Information Management: Additional Actions Are Needed to Meet Requirements of the Managing Government Records Directive
Released: 2015-05-14T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: The federal government collects large amounts of information, increasingly in electronic form, to accomplish its missions. This greater reliance on electronic communication and information technology systems has, as a result, radically increased the information that agencies must manage. In 2012, NARA and OMB issued a directive to reform federal records management in response to a 2011 presidential memorandum on managing government records. The directive requires federal agencies, NARA, OMB, and OPM to take actions toward reforming records management policies and practices.

GAO was requested to evaluate federal agencies' implementation of the directive. GAO's objectives were to (1) assess the extent to which federal agencies have taken the actions called for in the directive and (2) determine the extent to which OPM, OMB, and NARA have taken actions called for in the directive. To do this, GAO reviewed policies, guidance, and other documentation of actions taken through December 31, 2014, by 24 selected federal agencies, NARA, and OMB, and interviewed the agencies' records management officials.

section_title: What GAO Found
paragraphs: The 24 federal agencies took actions toward implementing each of the seven requirements set forth in the National Archives and Records Administration (NARA) and Office of Management and Budget (OMB) directive on managing government records (see table).

However, certain requirements were not fully met by 5 of the agencies because these agencies were either still working on addressing the requirement, or did not view the requirement as mandatory. For example, while all 24 agencies designated a senior official to oversee records management, 2 did not designate the official at the assistant secretary level, and 1 did not reaffirm the official by the specified deadline. Further, at 2 agencies, records management officers did not obtain the NARA training certificate or had not been granted an exemption. These agencies expect to complete their training by the end of fiscal year 2015.

The Office of Personnel Management (OPM), OMB, and NARA took steps to implement 11 required oversight actions, although not all actions had been completed. For example, OPM finalized an occupational series to elevate records management roles, responsibilities, and skill sets for agency records professionals. In addition, OMB was in the process of updating its Circular A-130 to include records management requirements for agencies when moving to cloud-based services or storage solutions. The agency expects to release the updated circular by December 2015. Lastly, NARA, in consultation with other stakeholders, produced a plan to move agencies toward greater automation of records management. However, it did not include metadata requirements in its guidance, as required. Until agencies, OMB, and NARA fully implement the directive's requirements, the federal government may be hindered in its efforts to improve performance and promote openness and accountability through the reform of records management.

section_title: What GAO Recommends
paragraphs: GAO is making 10 recommendations to 5 federal agencies and NARA to ensure records management directive requirements on designating senior officials and identifying, reporting, and managing records are met. In commenting on a draft of this report, the agencies and NARA generally agreed with the recommendations.

section_title: Letter
paragraphs: The federal government collects, generates, and uses large amounts of  information, increasingly in electronic form, to accomplish its missions.  Accordingly, greater reliance on electronic communication and  information technology systems has radically increased the volume and  diversity of information that agencies must manage. Recognizing this  challenge, on November 28, 2011, President Obama signed a  presidential memorandum that was to begin a government-wide effort to  reform federal records management policies.

To comply with the presidential memorandum, on August 24, 2012, the  Office of Management and Budget (OMB) and the National Archives and  Records Administration (NARA) jointly issued a memorandum to the  heads of federal departments and agencies: the Managing Government  Records Directive. OMB, NARA, and the Office of Personnel Management (OPM), to take  specific actions by established deadlines toward reforming records  management policies and practices and developing a framework for  managing electronic government records.

This directive required federal agencies, including  At your request, we conducted a study of the implementation of this  directive. Our specific objectives were to (1) assess the extent to which  federal agencies have taken the actions called for in the directive; and (2)

Executive Office of the President, Office of Management and Budget and National  Archives and Records Administration, Memorandum for the Heads of Executive  Departments and Agencies and Independent Agencies: Managing Government Records  Directive, M-12-18 (Washington, D.C.: Aug. 24, 2012). determine the extent to which OPM, NARA, and OMB have taken actions  called for in the directive, including overseeing agencies’ compliance.

In conducting this study, we focused on the records management  activities of the 24 major federal departments and agencies covered by  the Chief Financial Officers Act of 1990, along with OMB and NARA. We  limited our review to the actions that were to be implemented by these  agencies from November 2012 through December 2014. We also  examined one action required of OMB that did not have a specified  completion date.

To address the first objective, we obtained and reviewed the records  management policies, procedures, and guidance from these agencies.  We also collected and analyzed from the 24 selected agencies (1) annual  records management self assessments, (2) Senior Agency Official  reports, (3) listings of permanent records that have been in existence for  more than 30 years, (4) NARA certificates of Federal Records  Management Training, (5) records management training program  materials, and (6) listings of unscheduled records at NARA and agency  records storage facilities. We compared the agencies’ documentation to  the requirements specified in the directive that were required to be  completed by the December 31, 2014, deadline. In addition, we  conducted structured interviews with agency records management  officials and corroborated the information provided by these officials with  supporting agency documentation.

To accomplish the second objective, we obtained and reviewed NARA’s  records management policies, plans, and other documentation related to  electronic recordkeeping. Among other things, we reviewed the Senior  Agency Official reporting template, NARA guidance for transferring  permanent electronic records and for managing e-mail records, and  NARA’s plans for the automation of records management.

Further, we interviewed officials within OMB’s Offices of Information  Regulatory Affairs and E-Government & Information Technology to  discuss the agency’s efforts to update its Circular A-130. In addition, we  interviewed OPM’s Chief of Records Management and other agency  officials to discuss the development of the records management  occupational series. We corroborated the information provided by these  officials with supporting documentation to determine the actions taken by  the agencies to address the directive requirements. Appendix I describes  our objectives, scope, and methodology in greater detail.

We conducted this performance audit from March 2014 to May 2015 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: Records are the foundation of open government, supporting the principles  of transparency, participation, and collaboration. Well-managed records  can be used to assess the impact of programs, improve business  processes, and share knowledge across the government. Effective  records management is also an important tool for efficient government  operations. Without adequate and readily accessible documentation,  agencies may not have access to important operational information  needed to make decisions and carry out their missions.
subsections: section_title: Directive Established Federal Records Management Requirements
paragraphs: In response to the November 2011 presidential memorandum to begin an  executive branch-wide effort to reform records management policies and  develop a framework for the management of electronic government  records, the Director of OMB and the Archivist of the United States jointly  issued a directive to heads of federal departments and agencies. The  directive was aimed at creating a robust records management framework  for electronic records that complies with statutes and regulations to  achieve the benefits outlined in the presidential memorandum. It required  agencies, to the fullest extent possible, to eliminate paper and use  electronic recordkeeping.

