closely with NARA to complete the pre-appraisal 

process, having taken actions such as conducting inventories of 

more than 200 offices within DO. 

OIG Comments

The OIG believes that the actions taken address the intent of 

the recommendation. 
Records Management at DO (OIG-02-036) Page 19 

Finding 4 Disposition of Records 

At the time of our review, DO had on hand records that were 

scheduled for destruction onsite or at a Federal Records 

Center (FRC). Also, DO components had not transferred records to 

NARA or to the FRC in accordance with existing records schedules. 

Records that are scheduled for destruction, but are retained beyond 

the scheduled dates, may cause an agency to incur excessive 

storage costs. 

According to 36 CFR 1220.38, Disposition of records, agencies 

must ensure the proper, authorized disposition of their records, 

regardless of format or medium, so that permanent records are 

preserved and temporary records no longer of use to an agency are 

promptly deleted or disposed of in accordance with approved 

records schedules when the required retention period expires. This 

section of the CFR also states that, as an intermediate step, when 

records are not needed for current day-to-day reference, they may 

be transferred to a records storage facility. 

DO did not dispose of its records according to the schedules due to 

several ongoing lawsuits. At the time of our review, DO had 

implemented a freeze on some of its records. Employees, 

however, did not dispose of records that were not responsive to 

litigation. Offices did not seek waivers to dispose of such records. 

We found that the following four of the six offices that we selected 

for review had records onsite that were scheduled for retention at, 

and should have been sent to, another location. 

• Office of the Assistant Secretary for Public Affairs. 

• Office of the Deputy Assistant Secretary for Fiscal 

Operations and Policy. 

• Office of Trade Finance. 

• Office of Multilateral Development Banks. 

. 

Public Affairs had press conference transcripts and press speeches 

that should have been offered to NARA because, according to its 

general records schedule, the documents were considered 
Records Management at DO (OIG-02-036) Page 20 

permanent. Fiscal Operations and Policy also had documentary 

materials that were scheduled as permanent and should have been 

transferred to NARA. Both Trade Finance and Multilateral 

Development Banks had records that should have been transferred 

to the FRC. 

A memorandum from the OGC Deputy Counsel, dated December 8, 

1999, regarding a specific lawsuit, advised the Under, Assistant, 

and Executive Secretaries to inform their personnel and the FRC 

that all DO records potentially relevant to the litigation must be 

retained until further notice. Further, the memorandum stated that 

it was the Secretaries’ responsibility to identify for the FRC which 

records must be retained. 

Although the memorandum stated that records potentially relevant 

to the litigation must be retained, employees did not adequately 

dispose of records that were not responsive in accordance with the 

records schedules. 

In a memorandum to the Records Management Officer, dated 

February 11, 2000, NARA acknowledged that it had instituted a 

nationwide freeze on the destruction of all records of the Treasury 

components and bureaus that were in the physical custody of the 

FRC system. Further, the memorandum stated that the 

Department was being assessed storage and service charges for all 

of the records it stored at FRC facilities. 

Until the scope of this freeze is narrowed, DO holdings will 

increase because new accessions will continue to be retired to the 

FRC system, but older accessions that are otherwise eligible for 

disposal will not be destroyed. Consequently, DO storage and 

service charges will increase. 

If DO components do not dispose of non-litigation records that 

should be destroyed, DO will incur unnecessary charges. 

Subsequent destruction of records outside of the normal 

destruction period, depending on the timing, could also give the 

appearance of impropriety. 
Records Management at DO (OIG-02-036) Page 21 

We were unable to readily determine whether records at the FRCs 

and those maintained at DO component sites were responsive to 

litigation. However, the Records Management Officer informed us 

that, at the time of our review, DO had 362 cubic feet4

 of records 

that would otherwise be eligible for destruction for Calendar Year 

2000 at the FRC on hold because of the litigation freeze on 

records. 

During FY 2000, NARA began charging agencies for storage and 

service costs for agency records maintained at its FRC facilities. 

Yearly storage and service charges are $1.96 and $1.38, 

respectively. This results in a total cost of $3.34 per cubic foot. 

Costs associated with retention of the 362 boxes of records stored 

at the FRC would be $1,209 during FY 2001.5

As more records reach the retention periods designated in the 

records schedules but are not destroyed, costs to the Treasury may 

escalate. Costs incurred for storage and service charges could be 

put to better use by the Department.

DO management advised us that, in the overall context of records 

retention requirements for litigation, Treasury has no choice but to 

retain these documents, whatever the storage costs may be, and 

that records must be very carefully researched and reviewed before 

any determinations of waivers can be made. Such reviews would 

require resources from DO/MAP and experts from each of the 

program offices, with assistance from OGC. 

