National Archives and Records Administration: Oversight and Management Improvements Initiated, but More Action Needed
Published: 2010-10-05T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The mission of the National Archives and Records Administration (NARA) is to safeguard and preserve government records, ensuring continuing access to the essential documentation of the rights of American citizens and the actions of their government. However, in today's environment of fast-evolving information technology, federal agencies are creating vast and growing volumes of electronic records while continuing to create physical records in large numbers. Accordingly, GAO was asked to assess NARA's effectiveness in overseeing the governmentwide management of records, including commenting on its capacity to identify risk of unlawful destruction of federal records; describe its ability to preserve permanent records; and assess its policies, procedures, and plans supporting key management and oversight capabilities (collaboration, governance, and human capital). To do so, GAO analyzed NARA documentation in these areas, interviewed agency officials, and reviewed prior work.
section_title: What GAO Found
paragraphs: The effectiveness of NARA's oversight has been improved by recent increases in its oversight activities: NARA has conducted its first governmentwide records management self-assessment survey, resumed agency inspections after a long gap, and expanded its reporting (including giving more complete information about specific agencies). These efforts have provided a fuller picture of governmentwide records management: in particular, NARA found that almost 80 percent of agencies were at moderate to high risk of unlawful destruction of records. Reporting of such results may also help influence agencies to give more priority to records management, which has historically been given low priority. However, these initiatives have limitations. For example, NARA's efforts to validate self-reported survey data are limited, as are its plans for inspections of agency records management; addressing these limitations could enhance the usefulness of these efforts as they continue to be developed. NARA also oversees agency records management through its review and approval of the schedules under which agencies may dispose of records. Following an extended effort to get agencies to schedule electronic records and systems, NARA increased the number of schedules approved per year. However, it has also increased the backlog of schedules awaiting its approval, increasing the risk that NARA's success in promoting scheduling could bring in more schedules than it can handle in a timely manner. NARA faces challenges in preserving permanent records largely because of their volume, the finite resources available, and the technological challenges posed by electronic records. NARA has a large and persistent backlog of records on paper and other media needing preservation actions. Although it treated nearly 116,000 cubic feet of at-risk archival records in fiscal year 2009, the percentage of backlog remained constant at about 65 percent, and holdings requiring preservation grew from about 2.4 million cubic feet in 2008 to about 2.6 million cubic feet in 2009. For electronic records, NARA has an electronic records archive system that is still under development and does not yet include planned preservation functions. Until the system and its preservation capabilities are fully implemented, there is reduced assurance that NARA can ensure the preservation of all electronic records. NARA's policies and procedures for collaboration, selected aspects of governance, and human capital are generally aligned with its strategic planning. For example, it is participating in numerous collaborative activities that support the goals and strategies in its strategic plan. However, more action is needed. For example, with regard to governance, although its organizational responsibilities are generally aligned with its strategic plan, NARA has not established an enterprise risk management capability, reducing its ability to anticipate future challenges and avoid potential crises. Finally, NARA has developed and begun to implement a strategic human capital plan, but this implementation has been delayed, which hinders the agency's ability to ensure that it has the workforce and skills it needs.
section_title: What GAO Recommends
paragraphs: GAO is making recommendations to help NARA build on its recent oversight activities and to fill gaps in its risk management and human capital management. In comments on a draft of the report, NARA concurred.

section_title: Letter
paragraphs: The mission of the National Archives and Records Administration (NARA)  is to safeguard and preserve government records, ensuring continuing  access to the essential documentation of the rights of American citizens  and the actions of their government. However, in today’s environment of  fast-evolving information technology, this important mission is  increasingly challenging. At the same time that paper and other physical  records continue to be created in large numbers, federal agencies are  creating vast and growing volumes of electronic records.
In light of this challenging environment, you asked us to undertake a  review of the agency’s ability to effectively carry out its mission of  overseeing the management of federal records while preserving those of  historic and intrinsic value.
As agreed, our objectives were to (1) assess NARA’s effectiveness in  overseeing the governmentwide management of records, including  commenting on its capacity to identify risk of unlawful destruction of  federal records; (2) describe its ability to preserve permanent records; and  (3) assess its policies, procedures, and plans supporting key management  and oversight capabilities: governance, human capital, and collaboration.
To assess NARA’s effectiveness in overseeing governmentwide records  management, we examined its use of the oversight activities—surveys,  studies, inspections, and reporting—defined in the Federal Records Act  and its process for approving records schedules. We examined documents,  interviewed agency officials, and obtained input from a panel of experts  and from other federal records managers. To comment on NARA’s  capacity to identify risk of unlawful destruction of federal records, we  reviewed applicable laws, reviewed the results of a NARA survey, and met  with NARA records management staff to identify risk factors.
To describe NARA’s ability to preserve permanent records, we met with  NARA preservation staff; reviewed NARA’s survey of its physical records  and its backlog of records needing preservation actions and assessed their  reliability; and analyzed NARA’s ability to process its backlog. We also  reviewed external research on electronic records, interviewed staff  involved in developing NARA’s Electronic Records Archives (ERA)  system, and drew on our previous reports about the status of ERA.
To assess NARA’s policies, procedures, and plans supporting key  management and oversight capabilities, we analyzed NARA management,  strategic planning, and policy documents against requirements of the  Government Performance and Results Act (GPRA) and our risk  management framework in order to determine whether NARA lines of  responsibility were aligned with its strategic plans and whether it was  conducting an appropriate risk management program. To assess human  capital management, we compared NARA’s human capital management  capabilities and its human capital strategic plan against our Strategic  Human Capital Framework. We interviewed NARA officials and reviewed  progress in implementing its human capital plan against the plan’s  milestones. To evaluate NARA’s collaboration capabilities, we interviewed  policy and planning staff, analyzed agency policies and procedures related  to collaboration, obtained a list of NARA collaborative projects, and  examined whether collaborative activities specified in the strategic plan  were being carried out.
We reached out to the federal records management community to obtain  information on several issues. We worked with the National Academy of  Sciences to convene a panel of experts. We also obtained views of selected  federal government records managers at the Department of Defense and  surveyed members of the Federal Information and Records Managers  Council, an organization of federal records managers. Appendix I provides  further details on our objectives, scope, and methodology.
We conducted this performance audit from October 2009 to October 2010  in the Washington, D.C., metropolitan area in accordance with generally  accepted government auditing standards. Those standards require that we  plan and perform the audit to obtain sufficient, appropriate evidence to  provide a reasonable basis for our findings and conclusions based on our  audit objectives. We believe that the evidence obtained provides a  reasonable basis for our findings and conclusions based on our audit  objectives.
subsections: section_title: Background
paragraphs: NARA’s mission is to safeguard and preserve the records of the U.S.  government, ensuring that the people can discover, use, and learn from  this documentary heritage. In this way, NARA is to ensure continuing  access to the essential documentation of the rights of American citizens  and the actions of their government.
In carrying out this mission, NARA (among other things) is to provide  guidance and assistance to federal officials on the management of records;  determine the retention and disposition of records; store agency records in  records centers from which agencies can retrieve them; receive, preserve,  and make available permanently valuable federal and presidential records;  and centrally file and publish federal laws and administrative regulations,  the President’s official orders, and the structure, functions, and activities  of federal agencies through the daily Federal Register.
subsections: section_title: NARA Organization and Functions
paragraphs: NARA is organized into six main offices, as well as a number of offices  carrying out particular functions. As shown in the organization chart in  figure 1, of NARA’s six major offices, two are support offices (the Office of  Administration and the Office of Information Services), and four carry out  the organization’s primary missions (the Offices of Records Services,  Washington, D.C.; Regional Records Services; the Federal Register; and  Presidential Libraries). In addition, four independent offices with  specialized missions report directly to the Archivist of the United States,  and various staff offices (such as General Counsel) provide support.
Table 1 shows these organizations, major functions, and the levels of staff  in each (expressed as full-time equivalent—FTE).
NARA’s operations are dispersed throughout more than 40 facilities in the  United States. These facilities include the National Archives Building in  Washington, D.C. (housing the nation’s founding documents); the nearby  Archives II facility in College Park, Maryland; and its nationwide network  of regional archives, records centers, and presidential libraries and  museums.
section_title: Organizations Primarily Responsible for Federal Records Management and Preservation
paragraphs: Two offices share primary responsibility for performing NARA’s mission  to safeguard and preserve federal records: the Office of Records Services,  Washington, D.C., and the Office of Regional Records Services. These  offices also account for more than two-thirds of NARA’s approximately  3,200 FTE employees.
The Office of Records Services, Washington, D.C., has custodial  responsibility for the historically valuable records of the three branches of  the federal government in the Washington, D.C., area. Through its  programs, the office appraises, accessions, preserves, describes, and  provides access to these records. Besides the head office, it has six main  subdivisions, as shown in table 2.
The Office of Regional Records Services is organized into nine regions  (each headed by a Regional Administrator) plus the National Personnel  Records Center in St. Louis, Missouri. Each region operates records  centers, regional archives, and records management programs for the  region. In all, the Office of Regional Records Services manages 17 records  centers nationwide, which operate on a reimbursable fee-for-service basis.  They provide federal agencies with storage of agency records not needed  in day-to-day operations, among other services, including records  management assistance. The regional archives provide the public with free  access to the significant historical records of federal agencies for purposes  of education, genealogy, history, and research, as well as to facilitate  publications in all media. Of the staff of more than 1,400, about half (745)  are assigned to the Federal Personnel Records Center, with the rest  allocated to the regions.