In particular, the directive set forth two goals that federal agencies,  including OMB and NARA, are to work toward:  require electronic recordkeeping to ensure transparency, efficiency,  and accountability; and demonstrate compliance with federal records management statutes  and regulations.

To meet the two goals, the directive identified 10 requirements that  agencies had to address by established deadlines. As shown in table 1,  seven of the requirements had deadlines that ranged from November 15,  2012, to December 31, 2014.

The directive also required NARA, OMB, and OPM to take 13 actions to  assist agencies with meeting goal 2 of the directive. Table 2 describes the  required actions and their due dates.

section_title: Agencies Took Actions in Response to the Directive but Did Not Fully Meet All Requirements
paragraphs: The 24 federal agencies took actions toward implementing each of the  seven requirements due in November 2012, December 2013, and  December 2014. These actions included designating and reaffirming  senior agency officials at the appropriate level to oversee agencies’  records management programs, developing and implementing plans to  manage permanent electronic records, reporting progress in managing  permanent and temporary e-mail in an electronic format, identifying 30- year or older permanent records for transfer, identifying unscheduled  records, obtaining the NARA federal records management training  certificate, and developing records management training. However,  certain requirements were not fully met by 5 of the agencies because  these agencies were either still working on addressing the requirement, or  did not view the requirement as being mandatory. Until agencies fully  implement the directive’s requirements, the federal government may be  hindered in its efforts to improve performance and promote openness and  accountability through the reform of records management.
subsections: section_title: All Agencies Designated a Senior Agency Official to Oversee Records Management Activities, but Not All Designated the Official at the Appropriate Level
paragraphs: According to the directive, by November 15, 2012, and every year  thereafter, each agency is required to name or reaffirm the Senior Agency  Official who is responsible for coordinating with the agency records officer  and other appropriate officials to ensure the agency’s compliance with  records management statutes and regulations. The Senior Agency  Official should hold a position at the assistant secretary level or its  equivalent. Further, according to the directive, this official should be  empowered to make adjustments to agency practices, personnel, and  funding, as may be necessary, to ensure compliance and support the  business needs of the department or agency.

All 24 agencies had designated a Senior Agency Official to oversee  records management and had subsequently reaffirmed or named a new  official. Among these agencies, 22 had designated a Senior Agency  Official at the assistant secretary level or its equivalent and had given the  official responsibilities for overseeing records management, including  being empowered to make adjustments to agency practices, personnel,  and funding, as required.

Two agencies, OPM and the Department of Veterans Affairs, had not  designated their officials at the appropriate level. Further, at the  Department of Veterans Affairs, the official was not always reaffirmed in  accordance with the directive. Additionally, the department had not  assigned its Senior Agency Official the responsibilities for ensuring  records management compliance in the manner called for in the directive.  Specifically:

Within OPM, the Senior Agency Official was not at the assistant  secretary level or its equivalent. Rather, the position was delegated by  the Chief Information Officer to the Chief of Records Management and  Data Policy, within the Office of the Chief Information Officer. The  Chief Information Officer did not view the Senior Agency Official  designation at the assistant secretary level or its equivalent to be  mandatory, and thus, did not assign the official at that level. Further,  the Senior Agency Official said the position had the full responsibility,  as stated in the directive, for ensuring that the agency’s records  program complies with all records management statues and  regulations. Nevertheless, while OPM’s Chief Information Officer did  not consider the designation at the assistant secretary level or its  equivalent to be mandatory, NARA records management officials  stated that doing so is mandatory.

At the Department of Veterans Affairs, the Senior Agency Official was  named in 2012, and reaffirmed in 2013. However, the official was not  reaffirmed in 2014, thus not adhering to the directive requirement to  reaffirm the Senior Agency Official annually. According to records  management officials, the department regarded the requirement as  not applicable when the Senior Agency Official did not change, but  subsequently reaffirmed the official in February 2015. These officials  added that the current Senior Agency Official position is held by an  Associate Deputy Assistant Secretary who is instrumental in making  recommendations and follow-up justifications to ensure compliance  with the directive. However, the officials acknowledged that the Senior  Agency Official does not have the authority to make decisions about  agency practices, personnel, and funding to ensure compliance.

By not designating the Senior Agency Official at the level stated in the  directive, OPM has not demonstrated its commitment to ensuring that the  official it assigns to oversee compliance with records management  statutes and regulations is consistent with the directive requirement.  Further, by not designating a Senior Agency Official with the authority to  make necessary decisions about agency practices, personnel, and  funding critical to its electronic records management, the Department of  Veterans Affairs has not demonstrated its priority to ensuring compliance  with the directive in support of the department’s business needs.

section_title: Agencies Have Taken Actions to Manage and Transfer Temporary and Permanent Electronic Records, but More Action Is Needed
paragraphs: The managing government records directive established four  requirements that agencies were to complete by December 31, 2013.  Specifically, agencies were to develop and begin to implement plans to manage all permanent  records in an electronic format;  report to NARA annually the status of the agency’s progress in  managing both permanent and temporary e-mail records in an  electronic format; ensure that permanent records that have been in existence for more  than 30 years are identified for transfer and reported to NARA; and  coordinate with NARA to identify all unscheduled records, including  records stored at NARA’s and the agencies’ records storage facilities  that have not yet been properly scheduled.

As shown in table 3, the majority of the 24 agencies took actions to  implement the directive requirements.

The directive required each agency to develop and begin to implement  plans to manage all permanent records in an electronic format. To assist  agencies in meeting this requirement, NARA developed a Senior Agency  Official report template.agencies report on a number of specific areas, to include   In using the template, NARA requested that details on how permanent electronic records are currently captured,  retained, searched, and retrieved; plans to digitize permanent records currently in hard-copy format or plans to manage all permanent electronic records in electronic format,  including how the plans will be implemented; and  challenges the agency faced in achieving the requirement of  managing all permanent electronic records in an electronic format.