While records retention costs are a concern when considered on a 

Treasury-wide basis, these costs will continue to be borne by the 

Department until such time as the litigation is adjudicated, or until 

the Court rules otherwise. Although NARA officials told us that 

some agencies are attempting to have the parties that have 

requested that records be retained; i.e., the Justice Department or, 

in some cases, the plaintiffs; pay the costs associated with storing 

 

4

 The standard records box accepted by the FRC measures one cubic foot. 

5

 Costs incurred in this area by DO and BPD are relatively small when compared to those at FMS, with a 

total amount of close to $400,000 for FY 2001.
Records Management at DO (OIG-02-036) Page 22 

records, this is not a course of action that Treasury plans to 

pursue. 

It is our understanding that once the constraints of litigation are 

lifted, Treasury management plans to resume the proper disposition 

of records on an ongoing, structured basis, in accordance with 

each office's records schedule. 

Because of the circumstances surrounding current litigation, we 

defer to the decision of senior management to take a cautious 

approach regarding records retention, and make no further 

recommendations at this point. 

* * * * * * 

We would like to express our appreciation to DO for the 

cooperation and courtesies extended to our staff during the review. 

If you have any questions, please call me at (202) 927-6512 or 

Maria V. Carmona, Audit Manager, Banking and Fiscal Service, at 

(202) 927-6345. Major contributors to this report are listed in 

Appendix 3. 

Donald R. Kassel 

National Director, Banking and Fiscal Service 
Appendix 1 

Objectives, Scope, and Methodology 

Records Management at DO (OIG-02-036) Page 23 

The objectives of the audit were to determine whether DO had 

implemented applicable records management policies and 

procedures in accordance with regulatory guidance, and to evaluate 

whether DO components had controls in place that would allow for 

authorized, timely, and appropriate disposition of records. In 

addressing the first objective, we also considered whether 

procedures regarding litigation activities would enable program 

staff to appropriately communicate the need for records 

information and to retrieve documents required for litigation and 

for FOIA and congressional requests prior to disposition. 

Our audit work focused on policy formulation by DASIS/CIO, 

OITPS, and on operations of records management programs by the 

CMAPO RMRB. We obtained and reviewed the applicable records 

management systems policies and procedures at DO using a 

checklist developed for that purpose. We also evaluated the 

controls implemented to ensure authorized, timely, and appropriate 

disposition of documentary materials by conducting interviews and 

inventory assessments at six selected program offices. 

It should be noted that this review was not part of the OIG Annual 

Plan for FY 2000, but rather was initiated, in part, based on the 

results of prior audit work6

 and in response to concerns raised 

about the disposal of historical records during pending litigation. 

Also, the Department’s OGC had expressed interest in this matter. 

As part of this multi-bureau review of controls over records 

management, we conducted audit work at DO components, at 

FMS in Washington, D.C., and in Hyattsville, Maryland; and at 

BPD’s Washington, D.C., and Parkersburg, West Virginia, locations. 

This report reflects the results of our work at DO. We plan to issue 

separate reports for FMS and BPD. 

 

6

 Report titled Financial Management Service’s Deposit Fund Accounts Used for the Implementation of 

the Competitive Equality Banking Act, OIG-00-088, issued on May 30, 2000. 
Appendix 1 

Objectives, Scope, and Methodology 

Records Management at DO (OIG-02-036) Page 24 

We started our field work during April 2000 and completed onsite 

work at the three organizations during January 2001. We 

conducted our audit in accordance with generally accepted 

government auditing standards. 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 25 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 26 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 27 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 28 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 29 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 30 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 31 
Appendix 2 

Management Comments 

Records Management at DO (OIG-02-036) Page 32 

+
Appendix 3 

Major Contributors To This Report 

Records Management at DO (OIG-02-036) Page 33 

 Washington Headquarters

 Donald R. Kassel, National Director, Banking and Fiscal Service 

 Maria V. Carmona, Audit Manager 

 C. Samuel McGeorge, Audit Manager 

 Ethel Taylor-Young, Auditor-in-Charge 

 Delores V. Dabney, Senior Auditor 
Appendix 4 

Report Distribution 

Records Management at DO (OIG-02-036) Page 34 

 Department of the Treasury 

 

 Under Secretary for Enforcement 

 Office of Strategic Planning and Evaluations 

 Office of Accounting and Internal Control 

 Office of Budget 

 Departmental Offices

 

Office of the Acting Assistant Secretary of the Treasury for 

 Management/Chief Information Officer 

Deputy Assistant Secretary for Information Systems/Chief 

 Information Officer 

 Office of General Counsel 

 Chief Management and Administrative Programs Officer 

 Office of Management and Budget

 OIG Budget Examiner