In addition, the Office of Information Services plays an important role in  records management and preservation through two of its components:    The Electronic Records Archives Program Office manages the program to  develop ERA, a system that is intended to preserve and provide access to  huge volumes of all types and formats of electronic records, independent  of their original hardware or software.
The Center for Advanced Systems and Technologies works to discover  and promote archival technologies, including preservation technologies, to  NARA’s offices.
To coordinate records management activities that are performed in both  headquarters and the regions, NARA set up the National Records  Management Program, headed by the Director of Modern Records  Programs within the Office of Records Services, Washington, D.C. Among  the goals of setting up the National Records Management Program was to  be more responsive to NARA and agency records management needs and  goals, improve internal communications, and help clarify staff roles and  responsibilities. The program includes about 100 records management  staff working in both the Washington, D.C., office and the regions (each  region operates one or more records center facilities, each of which has  two to four staff that perform records management work).
section_title: NARA Funding and Allocation of Budget Authority
paragraphs: NARA’s fiscal year 2009 appropriation was about $459 million, while its  fiscal year 2010 appropriation is about $470 million. NARA’s budget  request for fiscal year 2011 is about $460 million. In addition to annual  appropriations acts, NARA’s operations are funded through revenues from  the National Archives Trust Fund, Gift Fund, and Revolving Fund (which  funds the operations of the regional records centers). NARA’s operations  at the presidential libraries are also partially supported by a Presidential  Library Trust Fund.
Figure 2 provides the reported breakdown of the allocation of budget  authority provided to NARA by annual appropriations acts for fiscal year  2009 ($486 million, which includes $26 million carried over in multi-year  and no-year funds available for obligation).
section_title: NARA’s Responsibilities for Records Management and Preservation
paragraphs: The Federal Records Act gives NARA responsibilities regarding both  federal records management and preservation of permanent records.   Thus, NARA supports agency management of records used in everyday  operations (both temporary and permanent) and ultimately takes control  of permanent agency records judged to be of historic value. Of the total  number of federal records, NARA estimates that less than 3 percent are  designated permanent.
subsections: section_title: Responsibility for Records Management Is Shared across the Government
paragraphs: By statute, some of the responsibilities for oversight of federal records  management are divided across several agencies. Under the Federal  Records Act, NARA shares a number of records management  responsibilities and authorities with the General Services Administration  (GSA). Under the Paperwork Reduction Act and the E-Government  Act, the Office of Management and Budget (OMB) also has records  management oversight responsibilities.
Further, the heads of federal agencies are responsible for their agencies’  records. The Federal Records Act establishes requirements for records  management programs in federal agencies. Each federal agency is required  to make and preserve records that (1) document the organization,  functions, policies, decisions, procedures, and essential transactions of the  agency and (2) provide the information necessary to protect the legal and  financial rights of the government and of persons directly affected by the  agency’s activities. (NARA is assigned responsibilities for assisting federal  agencies in this area.) Effective management of these records is critical for  ensuring that sufficient documentation is created; that agencies can  efficiently locate and retrieve records needed in the daily performance of  their missions; and that records of historical significance are identified,  preserved, and made available to the public.
Records must be managed at all stages of their life cycle, which includes  records creation or receipt, maintenance and use, and disposition.  Agencies create records to meet the business needs and legal  responsibilities of federal programs and (to the extent known) the needs  of internal and external stakeholders who may make secondary use of the  records. To maintain and use the records created, agencies are to  establish internal recordkeeping requirements for maintaining records,  consistently apply these requirements, and establish systems that allow  them to find records that they need. Disposition involves transferring  records of permanent, historical value to NARA for archiving  (preservation) and destroying all other records that are no longer needed  for agency operations.
NARA is responsible for issuing records management guidance; working  with agencies to implement effective controls over the creation,  maintenance, and use of records in the conduct of agency business;  approving the disposition (destruction or preservation) of records; and  providing storage facilities for agency records. The Federal Records Act  also gives NARA the responsibility for conducting inspections or surveys  of agencies’ records and records management programs and practices;  conducting records management studies; and reporting the results of these  activities to the Congress and OMB.
section_title: NARA Must Approve Disposition of Federal Records
paragraphs: Under the Federal Records Act, disposition of any records (destruction or  transfer to the Archives for preservation) requires the approval of the  Archivist of the United States. Scheduling is the means by which NARA  and agencies identify federal records and determine time frames for  disposition. Creating records schedules involves identifying and  inventorying records, appraising their value, determining whether they are  temporary or permanent, and determining how long records should be  kept before they are destroyed or turned over to NARA for archiving. For  example, one general records schedule permits civilian agencies to  destroy case files for merit promotions (2 years after the personnel action  is completed or after an audit by the Office of Personnel Management,  whichever is sooner). No record may be destroyed or permanently  transferred to NARA unless it has been scheduled, so the schedule is of  critical importance. Without schedules, agencies would have no clear  criteria for when to dispose of records and, to avoid disposing of them  unlawfully, would have to maintain them indefinitely.
NARA works with agencies to help schedule records, and it must approve  all agency records schedules. It also develops and maintains general  records schedules covering records common to several or all agencies.  According to NARA, records covered by general records schedules make  up about a third of all federal records. For the other two thirds, NARA and  the agencies must agree upon agency-specific records schedules.
Destruction of records before their scheduled disposition date or without  NARA approval is unauthorized and unlawful. Specifically, unlawful  destruction occurs when    permanent records or records that have not been scheduled are destroyed,  temporary records are destroyed before the end of their retention   period, or records required to be held for other reasons, such as litigation or  Freedom of Information Act requests, are destroyed.
Agency heads are responsible for preventing unauthorized destruction of  records and must make sure employees are informed about the  requirement, implement policies and procedures to ensure that records  are protected, and report any unauthorized removal or destruction to  NARA. If NARA learns of a potential or actual instance of unlawful  destruction, the Archivist is required to notify the agency head and assist  in initiating action through the Attorney General for the recovery of  records and other redress. If the head of the agency does not initiate an  action within a reasonable period of time, the Archivist is to request the  Attorney General to act and notify the Congress.
section_title: NARA Is Responsible for Preservation of Permanent Records
paragraphs: As the nation’s archivist, NARA is the legal custodian of the records of  federal agencies that are determined to have sufficient historical or other  value to warrant their continued preservation by the U.S. government.  NARA also accepts for deposit to its archives many of the records of the  Congress, the Architect of the Capitol, and the Supreme Court. In addition,  NARA accepts papers and other historical materials of the presidents of  the United States, documents from private sources that are appropriate for  preservation (including electronic records, motion picture films, still  pictures, and sound recordings), and records from agencies whose  existence has been terminated.
NARA archives vast quantities of federal records in various formats.  According to the agency, its 28 archives and presidential libraries across  the United States hold almost 4 million cubic feet of permanent federal  paper, photographic, audio, video, and film records and 600,000 artifacts.  Its multimedia collections include nearly 300,000 reels of motion picture  film; more than 15 million maps, charts, aerial photographs, architectural  drawings, patents, and ship plans; more than 200,000 sound and video  recordings; and nearly 6 million photographs and graphics. In addition, as  of August 2010, NARA has archived about 82.4 terabytes of electronic  information.
To preserve electronic records, NARA has been working since 2001 to  develop an electronic records archive system that is intended to preserve  and provide access to very large volumes of all types and formats of  electronic records, independent of their original hardware or software.  NARA plans for the system to manage the electronic records from their  ingestion through preservation and dissemination to customers. The ERA  system is being developed in five phases, or increments. NARA has  certified initial operating capability of the first two phases of ERA. NARA  plans to complete development of the remaining increments and achieve  full operating capability by 2012.
section_title: We Have Previously Reported on NARA’s Challenges and Federal Records Management
paragraphs: We have previously reported on the risks NARA faces in its acquisition of  ERA, on NARA’s oversight of federal records management, and on the  challenges of electronic records management.
From 2002 onward, we have issued a series of reports on ERA and its  development. Most recently, we reported, among other things, that  NARA’s plans for completing the final two increments were not  sufficiently specific: the most recent expenditure plan did not detail what  system capabilities would be delivered in the final two ERA increments or  dates for completion. Further, NARA’s management of the requirements  for ERA had weaknesses: NARA had established an initial set of high-level  requirements to guide the system’s development, but about 43 percent of  the requirements had not been allocated to the last two increments, and  NARA officials stated that it was uncertain whether they would be  implemented at all. Finally, NARA stated that it had reinterpreted some of  the requirements in its original requirements document but had not  updated it. The lack of a current set of requirements is a significant risk. If  requirements are incomplete and out of date, the system could be  completed without addressing all necessary requirements or with  functionality that meets requirements that are no longer valid.  Accordingly, we recommended that NARA ensure that ERA’s requirements  are managed using a disciplined process that ensures that requirements  are traceable throughout the project’s life cycle and are kept current.
We have also made recommendations to NARA on its oversight of federal  records management. Our recommendations were aimed at improving  NARA’s insight into the state of federal records management as a basis for  determining where its attention is most needed. In 1999, in reporting on  the substantial challenge of managing and preserving electronic records in  an era of rapidly changing technology, we noted that NARA did not have  governmentwide data on the electronic records management capabilities  and programs of all federal agencies. Accordingly, we recommended that  NARA conduct a governmentwide survey of these programs and use the  information as input to its efforts to re-engineer its business processes.  However, instead of doing a governmentwide baseline assessment survey  as we recommended, NARA planned to obtain information from a limited  sample of agencies, stating that it would evaluate the need for such a  survey later.