All but 1 of the 24 agencies described their efforts to address these areas  in the Senior Agency Official reports that they submitted to NARA. For  example, 1 agency stated that its permanent records were being captured  in both electronic and paper format and that permanent records were  retained in agency shared drives. Another agency stated that electronic  records capabilities were rolled out to its components to capture, retain,  search, and retrieve the agency’s permanent electronic records; while  another stated that its components capture, retain, search, and retrieve  permanent electronic records in a variety of ways depending on their  unique missions, business processes, and available technologies.

The National Science Foundation did not submit a Senior Agency Official  report and did not provide information to NARA on how it intends to  manage permanent records electronically. According to National Science  Foundation records management officials, the agency is in the process of  formalizing plans to manage permanent electronic records in an  electronic format and intends to complete the plan in fiscal year 2015.  However, the officials did not provide a date as to when the agency  intends to report its plans to NARA, as required. Until the National  Science Foundation completes and reports on its plans, it will not be  positioned to provide NARA with required information on how it intends to  manage permanent electronic records, or to receive feedback from NARA  that could help ensure the effectiveness of its approach.
subsections: section_title: Most Agencies Reported Progress in Managing Permanent and Temporary E- mail Records
paragraphs: The directive required that each agency report to NARA, on an annual  basis, regarding the status of its progress to manage both permanent and  temporary e-mail records in an electronic format. Toward this end, 23  agencies met this reporting requirement. The agencies reported their  progress through written responses in their Senior Agency Official  reports. (Within the report template, a section was designated for the  agency to describe its progress in managing both permanent and  temporary e-mail records in an electronic format.) The 23 agencies’  written responses described how their e-mail records were currently  captured, retained, searched, and retrieved, and how they identified  temporary and permanent e-mail records.

As previously discussed, the National Science Foundation did not submit  a Senior Agency Official report to NARA. In this regard, the agency’s  records management officials stated that the management of permanent  and temporary e-mail records was reviewed internally in May 2014 and  that they were looking into whether a current agency system could be  used to convert records into useable record types. However, no date was  given by the officials as to when the required review for permanent and  temporary e-mail records would be completed; nor did the agency provide  a date as to when it will report to NARA, as required.

By not reporting on its progress toward managing permanent and  temporary e-mail records in an electronic format, the National Science  Foundation has not taken an important step toward ensuring that NARA is  aware of the agency’s ability to retain e-mail records in an electronic  system that supports records management and litigation requirements,  including the capability to identify, retrieve, and retain the records for as  long as they are needed. Further, the agency risks not receiving feedback  from NARA that could help ensure it is prepared to retain e-mail records  in an electronic system, as envisioned.

section_title: Most Agencies Identified and Reported on the Transfer of Permanent Records to NARA
paragraphs: The directive required agencies to ensure that permanent records that  have been in existence for more than 30 years are identified for transfer  and reported to NARA. In accordance with that requirement, the majority  of the agencies identified for transfer and reported on their permanent  records that were in existence for 30 years or more. Specifically, 21 of 24  agencies submitted to NARA, as part of their annual records  management self-assessment reports, their lists of permanent records, or  reported that there were no permanent 30-year-old records in their  possession.

One agency, the National Science Foundation, did not report to NARA on  its possession of permanent 30-year-old records. Records management  officials at the National Science Foundation stated that the agency did not  meet the reporting requirement because it did not complete its process of  validating the accuracy of records that it had identified as potentially being  30 years old or older until the reporting deadline had passed. According  to these officials, the agency completed this process in December 2014  and determined that there were no 30-year-old or older records in  existence within the agency. The officials stated that, because the agency  had no such records in its possession, the agency did not view reporting  to NARA as a requirement. However, reporting that it had no permanent  records in existence for 30 years or more would be a practice that is  consistent with the majority of the agencies’ efforts to inform NARA  regarding the state of these records and would demonstrate the National  Science Foundation’s adherence with the directive.

Two other agencies—the General Services Administration and the  Department of Transportation—had not fully addressed this requirement  because they had not identified and reported on permanent 30-year-old  records stored at either NARA’s federal records centers or the agency’s  records storage facilities.

According to General Services Administration records management  officials, permanent records stored at NARA’s federal records centers  were identified, but permanent records stored at agency records  storage facilities had not been identified. The officials stated that the  agency plans to finalize, and report to NARA on, the identification of  these records as part of its next agency-wide records inventory, which  is supposed to occur in the summer and fall of 2017.

According to Department of Transportation records management  officials, the department had met the requirement for all but 3 of its 10  components. In particular, the officials stated that 1 component had  identified 30-year-old permanent records during its 2012 records  inventory and, as of March 2015, was working with NARA to transfer  these records by May 2015. The officials also stated that another  component reported to NARA in January 2014 that it did not have  permanent records that were in existence for more than 30 years.  However, this component subsequently identified one 30-year-old  permanent record in June 2014, and the department plans to report  and transfer this record to NARA by the end of fiscal year 2015. The  officials stated that the third remaining component had not completed  its records inventory, but as of March 2015, had not identified any  permanent 30-year-old records in its possession. Department of  Transportation officials stated that they plan to report this information  to NARA once their inventory is completed.

By not finalizing its identification of records stored at the agency’s records  storage facility until approximately 4 years beyond the date specified in  the directive, the General Services Administration delays its ability to  report the status of, and transfer to NARA, its records that have been in  existence for 30 years or more. Similarly, until the Department of  Transportation ensures that its component completes the identification of  permanent 30-year old records in its possession, it also limits its ability to  report this information to NARA, as required.

section_title: Most Agencies Identified Unscheduled Records
paragraphs: The directive required each agency to coordinate with NARA to identify all  unscheduled records, including all records stored at NARA and at  agencies’ records storage facilities that have not yet been properly  scheduled. We previously found that this is an essential step since  NARA considers unscheduled records an important indicator of the risk of  unauthorized destruction of records.