In 2002, we reported that because NARA did not perform systematic  inspections of agency records management, it did not have comprehensive  information on implementation issues and areas where guidance needed  strengthening. We noted that in 2000, NARA had suspended agency  evaluations (inspections) because it considered that these reached only a  few agencies, were often perceived negatively, and resulted in a list of  records management problems that agencies then had to resolve on their  own. We recommended that it develop a strategy for conducting  systematic inspections of agency records management programs to  (1) periodically assess agency progress in improving records management  programs and (2) evaluate the efficacy of NARA’s governmentwide  guidance.
In response to our recommendations, NARA devised a strategy for a  comprehensive approach to improving agency records management that  included inspections and identification of risks and priorities.  Subsequently, it also developed an implementation plan that included  undertaking agency inspections based on a risk-based model, government  studies, or media reports.
In 2008, we reported that under its oversight strategy, NARA had  performed or sponsored six records management studies in the previous 5  years, but it had not conducted any inspections since 2000 because it used  inspections only to address cases of the highest risk, and no recent cases  met its criteria. In addition, NARA’s reporting to the Congress and OMB  did not consistently provide evaluations of responses by federal agencies  to its recommendations, as required, or details on records management  problems or recommended practices that were discovered as a result of  inspections, studies, or targeted assistance projects. Accordingly, we  recommended that NARA develop and implement an oversight approach  that provides adequate assurance that agencies are following NARA  guidance, including both regular assessments of agency records and  records management programs and reporting on these assessments. NARA  agreed with our recommendations and devised a strategy that included  annual self-assessment surveys, inspections, and reporting, which it has  now begun to implement.
Most recently, we testified on the challenges of managing electronic  records and commented on the low priority that records management has  historically received within the federal government. Our past reports  identified persistent weaknesses in federal records management, including  a lack of policies and training. We also noted some of the challenges of  managing electronic records: For example, electronic information is being  created in volumes that pose a significant technical challenge to our ability  to organize and make it accessible. Electronic records range in complexity  from simple text files to highly complex formats with embedded  computational formulas and dynamic content, and new formats continue  to be created. Further, in a decentralized environment, it is difficult to  ensure that records are properly identified and managed by end users on  individual desktops (the “user challenge”). We concluded that technology  alone cannot solve the problem without commitment from agencies,  noting (among other things) that automation will not solve the problem of  lack of priority given to records management, which is of long standing.
section_title: NARA Is Improving its Oversight Activity, but More Remains to Be Done
paragraphs: The effectiveness of NARA’s oversight activity has been improved by  recent initiatives. However, these initiatives have limitations, and NARA’s  oversight alone cannot solve the persistent problems facing federal  records management.
NARA has begun to increase its efforts to assess governmentwide records  management and its reporting of results. Although the Federal Records  Act gives NARA responsibility for oversight activities (including  inspections, surveys, and reporting), until recently, its performance of  these activities was limited. It has now completed its first governmentwide  records management self-assessment survey, resumed agency inspections  after a long gap, and increased its reporting. These new efforts have  provided NARA with a fuller picture of governmentwide records  management, including an assessment by agency of the risk of  unauthorized destruction of federal records; as a result, it is in a better  position to determine where records management improvements are most  needed, develop and update guidance, and hold agencies accountable by  publishing assessments of their records management programs. NARA  plans to use these oversight activities to develop baselines against which  to assess future progress; however, it has not yet developed plans for  adequately validating self-reported data or targeting inspections of agency  records and records management programs to achieve governmentwide  results. As NARA continues to build its oversight program, such activities  will be important to provide assurance that reported changes from  baseline scores reasonably reflect actual performance.
NARA also provides oversight through its appraisal and scheduling work  with agencies, in which it appraises agency records for their permanent  value (among other things) and reviews and approves agency disposition  schedules, in accordance with the Federal Records Act. Following an  extended effort to get agencies to submit schedules for unscheduled  systems containing electronic records, NARA has increased the number of  schedules it has approved per year, but nevertheless has an increased  backlog of schedules awaiting approval. NARA faces the risk that its  success in getting agencies to schedule their systems may result in more  schedules being submitted than it can handle in a timely manner. Unless  NARA assesses this risk and develops appropriate mitigation plans, the  backlog may increasingly hinder agencies’ records management.
Although NARA activities alone cannot solve the persistent problems  facing federal records management (agency heads are responsible for their  agencies’ records and records management), building and improving on  NARA’s oversight activities could help both NARA and agencies more  effectively focus resources on areas needing improvement.
subsections: section_title: NARA Uses Surveys, Studies, and Inspections to Assess Governmentwide Records Management, but Limitations Remain to Be Addressed
paragraphs: Oversight addresses whether organizations are carrying out their  responsibilities and serves to detect other shortcomings. Our reports  emphasize the importance of effective oversight of government operations  by individual agency management, by agencies having governmentwide  oversight responsibilities, and by the Congress. Various functions and  activities may be part of oversight, including monitoring, evaluating, and  reporting on the performance of organizations and their management and  holding them accountable for results.
The Federal Records Act gave NARA responsibility for oversight of agency  records management programs by, among other functions, making it  responsible for conducting inspections or surveys of agencies’ records and  records management programs and practices; conducting records  management studies; and reporting the results of these activities to the  Congress and OMB. Consequently, as our previous work pointed out, it is  important for NARA to have a governmentwide picture of the state of  federal records management programs to help it to hold agencies  accountable, as well as to determine areas where its guidance needs  strengthening.
NARA has recently undertaken efforts to gather governmentwide  information to help it assess the status of federal records management and  risks of unauthorized disposition (including destruction) of records. In  September 2009, NARA sent the first of a promised series of annual  mandatory records management self-assessment surveys to 242 federal  records officers from cabinet-level agencies, agency components, and  independent agencies; the survey’s goal was to determine how effectively  agencies were meeting statutory and regulatory requirements for records  management. Agencies were asked 34 questions designed to obtain basic  information about agencies’ records management programs in five areas:  program management, records disposition, vital records, electronic  records, and e-mail records. NARA used the data collected to categorize  agencies according to the level of risk to records associated with the state  of agencies’ records management programs. According to NARA,  ineffective records management programs are the most significant  indicators of risk of unauthorized disposition of records.
NARA’s report on the self-assessment survey, released in April 2010,  described strengths and weaknesses in agencies’ records management  programs. It concluded that almost 80 percent of agencies were at  moderate or high risk of improper destruction of records; that is, the risk  that permanent records will be lost or destroyed before they can be  transferred to NARA for archiving or that other records will be lost while  they are still needed for government operations or legal obligations. In  particular, of the 220 (91 percent) federal agencies and components that  responded, 36 percent were at high risk in their records management  programs and 43 percent were at moderate risk. Overall, only 21 percent of  federal agencies and components responding were at low risk. For  electronic records, 39 percent were at high risk, and for e-mail, 48 percent  were at high risk. The Archivist referred to these results as “alarming” and  “worrisome”; in a subsequent oversight hearing, the director of NARA’s  Modern Records Program testified that the findings were “troubling” and  “unacceptable.”
NARA has also obtained governmentwide information on one facet of  records management—electronic records scheduling—through its efforts  to ensure that electronic systems holding records are scheduled. NARA  has periodically requested agencies to provide summary reports  documenting their progress. By September 30, 2009, NARA had received  electronic records scheduling reports from 160 of 240 federal agencies or  components for which it had been tracking electronic records scheduling,  for a 67 percent response rate. In June 2010, it summarized the results of  these reports. NARA determined that 25 percent were in the moderate to  high risk category for failing to schedule 90 percent or more of their  electronic records. Forty-two percent were rated low risk, and 33 percent  did not respond to NARA’s request for information.
These information-gathering efforts are important means for helping to  assess federal records management and risks to records. The 2009 self- assessment in particular provided NARA useful oversight information,  including a broad picture of governmentwide records management that  was not previously available. The self-assessment survey adds to NARA’s  ability to assess the risk of unauthorized destruction of records by  increasing its broad knowledge of the status of agency records  management programs; previously, although NARA’s regular work with  agencies on scheduling and disposition of records provided it insight into  agencies’ activities at the end of the records life cycle, NARA officials  agreed that its insight into records management at earlier stages—that is,  creation, maintenance, and use—had been more limited.
In addition, NARA’s work conducting the self-assessment survey raised  issues for further study, such as the role of the departmental records  officer and appropriate level of records management staffing. It also  provided NARA with important operational experience to apply to  improving further surveys. According to the survey report, the results of  the first few self-assessments will provide a baseline for records  management in the federal government and, along with findings from  agency inspections and records management studies, will allow it to  assess more thoroughly records management within individual agencies  and throughout the federal government. NARA has committed to  conducting the self-assessment survey annually, and it conducted a second  survey in May and June 2010 (at the time of our review, NARA had not yet  published the results of this second survey).
In addition, NARA has increased its reporting on the results of its  oversight activities. In the past, NARA had been reluctant to report  negative news about individual agencies’ records management, which we  attributed to an organizational preference for using persuasion and  cooperation when working with agencies. We noted that this reduced its  ability to hold agencies accountable. In contrast, this year NARA reported  fully on the results (both negative and positive) of its self-assessment  survey and its electronic records systems scheduling project. The current  reports not only provide summary results and analysis, they also list each  agency or component’s results individually. Also, besides sending the self- assessment report to the Congress and posting it on its Web site, NARA  made efforts to publicize the results, including announcements through a  press release, on Twitter, and on two blogs: those of the Archivist and of  NARA’s National Records Management Program. Further, the evaluation  sections in NARA’s performance and accountability reports for fiscal years  2008 and 2009 were more extensive than in 2007, and included sections on  challenges and risks. These sections discuss specific agencies where  NARA identified significant records management program risks and cases  of alleged unauthorized disposition of federal records. By widely reporting  results by agency, NARA has taken an important step toward improving  the visibility of records management to senior agency managers, the  Congress, and the public, potentially raising the priority that agencies  assign to records management.
Although instituting and reporting fully on annual self-assessment surveys  is a positive step, the initial survey had limitations. In its report, NARA  identified issues that it considered to affect the reliability and usefulness  of the data in its first self-assessment survey. Specifically:    Not all regulated agencies were covered. According to NARA, its list of  agency records contacts, to whom it sent the surveys, was not always  accurate: the distribution list was incomplete, and some people included  on the list were not responsible for their agencies’ records management  programs. In addition, NARA reported that some agencies did not return  surveys because they did not have an assigned records management  officer responsible for completing the task, they believed they were not  required to respond, or for other reasons, including inadvertent oversight.
Another issue involves the roles of departmental and component-level  records officers. According NARA officials, scoring was affected by issues  related to NARA’s level of knowledge of the responsibilities of each  department-level records officer. According to NARA, agencies of  comparable size and complexity might have one records officer answering  on behalf of the organization, or several component-level records officers  answering for each component. Some departments do not have a  departmental records officer. Some department-level records officers  responded for the entire organization, but, in at least one case, the  department-level contact did not respond and deferred to the components.
Some questions were unclear or inapplicable. Although NARA ran a focus  group and pilot test to obtain feedback on the survey questions, it reported  that responses and comments indicated that the wording of some  questions was unclear. For instance, some respondents answered “no”  when their comments indicated they should have answered “yes,” and vice  versa. In addition, NARA found that some questions on the survey were  not applicable to very small organizations (less than 100 FTEs), but a “no”  answer reduced their score, so that these organizations were penalized  inappropriately in the scoring.
NARA has taken steps to reduce the effect of these issues on the second  survey. According to NARA officials, they gathered additional information  on records contacts, including the areas covered by departmental records  officers, to ensure that the survey went to the appropriate contacts and  that NARA understood those contacts’ areas of responsibility. In addition,  the second survey included numerous definitions and revisions that,  according to officials, were intended to clarify the survey.
Another important limitation of the surveys as assessment tools is their  reliance on unvalidated self-reported data. In the first survey NARA did  little validation of agencies’ self-reporting. According to NARA, its  appraisal archivists reviewed the information provided by the agencies,  and their comments were incorporated into the analysis. However,  according to the survey report, NARA otherwise “took agencies at their  word and did not attempt to verify submissions.” For the second self- assessment survey (conducted in May–June 2010), NARA asked  respondents each to supply one item of documentation—the records  management directive or directives issued by the department—as  validation. According to officials, they expected to use these directives not  only to validate certain responses, but also for analysis of features such as  the age of the directives and extent they covered the requirements of the  C.F.R. Officials also told us they are considering asking for additional  documentation in future years, such as training curricula and internal  evaluation reports. An official said that besides examining the directives,  they validated answers for 5 of the 55 questions by comparing them with  records schedule information that they track in-house.
As NARA continues to perform self-assessment surveys, it will be  important for it to be assured that improvement (or deterioration) in  governmentwide and agency scores reasonably reflect actual performance.  Accordingly, validation of the results will be important both for the broad  assessment of federal records management and for the assessment of  individual agencies and programs. However, NARA has not yet developed  plans to use other means of validating responses, such as doing followup  interviews with respondents, requesting additional supporting documents,  or including questions in the survey on how response data were collected.  Without additional validation, confidence in the validity of the survey  results may be reduced, and they may be less effective for their intended  purposes.
subsections: section_title: NARA Has Shifted Efforts from Records Management Studies to Targeted Inspections, but Inspection Plans Are Limited and Still Under Development
paragraphs: According to NARA’s strategic records management plan, the agency is  to conduct records management studies to focus on cross-government  issues, to identify and analyze best practices, and to develop  governmentwide recommendations and guidance. For example, NARA  planned to undertake such studies when it believed an agency or agencies  in a specific line of business were using records management practices  that could benefit the rest of a specific line of business or the federal  government as a whole.
Since we last reported in 2008, NARA has conducted three records  management studies (see table 3).
In accordance with its plans, all of these studies are focused on records  management issues with wide application. In particular, flexible  scheduling (the first study in table 3) is a relatively recent approach that  allows so-called “big bucket” or large aggregation schedules (that is, a  single schedule would cover all records relating to a work process, group  of work processes, or a broad program area to which the same retention  time would be applied). According to officials, NARA used the results of  its study to update its original 2005 bulletin on this topic; the update was  released in May 2010. In contrast, the second study in table 3 (on  recordkeeping technologies) was not used to feed into guidance, but to  provide helpful information to agencies: in particular, on other agencies’  experience with implementing records management software and, in one  case, with e-mail archiving software being implemented at the Office of the  Secretary of Defense. The third study (on Web 2.0 use) was released in  September 2010; according to NARA, the study enabled the agency to  identify recommendations for future actions (such as clarifying the  definition of a federal record and integrating records management into  agency social media policy).
NARA recently shifted its efforts from performing studies to conducting  inspections. From 2005 to 2008, NARA set objectives for and performed  one or two records management studies in each fiscal year. For 2010 and  2011, NARA’s objectives did not include performing studies, but instead it  set an objective to perform one inspection in each year. According to  NARA officials, at the time the 2011 plan was developed, they had not  determined whether to conduct a study in that fiscal year or do additional  inspections; since then, they have decided to do additional inspections.
NARA’s plan to perform records management inspections in fiscal years  2010 and 2011 reflects a resumption of NARA’s agency inspection program  in response to our 2008 recommendation. NARA describes its new  program of inspections as taking a “targeted” approach, focusing on  particular aspects of records management at a given agency or agencies.  (In contrast, its previous approach involved more comprehensive reviews  of agency records programs.)
To set up the inspection program, NARA took a number of steps: it revised  its requirements, developed criteria for doing inspections, chose its first  inspection targets, and has begun performing inspections. NARA added a  new section of its regulations that defines the conditions under which it  may undertake an inspection and how the inspection will be initiated and  carried out with the agency. Under the final rule, published on October 2,  2009, “inspection” is defined as a formal review and report by NARA of an  agency’s recordkeeping processes that focus on significant records  management problems affecting records at risk that meet one or more of  the following criteria: (1) they have a direct and high impact on legal rights  or government accountability; (2) they are the subject of high-profile  litigation, congressional attention, or widespread media coverage; (3) they  have high research potential; or (4) they are permanent records with a  large volume, regardless of format.
For fiscal year 2010, NARA chose to perform two inspections, both at the  Department of Defense: an inspection at the Office of the Secretary of  Defense (OSD) looking at three aspects of records management and one at  the National Geospatial-Intelligence Agency (NGA). According to a NARA  official, the inspection at the NGA, planned to begin in 2010, will not be  completed until 2011. Table 4 describes these inspections.
At the time of our engagement, NARA had not issued planned reports on  the results of the OSD inspections, and, according to an agency official,  planning for the inspection at NGA was still in an early stage.
Resuming inspections is an important step, because inspections provide  information in more detail on actual performance and particular records  issues; however, the inspection program currently planned is limited.  NARA’s plan commits to conducting one inspection per year for fiscal  years 2010 and 2011, and officials told us they were considering one or two  inspections per year. According to one NARA official, NARA is unwilling  to commit to more inspections because it has other priorities for the  appraisal archivist staff, which also performs appraisals and scheduling,  conducts studies, and works on the self-assessment survey and other  special projects. (According to a NARA records management official, of  the 100 staff of the National Records Management Program, approximately  50 are appraisal archivists, who work with about 245 agencies or  components.)
NARA’s planning for its inspection program is at a high level and is still  under development. According to its 2009 methodology for self- assessments and inspections, NARA will develop a list of agency  inspection targets based partially on the self-assessment results, develop  inspection plans, and conduct inspections. The plan identifies 20  conditions that the records management staff is to consider to help  determine whether an agency may be an inspection candidate. (Examples  include nonresponses to NARA’s surveys, out-of-date agency records  management manuals, requests from an agency head, and unresolved  unauthorized destructions.) These are conditions that management is to  assess in making inspection decisions—a checklist of risk factors to  consider. According to agency officials, they expect to flesh out the  inspection methodology as they gain experience doing their first targeted  inspections in fiscal years 2010 and 2011.
However, the 2009 methodology does not define how NARA will  systematically target and leverage a limited number of inspections to help  achieve governmentwide results (one of its stated goals). For example, the  agency has not yet described how it might distribute inspections among  agencies or what topics it would like to cover over a period of years.  Similarly, although NARA plans to perform multi-agency inspections, it has  not yet developed plans to do so by, for example, defining key practices  and determining how to inspect these at multiple sites. NARA’s plan states  that self-assessment and inspection activities will help NARA monitor how  federal agencies manage their records, but it does not address how one or  two inspections a year would provide effective monitoring or how it would  best organize a limited number of inspections to accomplish this goal.
NARA activities alone cannot solve the persistent problems facing federal  records management, since agency heads are responsible for their  agencies’ records and records management, as well as for allocating  resources to these, and as we have pointed out in the past, records  management has historically received low priority. Nonetheless, shedding  light on the status of governmentwide records management can help focus  both agencies and NARA on areas needing improvement and the need to  devote resources to these areas. NARA’s renewed inspection program has  the potential not only to help motivate agencies to improve records  management, but also to contribute to the systematic collection of  comprehensive information for assessing progress. However, NARA’s  plans do not explain how it will systematically target and leverage a  limited number of inspections to help achieve its goals. Until it has a more  fully developed inspection methodology, NARA risks reducing the  potential effectiveness of inspections for improving records management.
section_title: NARA Is Addressing the Problem of Unscheduled Records, but Faces Backlogs in Approving Schedules
paragraphs: NARA oversees retention and disposition of all federal records through  records appraisal and approval of agency records schedules, processes  that are crucial both to the management of records in agency custody and  to the eventual preservation of permanent records in NARA’s custody.  NARA’s authority to approve disposition schedules provides it with the  ability to ensure that such schedules conform to its regulations.  NARA  has identified unscheduled records as an important indicator of the risk of  unauthorized destruction of records.