Among the 24 agencies, 20 had either identified unscheduled records and  reported their progress in identifying these records to NARA, or had  reported that they did not have any known unscheduled records by the  reporting deadline. In particular, Senior Agency Officials and records  officers for these agencies had either (1) worked in conjunction with  NARA staff and identified their unscheduled records, (2) independently  identified the unscheduled records, or (3) reported that there were no  unscheduled records in their possession.

Three agencies—the Departments of Commerce and Transportation and  the General Services Administration—did not complete the identification  of their unscheduled records by the reporting deadline, although they  subsequently did so for all or most of their components.

The Department of Commerce reported that it did not fully meet the  requirement for identifying unscheduled records until the reporting  deadline had passed. In particular, Commerce records management  officials reported that the department completed the process of  identifying the unscheduled records in September 2014.

Department of Transportation records management officials stated  that the department identified unscheduled records for 1 remaining  component (out of 10) in December 2013 and reported to NARA on  those unscheduled records in January 2014.

According to General Services Administration records management  officials, the agency did not identify unscheduled records stored at  agency records storage facilities until November 2014, following an  agency-wide records inventory in that same month.

Lastly, the National Science Foundation had not completed its  identification of, or reported on, any portion of its unscheduled records. In  July 2014, agency records management officials noted that they had  identified the unscheduled records, but a preliminary internal inspection of  the records had revealed administrative errors. Subsequently, the officials  stated that a review of the unscheduled records list was under way in  September 2014. However, as of March 2015, the officials stated that the  review was still ongoing and they could not provide a date for when it  would be completed. By not completing the identification of unscheduled  records, the National Science Foundation increases the risk that its  records could be destroyed without NARA’s awareness and approval.

section_title: Most Agencies Obtained Certifications and Established Records Management Training Programs
paragraphs: The records management directive established two requirements that  were to be completed by December 31, 2014. The first was that each  agency’s designated agency records officer must hold the NARA  certificate of Federal Records Management Training and that new records  officers must acquire the certification within 1 year of assuming the  position of agency records officer. The second requirement was that each  agency was to establish its own method to inform all employees of the  agency’s records management responsibilities and develop suitable  records management training for appropriate staff.

On December 4, 2013, NARA issued a bulletinagencies providing further guidance on agency records officer training  requirements as stated in the directive. The requirement applied to all   to the heads of federal  formally appointed federal agency records officers. In the bulletin, NARA  stated that it recognized that some designated agency records officers  had years of experience and accreditation in the records management  profession. In those cases, it agreed to grant the officer an exemption  from obtaining the certificate of Federal Records Management Training. If  an exemption was approved, no further action would be required to meet  the directive training requirement. To receive an exemption from NARA,  designated agency records officers must meet one of three criteria: (1)  have 3 years of experience as a designated agency records officer and  an Institute of Certified Records Managers certification, (2) have 3 years  of experience as a designated agency records officer and an Academy of  Certified Archivistsdesignated agency records officer at one or more federal agencies.   certification, or (3) have 7 years of experience as a  The majority of the federal agencies (22 of 24) either fully met the first  requirement that each designated agency records officer hold the NARA  certificate for Federal Records Management Training, were granted an  exemption from obtaining the certificate, or were appointed in 2014 and  have until a date in 2015 to complete the certification. Specifically, 17  agencies’ designated agency records officers had obtained the NARA  certificate for federal records management; 4 agencies had received  NARA exemptions for some or all of their designated agency records  officers; and 1 agency had recently appointed its designated agency  records officer, who has until September 2015 to complete the Federal  Records Management Training.

Among the remaining two agencies—the Departments of Commerce and  Defense—at least 1 designated agency records officer had not obtained  the NARA training certificate or been granted a NARA exemption by the  required deadline. Each of the agencies’ officials stated that their records  officers were in the process of completing classes or obtaining the  exemption. Specifically, at the Department of Commerce, 12 of 17  designated agency records officers had obtained the required NARA  training certificate or received an exemption. According to the  department’s records management officials, the remaining 5 designated  agency records officers plan to complete their training by the end of fiscal  year 2015.

For the Department of Defense, 23 of 24 designated agency records  officers had obtained the required NARA training certificate or received an  exemption. The department’s records management officials stated that  the remaining designated agency records officer expects to complete  training by August 2015.

With regard to the second requirement, all 24 agencies had established a  method to inform employees of their records management  responsibilities, as outlined in federal laws and policies. Specifically,  these agencies had established a method to inform employees of their  records management responsibilities either through agency-wide policy,  departmental regulation, or through an agency-wide e-mail.

However, two agencies had not yet completed the development of their  agency records management training. Specifically, the Departments of  Commerce and Energy were in the process of developing training for their  staff, and officials from these agencies said they plan to complete the  training by June 2015.

section_title: OPM, OMB, and NARA Took Actions to Oversee Agencies’ Implementation of the Directive, but Not All Specified Actions Were Completed
paragraphs: OPM, OMB, and NARA had taken steps toward implementing the 11 of  13 actions specified in the directive as their responsibility, but selected  requirements had not been fully addressed by the specified deadlines.  For example, OPM had finalized an occupational series to elevate  records management roles, responsibilities, and skill sets for agency  records professionals. In addition, according to an official in OMB’s Office  of Information and Regulatory Affairs, that agency was still in the process  of updating its Circular A-130 to include records management  requirements for agencies that are moving to cloud-based services or  storage solutions, with the updated circular expected to be released by  the end of calendar year 2015. Further, NARA had met with Senior  Agency Officials and produced a plan to move agencies toward greater  automation of records management. Moreover, NARA, in cooperation  with the Federal Records Council, had worked with community of interest  groups to identify tools that support electronic records management.  However, it had not included metadata requirements in its guidance, as  required. Until NARA completes the actions specified in the directive,  agencies may not have the guidance needed to help improve the  efficiency and effectiveness of records management across the federal  government, as envisioned by the directive.
subsections: section_title: OPM Established the Records and Information Management Occupational Series
paragraphs: The managing government records directive required OPM to establish,  by December 31, 2013, a formal records management occupational  series. In doing so, OPM was to elevate records management roles,  responsibilities, and skill sets for agency records officers and other  records professionals.

In response to the directive, OPM created a draft position classification  document for the Records and Information Management Series, 0308, by  the December 2013 deadline, but did not finalize it until March 2015. The  document was created to establish the records management series and  classify positions within this series.