NARA has been making efforts to get agencies to schedule unscheduled  records in computer systems. This project, which it refers to as the  Electronic Records Project, was initiated in response to the requirements  of the E-Government Act. In December 2005 NARA issued a bulletin  requiring agencies by September 30, 2009, to submit records schedules to  NARA for all electronic systems of records existing as of December 17,  2005, and it has periodically requested agencies to provide summary  reports documenting their progress. After the 2009 deadline expired,  NARA issued, in February 2010, an additional bulletin reminding agencies  of their continuing responsibility to schedule all their electronic records  series and systems and requiring them to report semiannually on the status  of their electronic records scheduling activities.
In fiscal year 2009, the number of schedules received jumped from 549 the  previous year to 974, which NARA attributes to its efforts to hold agencies  to the September 2009 deadline. Although this result is encouraging, it also  led to an increase in NARA’s backlog of schedules to be processed and  approved. The number of schedules submitted increased by more than  400, while the number closed out increased by only about 100, from 402 to  501; as a result, the approval backlog increased from 575 to 1048. NARA’s  processing capacity reached a high of 501 schedules closed out in 2009, so  the current backlog represents about 2 years’ work for appraisal staff,  assuming that that they go on approving schedules at the current rate, and  that no other schedules are submitted in the meantime.
NARA’s schedule approval process occurs in four steps (see table 5)  involving professional analysis and judgment, as well as input from the  public.
NARA estimates that it generally takes approximately 6 months or less to  process simple schedules for records that are clearly temporary and do  not have legal rights implications, with almost 4 months of this time period  taken by the public comment process. It may take up to a year for NARA  to process large and complex schedules requiring closer review or eliciting  critical public comments. According to NARA, the median time for it to  approve a schedule has historically been about 300 calendar days.
NARA is trying to shorten its approval process and increase its capacity to  process schedules despite limited resources. It has about 100 people  working on records management, about half of whom work on appraisal  and scheduling. The director of the Lifecycle Management Division (within  Modern Records Programs) said the records management program aimed  to increase approvals of records schedules covering electronic records by  about 10 percent a year, and that staff are working on streamlining the  scheduling process. For example, the program has reduced the time  allowed for public comment by 15 days, and staff are using e-mail rather  than letters to communicate and send responses to requests from Federal  Register requesters. The official also described future projects, including a  project to improve the scheduling and appraisal workflow and a large  project to revise the General Records Schedules, which should have the  effect of reducing the number of schedules that agencies will have to  submit, thereby improving NARA’s ability to keep up with other submitted  schedules.
Although these efforts may help to streamline the process, the number of  records and systems that remain to be scheduled is likely very large.  Currently, the Director of Lifecycle Management said that they are unable  to estimate “the universe of electronic records,” although they are  confident that it is a “big number.” For example, in 2006, NARA requested  information from agencies on outstanding systems to be scheduled and  received answers from 54 agencies, for a total of about 8,500 systems.
Other indications also support the conclusion that many records remain  unscheduled. For example, NARA’s electronic records summary report  indicated that many electronic records were still unscheduled. As of  September 30, 2009, based on 240 federal agencies and components:    For 14 percent of agencies, schedules were submitted for 59 percent or  fewer of their e-records (these were characterized as high risk).
For 11 percent of agencies, schedules were submitted for 60 to 89 percent  of their e-records (these were characterized as moderate risk).
For 42 percent of agencies, schedules were submitted for 90 percent of  more of their e-records (these were characterized as low risk).    33 percent of agencies did not submit reports.
Further, NARA’s agency self-assessment indicated that 27 percent of  agencies responding had scheduled fewer than half of their electronic  systems. The survey did not ask for the numbers of systems remaining  unscheduled; however, NARA’s February 2010 bulletin requires agencies  to list unscheduled systems. As agencies comply with this requirement,  such lists should provide a basis for a better estimate.
NARA thus faces the risk that if its efforts to get agencies to submit  schedules for outstanding agency systems continue to be successful, it will  be unprepared to deal with the workload. The jump in its backlog  associated with the 2009 deadline for scheduling electronic systems  suggests that this is a real concern. NARA has acknowledged that in light  of the volume and complexity of electronic records increasing each year,  keeping pace with the requirements to schedule all existing electronic  records is a continuing challenge for both NARA and agencies. However,  it has not assessed the risk that it may be unable to keep up with  schedules submitted, nor has it developed plans to mitigate that risk.  Unless it does so, the risk increases that the backlog may increasingly  hinder agencies’ records management—for example, they may be required  to retain records unnecessarily that they would otherwise be authorized to  dispose of, and they may be delayed in transferring permanent records to  NARA.
section_title: NARA’s Ability to Preserve Federal Records Is Strained by Volume of Records, Finite Resources, and Technology
paragraphs: NARA faces challenges in preserving permanent records in its  possession—both paper and electronic—largely because of the sheer  volume of federal records, the finite resources available to deal with them,  and the technological challenges posed by electronic records. NARA has a  large and persistent backlog of records in paper and other media needing  preservation actions. It has developed priorities for preserving physical  records based on factors such as their demand and condition, but it does  not foresee being able to accomplish those priorities. As a result, large  numbers of physical records requiring preservation remain at risk. In  addition, as we have previously reported, its development of the  Electronic Records Archives is still ongoing, including the development of  a preservation framework for electronic records. Until ERA and its  electronic preservation capabilities are fully implemented, there is  reduced assurance that NARA can ensure the preservation of all electronic  records.
subsections: section_title: The Volume of Physical Records Needing Preservation Actions Has Led to Large Backlogs
paragraphs: According to NARA, preservation encompasses the activities that prolong  the usable life of archival records. Preservation activities are designed to  minimize the physical and chemical deterioration of records and to  prevent the loss of informational content. For physical records, an  important part of preservation is holdings maintenance, defined as those  preservation actions that are designed to prolong the useful life of records  and to reduce or defer the need for laboratory treatment by improving the  physical storage environment. These actions include replacing acidic  storage materials such as file folders with materials of known quality that  meet NARA specifications, improving shelving practices, removing  damaging fasteners, and reproducing unstable materials such as  Thermofax copies onto stable replacement materials. In addition,  preservation may involve removing fragile records from use by capturing  the information in a new format. NARA may duplicate motion picture film,  still photos, microfilm, and sound and video recordings; reformat audio  and video recordings that are in formats that cannot be used on currently  available playback equipment; and generate digital images of records.
NARA’s approach to preserving physical records and media (such as paper  records, videotapes, microfilm, maps, charts, and artifacts) is to examine  holdings to assess their preservation needs; provide storage conditions  that retard deterioration; and treat, duplicate, or reformat records at high  risk for loss or deterioration (for example, film and microfilm, audio  recordings that require obsolete equipment, videos, brittle and damaged  paper records, and motion pictures). Some of the factors influencing the  rate at which NARA performs maintenance and preservation treatments,  according to the agency, include large accessions of at-risk records,  increased demand for the digitization of records, and high public interest.
The number of physical records requiring some degree of preservation  activity has led to a backlog in preservation actions. In 2009, NARA  reported that 65 percent of its archival holdings were in need of some  preservation action. NARA defined “in need of preservation action” as  that there was an imminent threat to the record, and the information it  contained could not be accessed due to condition. According to NARA, it  was conservative in this assessment, focusing on whether records could  be safely served to researchers in their existing state and housing. For  example, even though poor quality, chemically unstable boxes are not  ideal for archival preservation, they would not be considered to require  preservation action (that is, replacement); however, a box that did not  adequately support the records would, since records that are not well  supported are likely to be damaged.
NARA has set a strategic goal of reducing the backlog to 50 percent by  2016. However, there is little assurance the goal will be met. The 65  percent figure has remained almost constant since NARA established a  baseline. In fiscal year 2009, NARA reported treating nearly 116,000 cubic  feet of at-risk archival records. Nonetheless, as additional records were  accessioned, the percentage of backlog remained essentially constant, and  the actual amount of holdings requiring preservation action grew from  about 2.4 million cubic feet in 2008 to about 2.6 million cubic feet in 2009.  Further, in its 2008 preservation plan for nontextual holdings (maps,  photos, audio, and video), NARA noted that 54,000 cubic feet of these  records needed preservation actions, and that even addressing only the  highest priority items (about 25 percent) exceeded its staff resource  capabilities.
Over the past year, NARA increased the staff performing holdings  maintenance (preservation activities such as rehousing at-risk materials)  from about 8 to 18 dedicated staff (according to officials, some additional  staff also devote part of their time to holdings maintenance). Nonetheless,  there is little assurance that NARA will be able to meet its goal of reducing  the backlog to 50 percent by 2016, and in any case, large numbers of  permanent records will remain at risk for the foreseeable future.
section_title: Electronic Records Preservation Will Remain a Challenge
paragraphs: Preservation of electronic records presents significant challenges because  these records are stored in specific formats and cannot be read without  software and hardware—sometimes the specific types of hardware and  software on which they were created. This hardware and software can  vary not only by type but by generation of technology: the mainframe, the  personal computer, and the Internet. Each generation of technology has  brought in new systems and capabilities, and over time, hardware,  software, storage media, and file formats become obsolete.
NARA is still developing the means to preserve permanent electronic  records—the Electronic Records Archives. ERA achieved initial  operational capability of the first two phases of the five-phase  development, but the preservation component of the project is still being  developed. The former CIO told us that in her view, the preservation  module would be the most difficult to implement of the system’s  functional areas. This module is to enable secure and reliable storage of  files in formats in which they were received, as well as creating backup  copies for off-site storage.
Part of the preservation challenge is developing ways to ensure access to  the most important formats, which NARA intends to do through various  means, such as encouraging the use of sustainable formats and using  viewers and transformation. According to the conceptual framework for  ERA preservation, NARA will encourage creating entities to transfer  records to NARA using sustainable formats—that is, formats that are  relatively resistant to obsolescence and can reasonably be expected to be  usable for some period of time. However, the framework recognizes that  in many cases, this will not happen, and so ERA will need to ingest a broad  range of formats. After files are ingested, the intent is to transform records  as necessary into formats that are sustainable. Since transformation is the  most expensive strategy for providing access to records, NARA plans to  consider transforming electronic records only if the data file format is at  risk of obsolescence, users require an enhanced level of access, or both.  NARA expects to be able to preserve “all the bits” of electronic files that it  accessions, but it will not be able to guarantee that all formats will be  immediately or permanently accessible.
Further, we recently reported that NARA planned to begin development  of ERA’s preservation framework in 2010 and complete it in 2011, but that  the plan did not contain specific dates for completion or identify the  associated capabilities that are to be delivered. As a result, we expressed  doubt that the completed ERA system would be delivered by 2012 with the  originally envisioned capabilities. Most recently, ERA has been listed by  OMB as a high-priority project that has the potential for faster, smarter  implementation. Properly implementing our outstanding  recommendations related to strengthening requirements management  and earned value management could help the ERA project meet its  performance goals within reasonable funding and time constraints. Until  ERA and its preservation module are complete, it will remain uncertain  whether NARA will be able to effectively preserve all permanent  electronic records in such a way that the information is accessible.
section_title: In Key Management Areas, NARA Has Policies and Procedures that Are Consistent with Its Strategic Planning, although Gaps Remain
paragraphs: NARA’s policies and procedures for key aspects of governance, human  capital, and collaboration are generally aligned with its strategic planning,  but selected areas have gaps. With regard to governance policies and  procedures, NARA has defined and delegated areas of authority and  responsibility that are generally aligned with its strategic plan, but it is not  managing risk at the enterprise level. In addition, it has developed a  strategic human capital plan that is consistent with our human capital  strategic framework, but its implementation of the plan has been delayed,  so that the agency is not yet managing human capital strategically. To its  credit, NARA is taking advantage of numerous collaboration opportunities,  which are generally aligned with the goals and strategies in its strategic  plan. If NARA addresses the identified gaps in governance and human  capital, it will be better positioned to achieve its goals.
subsections: section_title: NARA Has Policies and Procedures Defining Key Aspects of Governance, but It Lacks an Enterprise Risk Management Capability
paragraphs: We have previously described governance as the process of providing  leadership, direction, and accountability in fulfilling an organization’s  mission, meeting objectives, and establishing clear lines of responsibility  for results. Further, our prior work has established that enterprisewide  risk assessment and management is a key part of governance.
subsections: section_title: NARA’s Lines of Responsibility Are Generally Aligned with Its Strategic Planning
paragraphs: Strategic planning and management can help agencies effectively manage  resources and fulfill their missions, and, since the mid-1990s, we have  reported on leading practices for effective strategic planning and  management, including establishing long-term goals, identifying and  developing strategies to address key management challenges, and aligning  resources and activities to agency goals.
NARA has a strategic plan and a process for aligning its organization and  lines of responsibility to support its goals. The agency’s recently updated  strategic plan governs its activities until 2016 and details six strategic goals  (see table 6) and 46 specific strategies it will use to achieve these goals.
Specific strategies support each of these goals. These strategies include,  for example,   “we will continue to make the business case at senior levels throughout  the Federal Government that records and information are important  Government assets and that records management is an important tool,”  “we will ensure that all of our holdings are in appropriate space,”  “we will identify permanently valuable electronic records wherever they  are, capture them, and make them available in usable form as quickly as  practical,” and  “we will identify and implement the cultural changes that we need to  better serve our customers in a changing environment.”
NARA has also established policies and procedures that define its  organization and determine lines of authority and areas of responsibility.  Responsibilities at the agency are approved by the Archivist through a  defined process and are codified, along with the change process, in NARA  Directive 101: NARA Organization and Delegation of Authority. For tasks  that cut across organizational structures, NARA has procedures for setting  up committees, task forces, and working groups, which are governed by  charters establishing their goals and membership. It has a directive  governing creation of these charters.
Generally, NARA’s organization and lines of responsibility were aligned  with its strategic plan. Of 21 specific strategies that we examined, 17 were  under clearly documented lines of authority and were assigned to  appropriate offices by the agency’s policies, with 4 strategies lacking  clearly documented lines of responsibility (see table 7).
According to NARA officials, they did not consider that some of these  strategies required specific assignments of responsibility, either because  they were global responsibilities or because they were good business  practices. However, clear statements of responsibility are important for  implementing these strategies. We have previously reported that a  dedicated implementation team assisted by supporting teams, such as  functional or crosscutting teams, is a key practice in implementing cultural  transformations. Assigning responsibility for these strategies to  appropriate offices would help to provide assurance that they are  appropriately carried out.
section_title: NARA Does Not Manage Enterprise Risk on a Continuous Basis
paragraphs: Enterprisewide risks are those that would threaten an organization’s  ability to carry out its mission, such as an act of terrorism, loss or  compromise of critical information (such as classified or personally  identifiable information), or a natural disaster. Risk management is the  continuous process of assessing such risks, reducing the potential that an  adverse event will occur, and putting steps in place to deal with any event  that does occur. Without an effective program of risk assessment and  internal control, management may have less assurance that it is using  organizational resources effectively and efficiently, or that agency assets  and operations are protected. As our previous work has shown, and as  called for by the Standards for Internal Control in the Federal  Government, agencies should continuously and systematically monitor  their internal and external environments to anticipate future challenges  and avoid potential crises.
GAO has developed a framework for risk management (see figure 3) that  identifies five major phases: (1) setting strategic goals and objectives, and  determining constraints; (2) assessing the risks; (3) evaluating alternatives  for addressing these risks; (4) selecting the appropriate alternatives; and  (5) implementing the alternatives and monitoring the progress made and  results achieved.
Our work has shown that decisions for enterprisewide risk management  should be made in the context of an organization’s strategic plan, and  organizations should have risk planning documents that address risk- related issues that are central to the organization’s mission.
According to NARA program officials, NARA currently performs risk  management for the ERA project, its major system investment. The agency  manages ERA’s risks using an agency-level risk review board, a program- level risk review board, and a technical risk review team. In addition,  officials stated that the ERA program office produces monthly reports that  include top identified risks and specify associated mitigation strategies.  Risk status is communicated to senior NARA management and OMB on a  monthly basis and Congress on a quarterly basis. The project uses an  automated tool to track and manage risk.
However, although NARA has identified important risks facing the agency,  it currently has no dedicated active function to manage these risks at the  enterprise level. Some risks of which NARA is aware include  technological change causing record formats to become obsolete and  unreadable,  failure of the ERA project, and   effects of climate change or natural disasters (such as on continuity of  operation, preservation requirements, locations of facilities, and energy  use).
According to NARA officials, the organization had a risk review board,  which existed for about 2 years, but it became inactive. This occurred  because the board’s discussion of risk tended to focus either on project  and program risks or highly generic risks.
NARA officials told us that the agency has also relied on a work group of  senior executives, the Lifecycle Guidance Team, to address enterprisewide  risks. However, as currently established, the Lifecycle Guidance Team  does not explicitly focus on enterprise risk management. The members of  this team, chaired by the Deputy Archivist, are members of NARA’s senior  staff. However, although the team is at an appropriate level of seniority  to address enterprise risk management, this function is not part of its  charter. According to the charter, the group focuses on ensuring that  NARA’s records lifecycle initiatives are effectively coordinated, integrated,  and implemented agencywide, and it provides leadership and oversight to  initiatives to advance the agency’s mission and strategic goals and improve  records, information, and knowledge management governmentwide.  Among the initiatives it is reviewing or has reviewed are systems in  operation or in development, for which project risks have been discussed.  However, these risks are not enterprise risks.
According to NARA officials, the development of a new process and  system for internal control has recently been proposed. The process and  system, to be based on a similar system at the Library of Congress, are  intended to automate internal controls and would include assessment and  categorization of risk on the functional level. According to the officials,  such an implementation would benefit NARA’s risk management and  internal control capabilities. This proposal has been reviewed by senior  management, but is still in the first stages of planning and does not yet  include a clear picture of which divisions will be responsible for dealing  with strategic risks. At the time of our report, agency officials also  acknowledged that NARA has neither completed a time frame for  implementation nor established an estimated finish date.
Unless NARA begins to manage its enterprise risks on a continuous basis,  there is a greater likelihood that serious threats to NARA may not be  addressed.
section_title: NARA Is Addressing Human Capital Issues, but Implementation of Strategic Human Capital Management Is Only Beginning
paragraphs: The success of any organization depends on effectively leveraging people,  processes, and tools to achieve defined outcomes and results. For people  to be effectively leveraged, they must be treated as strategic assets. An  agency’s strategic human capital plan establishes an agencywide vision  that guides workforce planning and investment activities.