OPM disseminated the document to all federal agencies and obtained  comments. Specifically, it issued a memorandum on December 27, 2013,  to announce the release of the draft position classification document for  the records management work. Federal agencies were asked to provide  their comments by February 7, 2014.

All 24 agencies, including NARA, provided comments to OPM regarding  the records management occupational series. Among the comments,  agencies suggested that OPM incorporate changes to the position series  and title, update the series to include the duties of federal records  managers at senior levels and the working relationship between records  management staff and senior officials, such as the Senior Agency Official,  to ensure that agencies have efficient and effective records management  programs.

Other comments suggested that personnel in this series should be  considered as subject matter experts, and indicated that the draft series  did not acknowledge the records management position as a full-time  position with full-time responsibilities. The comments also stated that  OPM should revise the series and consider that some positions would be  a combination of records management, knowledge and information  management, and information compliance roles, including data protection  and freedom of information.

According to the Records and Information Management Occupational  Series document, OPM summarized what it described as “major” agency  comments on the occupational information, occupational title, and grading  criteria, along with OPM’s response to these comments, in an appendix of  the final series document. According to the document, OPM revised the  occupational information to include language that addressed the  modernization of records management, electronic records, and training,  among other things. OPM also changed the occupational title to “Records  and Information Management Specialist,” based on agency comments  that it received on the title. Additionally, OPM revised the grading criteria  language to align with the language of other recently issued series. By  establishing a formal records management occupational series in March  2015, OPM took steps to elevate the roles, responsibilities, and skill sets  for agency records officers and other records professionals.

section_title: OMB Has Not Yet Updated Its Policy for the Management of Federal Information Resources
paragraphs: According to the directive, OMB is to include in its next revision of Circular  A-130 provisions for federal agencies to incorporate records  management requirements when moving to cloud-based services or  storage solutions. The directive did not establish a date by which this was  to be accomplished.

As of March 2015, OMB had not finalized its revisions to Circular A-130 to  require agencies to incorporate records management requirements when  moving to cloud-based services or storage solutions, as specified in the  directive. Officials in OMB’s Office of Information and Regulatory Affairs  stated, however, that the requirement is expected to be included in the  circular when it is finalized.

In explaining the status of this initiative, an official stated that revisions to  the circular began in 2012 and were distributed for interagency  comments. Additional revisions to the circular continued in 2013 and, in  2014 the agency waited for the approval of legislation, such as the  Federal Information Security Modernization Act of 2014, which requires  OMB to amend or revise Circular A-130 to eliminate inefficient or wasteful   According to OMB officials, the agency expects  reporting within 1 year.to finalize and issue the revised OMB Circular A-130 in December 2015.  If consistent with the directive, this planned action of revising Circular A- 130 by OMB should help agencies incorporate records management  requirements when moving to cloud-based services or storage solutions.

section_title: NARA Acted on Nine Specific Requirements, but Work Remains
paragraphs: The directive included nine specific actions that NARA was to implement  by the end of December 2012, December 2013, and December 2014.  Many, but not all of NARA’s actions met the requirements of the directive.

By December 31, 2012, the Archivist of the United States was required to  convene the first of periodic meetings of all Senior Agency Officials to  discuss progress on (1) implementation of the directive, (2) agency  federal records management responsibilities, and (3) partnerships for  improving records management in the federal government. Additionally,  by this date, NARA was to complete a review of its records management  reporting requirements and produce a template for a single annual report  that each Senior Agency Official was to send to the Chief Records Officer  for the U.S. Government beginning on October 1, 2013.

Toward this end, in November 2012, the Archivist held the first meeting  with Senior Agency Officials, agency records officers, and NARA staff.

According to documentation we reviewed, meeting topics addressed two  of the required areas: (1) an overview of the implementation of the  directive and (2) Senior Agency Officials’ responsibilities and duties.  Subsequent meetings were also held with the Senior Agency Officials of  various agencies from August 2013 to August 2014 that addressed the  implementation of an e-mail management approach and strategies for  meeting the goals of the directive, among other topics.

Nevertheless, NARA records management officials acknowledged that  the Senior Agency Official meetings did not include a discussion of  partnerships for improving records management in the federal  government, as required by the directive. According to the officials, the  agency considered these meetings to be information-sharing discussions  that would facilitate the exploration for future partnerships. The officials  added that NARA planned to contact Senior Agency Officials and  agencies when it dedicates more resources to address these  partnerships.

Also in December 2012, NARA completed a review of its records  management reporting requirements. Among other things, this review  examined instances in which agencies were required to report on their  progress through the managing government records directive, agencies’  records management self assessments, and inventories that the agencies  were to conduct of electronic recordkeeping systems.

The review concluded that federal agencies were required to submit  information to NARA for its use in measuring the state of federal records  management in 11 different instances. These submissions were in  addition to other information, such as plans and improvements that the  agencies were making in response to the managing government records  directive. NARA officials stated that, as a result of the review, it took steps  to streamline agencies’ reporting requirements and reduce the number of  times that agencies submit information. For example, in 2013, it  eliminated the requirement for federal agencies to report semi-annually  on their electronic records inventories. Instead, in 2014, NARA began  requiring agencies to report annually on their electronic records as part of  their records management self-assessment submissions.

Further, the officials stated that NARA had used the results of the review  to create the required template that was to guide Senior Agency Officials  in the development of their annual reports on the management of  government records. NARA disseminated the template to federal  agencies via an August 2013 memorandum. Subsequently, the agencies  were to use the template to guide their descriptions of current and future  plans to manage permanent electronic records, temporary and permanent  e-mail records, and the use of cloud computing services. As discussed  earlier, specific details of the template included questions about how  agencies capture, retain, search, and digitize records. Also required were  details on how the agencies intend to implement plans, as well as  anticipated challenges to their management of permanent records  electronically. According to the directive, agencies were to submit their  reports based on the template by December 31, 2013.