As our previous work has shown, a strategic approach to human capital  management enables an organization to be aware of and prepared for its  current and future human capital needs, such as workforce size,  knowledge, skills, and training. Sound human capital strategic planning  provides the essential context for making sensible, fact-based choices  about designing, implementing, and evaluating human capital  approaches. It is critical to ensuring that agencies have the talent and  skill mix they need to address their current and emerging human capital  challenges.
Our research shows that to be effective, a strategic approach should use  data-driven methods to (1) assess the knowledge and skills needed;  (2) inventory existing staff knowledge and skills; (3) forecast the  knowledge and skills needed over time; (4) analyze the gaps in capabilities  between the existing staff and future workforce needs, including  consideration of evolving program and succession needs caused by  turnover and retirement; and (5) formulate strategies for filling expected  gaps, including training and additional hiring. (Figure 4 is an overview of  verview of  this process.)  this process.)
Inventory of existing  workforce capabilities In August 2009, NARA published its first Strategic Human Capital Plan,  which covers fiscal years 2009 through 2014. Linked to the agency’s overall  strategic plan, this strategic plan discusses strategies for achieving each of  its five human capital goals: strategic alignment, leadership and knowledge  management, results-oriented performance culture, talent management,  and accountability.
The strategic plan includes a set of improvements that would give NARA  the capability to strategically manage its human capital, as called for in our  human capital framework. Specifically, section 3, “Workforce Planning,”  includes all five of the elements of our strategic human capital framework.  The plan also includes related goals, such as being able to hire people  faster by automating manual and paper-based processes; NARA’s Director  of Human Resources cited this as one of the agency’s highest priorities.
The agency has taken some initial steps to implement its plan. For  example, it has completed a pilot of a competency development approach  in which it modeled the competencies required for all positions in the  Modern Records Program and in the Information Security Oversight  Office; it is currently assessing the accuracy and effectiveness of the  competency models developed under the pilot. Modeling competencies— determining the skills needed for specific positions—is a key tool for  determining what skills NARA will need to meet organizational goals.  Once competency modeling is completed, NARA will be in a position to  forecast future workforce skills needs. It is also currently finalizing  guidance for workforce planning, another part of the process of  forecasting future workforce needs. Finally, it has completed a pilot for an  online training needs assessment tool. The results are currently being  analyzed, and a report is tentatively scheduled for September.
However, NARA is falling behind in the implementation of its human  capital management milestones. For fiscal year 2010, NARA set 72  milestones for implementing the strategic plan. However, as of the end of  the third quarter, 23 milestones had been met, 14 were missed, 3 future  milestones were pushed further back, and 8 had other weaknesses, such  as lacking a specific date or status update. Of the remaining 24, some are  not due yet, and some were periodic actions with no single due date (see  figure 5). An example of a missed milestone specifically related to our  strategic human capital framework is the development of an agencywide  workforce plan that includes a hiring projections worksheet. In addition,  NARA has not completed an inventory of existing workforce skills.  Without a complete skills needs forecast and a current skills inventory, it  cannot perform a gap analysis and consequently cannot plan future human  capital initiatives, three of the steps of our strategic human capital  framework.
The agency’s human capital officials stated that milestones had been  missed or pushed back because they had to address other priorities,  including realigning staff to address the requirement to comply with the  Office of Personnel Management’s (OPM) 2009 Hiring Reform and the May  2010 Presidential Hiring Reform Initiatives.
To its credit, in responding to these initiatives, NARA is making progress  on addressing its hiring process. Hiring is an important part of strategic  human capital management, since hiring is a critical tool for addressing  skills gaps. According to NARA, as of September 2009, it had an overall  average time to fill a position of 163 to 213 days. In contrast, the model set  up by OPM called for an 80-day hiring process. Responding to OPM’s 2009  Hiring Reform, NARA’s Hiring Process Action Plan (submitted to OPM in  December 2009) identified primary barriers to a timely and effective hiring  process. According to the plan, an important barrier was the agency’s  paper-based application process, including manual routing of forms.  During NARA’s hiring process, its staff manually printed, reviewed, and  annotated hundreds of applications at several stages in order to verify and  screen applications. The agency also experienced a 45 to 90 day backlog of  hiring actions, which NARA officials attributed largely to reliance on  paper-based hiring systems. NARA determined that without an automated  staffing system to screen applications, addressing the other barriers  identified in its action plan would have only a marginal impact on its  overall time to fill a position.
To address this barrier, NARA piloted and implemented automated hiring  software, called USA Staffing, provided by OPM. This Web-based system  automates the recruitment, assessment, referral, and notification  processes, reducing the degree of human intervention required in the  hiring process. According to NARA, the agency implemented the USA  Staffing tool in May 2010, and as of July 2010, it reported reducing the  average time-to-hire to 126.5 days. Agency human capital officials told us  they believed further reductions were likely as the staff becomes more  familiar with the new tool.
NARA continues to work on its hiring process in response to the May 2010  Presidential Hiring Reform Initiative, which set a deadline of November 1,  2010, for federal agencies to adopt certain streamlined hiring procedures,  including eliminating knowledge, skills, and abilities (KSA) essays,  allowing applicants to apply using resumes and cover letters, and involving  the managers and supervisors responsible for hiring in the complete hiring  process.
Agency human capital officials believe that these improvements will result  in a more efficient hiring process. However, the reforms under the  Presidential Initiative are still ongoing. Further, because the adoption of  the new staffing system is still recent, it is not possible to fully evaluate its  impact.
In addition, for the hiring process to be fully effective, it is important that  NARA implement its strategic human capital plan and particularly that it  complete its skills needs analysis and gap analysis. Such analyses are  crucial for effectively determining hiring needs; they are also important for  helping determine how to allocate personnel to mission areas in which  NARA has identified resource-related backlogs, such as records  management and preservation. Until NARA completes these analyses,  there is no assurance that the agency will be able to manage its human  capital strategically, ensuring that it has staff with the right competencies  to perform its mission now and in the future.
section_title: NARA Engages in Collaborative Efforts That Further Strategic Goals
paragraphs: As a small agency with a broad mission, NARA has stressed the  importance of collaborative efforts in achieving the organization’s goals. In  his preface to the agency’s strategic plan, the Archivist refers to the  importance of involvement with the archival and records management  communities as well as other stakeholders, stating that partnerships at all  levels of the organization will add depth and richness to NARA’s programs  and initiatives. The strategic plan itself emphasizes collaboration and  partnering. It spells out six strategic goals, for each of which the plan  describes a number of specific strategies. For five of the six goals in the  strategic plan, either one or two of the specific strategies are directly  related to collaboration and partnership; table 8 shows the specific  strategies associated with each strategic goal.
NARA has established or begun to establish collaborative efforts that are  generally aligned with all these goals and strategies. For example, for the  third strategic goal, which focuses specifically on electronic records, the  specific strategy related to collaboration is to partner with agencies,  research institutions, and private industry to develop, implement, manage,  and promote NARA’s electronic records program. According to its  workplan, multiple efforts in this area are planned to be managed by  NARA’s Center for Advanced Systems and Technologies (NCAST) within  the Office of Information Services. NCAST serves as lead for collaborating  in information technology research and development with  governmentwide, interagency, professional, and academic organizations.  Among other things, NCAST is to organize, sponsor, and participate in  research in computer science, archival science, and related technologies  capable of improving the lifecycle management of records.
In support of this responsibility, NCAST has both planned and completed  collaborative research agreements with partners that include federal  organizations and consortia, industry, and academia, including the  National Science Foundation. For example, NCAST has worked with the  Records Management Services Working Group of the Object Management  Group (OMG), an international, open membership, not-for-profit  standards-setting consortium of the computer industry and other  information technology organizations, on the creation of new software  specifications for records management. The working group identified  and documented key requirements for records management functionalityin systems that manage electronic records. NCAST is also a member of th e  Networking and Information Technology Research and Development  Subcommittee of the National Science and Technology Council’s  This organization is a collaborative effort of  Committee on Technology. more than a dozen federal research and development agencies that fund  research in advanced information technologies such as computing,  networking, and software.
Examples of other collaboration efforts related to this strategy include two  other groups. One of these is the NARA-chaired Advisory Committee on  the Electronic Records Archives. According to its charter, this committee  brings together experts from many different fields to make  recommendations to the Archivist on development of ERA, and its  membership includes experts from private organizations with an interest  in records management, members of academia, researchers, and state  officials with responsibility for electronic records. NARA also established  the Federal Records Council to provide advice and support from other  federal agencies to the Archivist on all aspects of records management,  with special emphasis on the management of electronic records.  Membership on the council, as stated in its charter, includes  representatives from OMB and GSA, officials from cabinet-level  departments, and representatives from communities such as science,  intelligence, and the federal court system. Several other organizations  outside of these groups have also sent members to Federal Records  Council meetings. Members are departmental records officers and officials  from other divisions with records management responsibilities, such as  information technology, information security and privacy, and Web  content. According to its charter, the council contributes strategic advice  and support to the Archivist in issuing records management guidance, and  provides a mechanism for agencies to work together to identify strategies  and best practices for electronic information and records issues.
In one instance (the second strategic goal, involving the accessioning and  processing of records), NARA did not set a specific strategy related to  collaboration. However, in discussing this goal, the strategic plan refers to  seeking out and developing partnerships to assist in improving work  processes to deal with a backlog of holdings that had been accessioned, or  legally transferred to NARA’s possession, but not yet processed.  (Processing involves such steps as flagging records based on  classification, providing enhanced descriptions of the content of the  records, and making records available to the public.) In support of this  goal, NARA has established, for example, a working agreement with a  private company through which the company would provide metadata for  digitized NARA information according to the agency’s standards.  According to an official, having these metadata would provide the agency  with more information about the content of the records, which assists in  their processing.