NARA officials stated that their assessment of information provided by  agencies in the Senior Agency Official report template had disclosed that  responses varied in length and detail. Specifically, some agencies  provided brief generalizations while others provided an abundance of  information. We also found variations in the extent of Senior Agency  Official template responses and supporting information. For example, in  addition to providing descriptions of its progress being made toward  specific directive goals and requirements in the Senior Agency Official  template, the Nuclear Regulatory Commission submitted a preliminary  plan that contained, among other things, the objective, scope of work,  schedule, project team members, and project costs needed to modernize  its information and records management program. This degree of  specificity was not common in other agency submissions.

NARA records management officials acknowledged that the original  reporting template had lacked specificity regarding the level of detail that  it required agencies to provide. The officials stated that they did not  require agencies to provide items, such as project plans, and did not  intend to evaluate the report submissions for the sufficiency of agency  plans. Rather, the officials indicated that NARA had wanted to identify  what agencies were doing well, so those methods could be shared with  other agencies that were in the initial stages of planning. Further,  according to the officials, NARA wanted to encourage agencies to begin  planning how they would meet the final December 2019 requirement to  manage all permanent electronic records in an electronic format in  advance of the deadline. Moreover, it wanted agencies to consider the  sequential steps as well as timing and resources needed to move toward  electronic recordkeeping.

NARA records management officials recognized the need for more  information and stated that the next version of the Senior Agency Official  reporting template, based on the data collected in 2013, is expected to  seek information to be used as metrics to show what progress is being  made across the government toward meeting the directive’s goals. In  particular, in September 2014 NARA revised the reporting template to  collect information on, among other things, agency records officers’  efforts in obtaining the federal records management certificate, and best  practices applied and lessons learned on each agency’s transition to  electronic recordkeeping.

According to the officials, NARA is committed to making the template  instrumental to agencies, providing support to records management  programs, and achieving the goals of the directive. By taking steps to  ensure that agencies provide consistent and complete information  regarding their efforts to manage permanent electronic records, NARA  stands to have better awareness of agencies’ readiness to meet the  established deadline.
subsections: section_title: NARA Revised Transfer Guidance for Permanent Electronic Records, but Metadata Requirements Were Not Included
paragraphs: According to the records management directive, NARA was to complete  and make available by December 31, 2013, revised guidance, including  metadata requirements for agency transfer of permanent electronic  records to NARA. The revised guidance was to include additional  sustainable formats commonly used to meet agency business needs.  Also, NARA was to update the guidance regularly, as required, to stay  current with technology changes.

In January 2014, NARA revised its transfer guidance for permanent  electronic records and made the document available to the public on its  website in the form of NARA Bulletin 2014-04, Revised Format Guidance  for the Transfer of Permanent Electronic Records.covered categories not addressed in the previous guidance, such as  digital audio and moving images. Among its revisions, the bulletin applies to all electronic records that have been appraised and  scheduled for permanent retention,  specifies which file formats are acceptable when transferring  permanent electronic records to NARA,  identifies preferred and acceptable formats for each category of  electronic file, and expands the number of suitable formats that NARA will accept for  transfer, based on their sustainability.

However, NARA’s revised guidance did not include metadata  requirements, as called for in the directive. The bulletin stated that NARA  would develop metadata requirements for electronic records separately,  although no date was given for when it intends to do so. Further, as an  alternative, NARA included in the bulletin a list of other currently available  guidance for electronic records that address metadata. For example, the  bulletin refers to guidance for electronic pointers (such as metadata tags)  to establish linkages and the capture and maintenance of required  metadata. The bulletin also specifies that agencies must comply with  existing requirements for documentation and metadata as described in  existing federal regulations until new requirements for metadata for  electronic records are published.

NARA records management officials stated that the previous guidance for  transferring permanent electronic records had identified metadata for a  few record types, including digital photographs, geospatial records, and e- mail records. However, the development of new guidance on metadata  requirements will be the first time that NARA has specified individual  elements of metadata for all permanent electronic records. According to  the officials, NARA anticipates that agencies will use the revised  metadata guidance when implementing automated technologies for  records management, and to address the creation, management, and  eventual transfer of permanent electronic records to NARA. Nevertheless,  the officials acknowledge that NARA had not set a time frame for making  the revised metadata guidance available to agencies. Until NARA  establishes a time frame for and, accordingly, takes steps to include  metadata requirements in its revised guidance, agencies will remain  unaware of all of the information they need to provide when transferring  electronic records to NARA.

section_title: NARA Created New E-mail Guidance
paragraphs: The directive required NARA to issue new e-mail guidance by December  31, 2013. The guidance was to describe methods for managing,  disposing of, and transferring e-mail.

Accordingly, in August 2013, the agency released NARA Bulletin 2013- 02, Guidance on a New Approach to Managing Email Records. The  bulletin presented an e-mail management approach called Capstone.  NARA records management officials described Capstone as an  automated or manual method of categorizing and scheduling e-mail  based on the work or positions of e-mail account owners. It is to be  employed using various tools or systems and offers agencies a more  simplified way to manage e-mail when compared to print and file systems  or records management applications that require staff to file e-mail  records individually.

NARA records management officials anticipate that the Capstone  approach will provide agencies with a feasible solution to e-mail records  management challenges, especially as agencies consider cloud-based  solutions. Further, according to these officials, the Capstone approach is  expected to allow agencies to consider whether e-mails contain the  required metadata elements at the time of transfer to NARA. For its part,  NARA has supplemented Capstone with training materials and other  related guidance and resources, and has made this information available  to agencies on its website to assist them in evaluating or adapting  Capstone features.

By providing agencies the Capstone bulletin and related information  representing a simplified automated e-mail management methodology,  NARA has taken steps to assist agencies in incorporating recordkeeping  requirements into their business processes and, in identifying the specific  means by which they can fulfill their responsibilities under the Federal  Records Act.

section_title: NARA Developed a Plan to Move Agencies toward the Increased Automation of Records Management
paragraphs: NARA was required to produce a comprehensive plan, in collaboration  with the Federal Chief Information Officers Council, the Federal Records  Council, private industry, and other stakeholders that describes suitable  approaches for the automated management of e-mail, social media, and  other types of digital record content, including advanced search  techniques. The plan was to detail expected outcomes and potential  associated risks and be completed by December 31, 2013.