Table 9 summarizes NARA’s collaborative efforts related to its strategic  goals and provides examples.
NARA’s Open Government Plan describes further collaborative initiatives  in addition to these. Issued in response to the Open Government  Directive, NARA’s Open Government Plan describes its efforts aimed at  increasing transparency, participation, and collaboration in government.  Among these is a collaboration with the Department of Justice on the  development of a dashboard that would provide information on agencies’  performance in fulfilling Freedom of Information Act requests. Another is  collaborating with academic law and policy groups, such as the Legal  Information Institute at Cornell University and the Center for Innovative  Technology Policy at Princeton University.
Furthermore, in accordance with the open government principles of  transparency, participation, and collaboration, NARA has established new  collaborative efforts with the public. For example, according to its Open  Government Plan, NARA used Ideascale, a commercial collaboration  platform, to gather perspectives from the public on the content of the plan.  It has also established blogs and a wiki to further collaboration both with  the public and other agencies. Its NARAtions blog and its Our Archives  wiki are addressed to the public and research community that uses its  archival holdings, both providing information and soliciting input. Its  Records Express blog shares information and solicits comment from the  federal records management community.
section_title: Conclusions
paragraphs: NARA has taken steps to expand its oversight activities and improve their  effectiveness. Although it cannot by itself ensure that agencies are  managing records appropriately (agencies control and are responsible for  their own records), NARA can use its oversight activities to help determine  where records management improvements are most needed and improve  its ability to influence agencies to give more priority to records  management programs. This will require that it continue to build and  improve its oversight activities, including studies, surveys, inspections,  and reporting. As NARA continues to refine its approach to oversight, it  will be important for it to consider how to validate self-assessment data  (for example, by doing followup interviews) and how to strategically plan  inspections to maximize their value as oversight tools, by, for example,  defining key practices and inspecting these at multiple sites. Further, it  will also be important going forward for NARA to assess the risk that its  capacity to process and approve schedules may not be sufficient to meet  the demand.
As an agency with a broad mission, NARA faces numerous challenges, for  which its strengths in seeking collaborative opportunities should be  helpful. Further, NARA’s organizational responsibilities are generally  aligned with its strategic plan, and it has developed a human capital  strategic plan that, if implemented effectively, would give NARA the  capability to strategically manage its human capital, as called for in our  strategic human capital framework. However, there are opportunities for  improvement. For a few specific strategies, NARA has not yet established  clear lines and assignments of responsibility. In addition, the lack of  adequate enterprisewide risk management leaves the agency vulnerable to  a variety of risks that may not be foreseen or mitigated. Further, until  NARA has implemented the capability to manage its human capital  strategically, the risk remains that it will not have the staff with the skills  needed to meet present and future mission needs.
section_title: Recommendations for Executive Action
paragraphs: To help NARA improve its management and oversight capabilities, we are  recommending that the Archivist of the United States take the following  six actions:    To help ensure that its future assessments of the status of  governmentwide and agency records management are accurate, develop  additional means to validate the self-reported data in its surveys.
To ensure that its inspections program helps provide a comprehensive  view of federal records management and greater impetus for agency  improvement, develop a plan, with milestones, that provides for  systematically and strategically targeting inspections to maximize their  value as oversight tools.
To help ensure that it can manage the backlog in the scheduling process,  assess the risk that it will be unable to keep up with schedules submitted  and develop plans to mitigate that risk, if indicated.
To ensure that its organization and governance reflect its strategic goals  and strategies, ensure that all the specific strategies in its strategic plan  have clear lines and assignments of responsibility.
To ensure that NARA’s senior staff and decision makers can appropriately  and quickly assess threats and vulnerabilities stemming from enterprise  risks, develop and assign responsibility and resources for an  enterprisewide risk management capability that allows it to monitor its  internal and external environments continuously and systematically.
To ensure that it has the appropriate skills and staff to meet present and  future needs, give priority to completing its skills, needs, and gap analyses  and developing a plan to fill those gaps.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments on a draft of this report from the Archivist  of the United States. In these comments (reproduced in appendix II),  NARA concurred with the six recommendations in the report. The  Archivist stated that to address them, NARA plans to (1) develop and  implement additional means to validate self-reported data from self- assessment surveys in fiscal year 2011, (2) develop a plan for  systematically and strategically targeting inspections to maximize their  value, (3) conduct a study of the risks associated with the backlog in its  records scheduling process, and develop mitigation plans, (4) review the  current strategic plan to make sure it can tie strategies to specific actions  and targets, (5) roll out an enterprisewide internal controls program that  uses risk assessment as an integral part of managing and monitoring  internal controls, and (6) consider using an existing contract to draw in  additional resources to assist NARA with completing its competency  modeling initiative.
The agency also supplied technical comments, which we have  incorporated as appropriate in the final report.
As agreed with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from the  date of this letter. At that time, we will send copies of the report to  interested congressional committees, the Archivist of the United States,  and other interested parties. In addition, the report will be available at no  charge on the GAO Web site at http://www.gao.gov.
If you or your staff have questions about this report, please contact me at  (202) 512-6304 or melvinv@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to (1) assess the National Archives and Records  Administration’s (NARA) effectiveness in overseeing the governmentwide  management of records, including commenting on its capacity to identify  risk of unlawful destruction of federal records; (2) describe its ability to  preserve permanent records; and (3) assess its policies, procedures, and  plans supporting key management and oversight capabilities: governance,  human capital, and collaboration.
For all of our objectives, we reviewed NARA documentation of its records  management and preservation activities, interviewed agency officials, and  reviewed prior reports by us and others.
We reached out to the federal records management community to obtain  information on several issues. We obtained views of selected federal  government records managers by contacting records officials at several  components of the Department of Defense (DOD) and through an online  survey of members of the Federal Information and Records Managers  Council (FIRM), an organization of federal records managers.
We also convened a panel of experts to obtain information about records  management challenges and best practices and NARA’s oversight of  federal records management programs. We worked with the National  Academy of Sciences to choose a diverse group of panel members. The  method for this was an iterative discussion with representatives of the  Computer Science and Telecommunications Board at the National  Academy of Sciences to determine which experts had expertise in areas  most applicable to our objectives. The final panel included several former  NARA employees, representatives of federal agencies that deal directly  with NARA, and records management experts from the private sector and  academia. The panel also included an expert in electronic records  management, as well as one from the Smithsonian, the mission of which is  similar to NARA’s in terms of records preservation.
To assess NARA’s effectiveness in overseeing governmentwide records  management we examined its use of the activities defined in 44 C.F.R. 29:  surveys, studies, inspections, and reporting. We obtained input from the  expert panel, from records managers at DOD, and from our survey of  FIRM members. We also examined NARA’s process for approving records  schedules and compared the numbers of schedules it has approved in  recent years with estimates of the numbers of outstanding records series  and systems. To comment on NARA’s capacity to identify risk of unlawful  destruction of federal records, we reviewed applicable laws, reviewed the  results of the agency self-assessment survey, and met with NARA records  management staff to identify risk factors.
To describe NARA’s ability to preserve permanent records, we met with  NARA preservation staff and obtained input from the expert panel. We  reviewed and assessed the reliability of NARA’s survey of its preservation  needs and its backlog, and we analyzed its ability to process its backlog.  To assess NARA’s ability to preserve electronic records, we reviewed  external research and standards related to electronic records issues,  interviewed staff involved in development of the Electronic Records  Archives (ERA), and drew on our previous reports about the status of the  ERA development process.
To assess its policies, procedures, and plans supporting key management  and oversight capabilities (governance, human capital, and collaboration),  we did the following:    We assessed NARA documents relating to governance, including strategic  planning and policy documents, against requirements of the Government  Performance and Results Act (GPRA) and our risk management  framework. To assess whether NARA organization and performance  measures were aligned with its strategic plans, we examined NARA’s  directive that assigns responsibilities, as well as charters of temporary  task forces, to determine whether lines of responsibility were clearly  delineated for specific strategies in the strategic plan. We compared  NARA’s risk management activities against GPRA requirements and our  risk management framework.
We evaluated NARA’s human capital management capabilities and its  Human Capital Strategic Plan against our strategic human capital  framework. We interviewed the Director, Human Resources Services  Division, and the Director, Staff Development Services, and other officials.  To assess NARA’s progress in implementing needed strategic human  capital capabilities, we reviewed progress in implementing its Strategic  Human Capital Plan against the plan’s milestones. We also analyzed  NARA’s hiring process against Office of Personnel Management criteria,  and examined the effects of reported recent improvements in the hiring  process.
We evaluated NARA’s collaboration capabilities by interviewing policy and  planning staff, and analyzing agency policies and procedures related to  collaboration. We obtained a list of NARA collaborative projects and  examined whether collaborative activities specified in the strategic plan  were being carried out.
We conducted this performance audit from October 2009 to October 2010  in the Washington, D.C., metropolitan area in accordance with generally  accepted government auditing standards. Those standards require that we  plan and perform the audit to obtain sufficient, appropriate evidence to  provide a reasonable basis for our findings and conclusions based on our  audit objectives. We believe that the evidence obtained provides a  reasonable basis for our findings and conclusions based on our audit  objectives.
section_title: Appendix II: Comments from the National Archives and Records Administration
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, key contributors to this report  were Barbara Collier (Assistant Director), Shaun Byrnes, Kami Corbett,  Neil Doherty, Rebecca Eyler, Jason Kirwan, Lee McCracken, Glenn  Spiegel, and Walter Vance.