Although not completed by the required deadline, NARA finalized and  released a plan in September 2014 that was developed in consultation  with the Federal Chief Information Officers Council, the Federal Records  Council, private industry, and other stakeholders. The plan identified  approaches for federal agencies to pursue when automating electronic  records management, to include automated management of e-mail, social  media, and other types of digital record content, as well as advanced  search techniques. The plan discussed the outcomes, benefits, and risks  of these approaches and described a framework that agencies may use  to help meet the goals of the directive. It also listed ideas or activities  intended to help NARA, agencies, and stakeholders achieve effective  federal electronic records management.

NARA records management officials described the plan as being a living  document and stated that the community of private industry and federal  councils intends to continue to revise it as more is learned about  automation technologies and additional efforts are made to work toward  easier and consistent electronic information management. Moreover, the  officials stated that NARA anticipates continuing to work with its  stakeholders to identify milestones and tasks intended to, among other  things, increase automation, reduce burden on end users, and achieve  more consistent and affordable compliance with recordkeeping  requirements. If effectively implemented, NARA’s plan could serve as an  important tool to aid records management stakeholders’ awareness of  recommended approaches for improving automated management of e- mail, social media, and other types of digital record content.

section_title: NARA Created a Template for Reporting Cloud Initiatives
paragraphs: The directive required NARA, by December 31, 2013, to incorporate into  existing reporting requirements an annual agency update on new  “cloud” initiatives, including a description of how each initiative meets  Federal Records Act obligations and the goals outlined in the directive.  For the initial report, agencies were to identify any existing uses of cloud  services or storage, and the dates of implementation.

The Senior Agency Official annual reporting template created by NARA  for 2013 included reporting requirements for cloud initiatives. As  discussed earlier, NARA disseminated the template to federal agencies  via an August 2013 memorandum.

section_title: NARA’s Feasibility Study Concluded That It Should Not Provide Government-Wide Storage and Management Services for Electronic Records
paragraphs: The directive required NARA, by December 31, 2013, to evaluate its  feasibility of establishing a secure cloud-based service to store and  manage unclassified electronic records on behalf of agencies. Further,  the directive stated that this basic, shared service should adhere to  NARA’s records management regulations and provide standards and  tools to preserve records and make them accessible within their  originating agency until NARA performs disposition.

In response to this requirement, NARA conducted a study examining the  technical feasibility and cost for it to establish a repository and system to  store, manage, and dispose of electronic records on behalf of federal  agencies. The study included an assessment of secure cloud-based  services and the cloud-based data-at-rest model. For the data-at-rest  model, the study presupposed an environment where records are  managed within the same clouds as agencies’ active business and  administrative records. Also, these same clouds would be used for  access and preservation of records. According to the study, disposition  rules would then be applied where the records are stored because the  data sets would be expected to continue to grow in size, thus becoming  impractical to physically move them from repository to repository.

Additionally, the feasibility study determined that “data at rest” would  require procedures, tools, and a processing environment that allows for  archival records to be accessioned, preserved, and made publicly  available without being physically transferred from their initial host  environments. The report anticipated that these types of issues could be  effectively managed with the assistance of external service providers.

NARA also considered cost factors in conducting the feasibility study and  concluded that it should not serve as a direct service provider in assisting  agencies with the storage and management of electronic records.  Specifically, the study determined that costs were not practical for a secure cloud-based service needed to meet the requirements of a an infrastructure capable of managing large volumes of agency- large user base,  the investment required to establish a cloud-based repository, and  owned records.

Consequently, the study concluded that a more sustainable approach to  improving electronic recordkeeping may be to pursue alternative service  models where NARA does not store and manage electronic records on  behalf of agencies. According to NARA, these services and the agency’s  role in providing them could be developed and tested as part of the  managing government records directive’s work with automation, open  source technology development, and cloud computing.

section_title: NARA Created Community of Interest Groups to Help Support Electronic Records Management Initiatives
paragraphs: By December 31, 2013, NARA, in cooperation with the Federal Chief  Information Officers Council, the Federal Records Council, and other  government-wide councils that expressed interest, was to establish a  community of interest to bring together leaders from the information  technology, legal counsel, and records management communities to  solve specific records management challenges. In particular, the  community of interest group was to develop and propose guidance, share  information, create training, and identify tools that support electronic  records management.

Toward this end, NARA reported that two communities of interest were  established: (1) the Electronic Records Management Automation Working  Group, established in March 2013; and (2) the Federal Records Officer  Network, established in May 2013.

According to NARA records management officials, the Electronic Records  Management Automation Working Group is made up of 133 members  from the information technology, legal counsel, and records management  communities in the federal government. The officials stated that, through  this working group, records managers, information managers, and IT staff  share information with other group members on increasing the  automation of electronic records management tasks. Further, the officials  stated that the Electronic Records Management Automation Working  Group has suggested topics for guidance that NARA could produce,  including the disposal of paper records after digitization, required  metadata, and auto-categorization.

The Federal Records Officer Network has 172 members from various  federal agencies and collaborates on projects, shares information, and  develops training on records management. According to NARA’s records  management officials, the Network, in consultation with NARA, has  consolidated records management training materials from multiple  agencies into a single e-learning product that agencies can download and  use to meet training requirements. NARA records management officials  also stated that the Federal Records Officer Network has made  suggestions on records management best practices and training projects.

Additionally, NARA records management officials stated that the agency  has, in cooperation with the Federal Records Council, worked with  community of interest groups, including the Electronic Records  Management Automation Working Group and the Federal Records Officer  Network, to identify tools for records management. By creating  communities of interest that proposed guidance, shared information,  developed training, and helped to identify tools to support electronic  records management, NARA has taken steps toward assisting agencies  with records management challenges.

section_title: NARA Identified and Enhanced an Analytical Tool to Evaluate the Effectiveness of Federal Records Management Programs
paragraphs: By December 31, 2013, NARA was required to identify a government- wide analytical tool to evaluate the effectiveness of records management  programs. The tool was intended to supplement NARA’s assessments,  inspections, and studies of agencies’ records management programs.  The tool was also to help NARA and agencies measure program  compliance more effectively, assess risks, and aid in agency decision  making.

In accordance with the directive, by the second quarter of fiscal year  2013, NARA had identified the Records Management Maturity Model  Integrated tool developed by the Department of Homeland Security, as  the most feasible foundation for a records management solution to  evaluate agency records management programs. NARA then created a  working group of agency officials from the Federal Records Council to  modify the Records Management Maturity Model Integrated tool. The  working group members represented six federal agencies: NARA; the  Securities and Exchange Commission; and the Departments of Homeland  Security, the Interior, Justice, and Transportation.

The working group’s efforts resulted in the development of the Federal  Records and Information Management Program Maturity Model, a  government-wide analytical tool. According to the Federal Records and  Information Management Program Maturity Model’s user guide, the  purpose of the tool is to help agencies or components assess areas of  their records management programs to determine where improvements  are most needed. The tool is also intended to measure the maturity of an  agency records management program, regardless of the program’s size  and records management maturity level. The working group developed  organizing principles, assessment criteria, and performance measures for  the tool and, as of January 2015, had completed the tool and finalized a  guide for its intended users.

NARA records management officials stated that the agency presented the  Federal Records and Information Management Program Maturity Model  tool at its bi-monthly records management meeting in March 2015 and  posted the final product on its records management website in April 2015.  If the tool and the actions planned by NARA work as intended, they could  assist NARA and the agencies in evaluating the effectiveness of  agencies’ records management programs and measuring agency  compliance.

section_title: NARA Obtained External Involvement for Development of Open Source Records Management Solutions
paragraphs: The directive required NARA to collaborate with the Federal Chief  Information Officers Council and the Federal Records Council, and obtain  external involvement to develop open source records management  solutions by December 31, 2014.

To address this requirement, in 2013 and 2014, NARA engaged the  Federal Chief Information Officers Council, the Federal Records Council,  and the private sector to develop open source records management  solutions. For example, as discussed earlier, NARA generated a plan with  stakeholder participation that included activities that pertained to the  development of open source opportunities. Specifically, the plan, among  other things, (1) identified activities that will aid in developing open source  records management tools and (2) encourages external involvement to  develop open source records management tools.

The plan described a NARA activity to identify open source records  management tools by compiling a list of available open source tools that  could be used for various records management functions. This list and  related information would be maintained online as a resource for the  federal records management community. In addition, the plan specified  that NARA intends to identify gaps in open source records management  tools and identify opportunities for external involvement in the  development of new records management solutions. Further, to  encourage external involvement in the development of open source  records management tools, NARA requested information from selected  private sector vendors pertaining to cloud-based and open source records  management solutions for the federal government. According to NARA  officials, their outreach to vendors discovered that many viable automated  records management solutions are already on the market, including some  open source solutions. Consequently, in collaboration with the Federal  Chief Information Officers Council and the Federal Records Council,  NARA worked with private industry to help familiarize agencies with  existing solutions with the goal of identifying any remaining unmet  requirements. For example, NARA  Invited presentations to the federal records management community  on particular automated solutions and provided a list of questions for  vendors to answer about their products during those presentations.

Hosted an industry day event on September 10, 2013. At this event,  records officers, IT staff, and chief information officers from several  agencies, including NARA, discussed with vendors automated  electronic records management and the kinds of solutions the  agencies were seeking.

Published a request for information in FedBizOpps13, 2013, requesting vendor capability statements describing their  solutions and services to support automated electronic records  management. By April 15, 2014, NARA had received 52 capability  statements in response, all of which were shared with the federal  records management community through the Electronic Records  Management Automation Working Group.

Additionally, NARA provided evidence that it worked with other  stakeholders, such as in 2013, when it invited volunteers from other  federal agencies to share ideas and good practices and lessons learned  with each other in the Electronic Records Management Automation  Working Group. Further, according to its records management officials,  NARA issued the open source records management tools report in March  2015. According to NARA records management officials, the report  compiled a list of available open source tools that could be used for  various records management functions and maintain the information  online as a resource for the federal records management community.  This action, coupled with the work involving the private sector and other  stakeholders, should assist NARA in identifying and developing open  source records management solutions.

section_title: Conclusions
paragraphs: The majority of the 24 federal agencies had taken steps toward  addressing the seven directive requirements for managing government  records that had completion dates from November 2012 through  December 2014. However, certain requirements were not fully met by 5 of  the agencies. Specifically, not all agencies had designated Senior Agency  Officials at the assistant secretary level; reported to NARA on how they  planned to manage permanent electronic records, including e-mails;  identified and reported on permanent records that have been in existence  for 30 years or more; or identified unscheduled records. Further, the  Departments of Commerce, Defense, and Energy had not fully  implemented the requirement to develop records management training for  all employees, or had not ensured that all agency records officers held  the NARA certificate for Federal Records Management Training.  However, these 3 agencies indicated that they expect to complete their  requirements by the end of fiscal year 2015. Until agencies fully  implement the directive requirements, they may not be well-positioned to  implement the records management reforms envisioned by the directive.

In addition, OPM had finalized the records management occupational  series, and OMB had established a deadline for updating key guidance to  direct agencies to incorporate records management requirements when  moving to a cloud-based service. However, while NARA had taken action  to oversee agencies’ directive compliance and identified tools for  addressing electronic records management challenges, it had not  developed metadata requirements, which are needed to assess progress  and streamline agency efforts to process records. Completing this effort  could provide agencies with resources for more efficiently managing their  records.

section_title: Recommendations for Executive Action
paragraphs: To help ensure that directive requirements are met, we are making 10  recommendations to specific agencies and NARA.

We recommend that the Director of the Office of Personnel  Management take the following action:

Ensure that the Senior Agency Official designated to oversee the  agency’s compliance with records management statutes and  regulations is at or equivalent to the level of an assistant  secretary, as required by the directive.

We recommend that the Secretary of Veterans Affairs take the

Designate a Senior Agency Official at or equivalent to the level of  assistant secretary who has direct responsibility for ensuring that  the agency complies with applicable records management  statutes, regulations, and NARA policy, including being able to  make adjustments to agency practices, personnel, and funding.

We recommend that the Secretary of Transportation take the following  Identify permanent records that were in existence for 30 years or  more for one remaining component and report this information to  NARA.

We recommend that the Administrator of General Services  Administration take the following action:

Expedite efforts to ensure that permanent records that were in  existence for 30 years or more, including records stored at agency  records storage facilities, are identified and reported to NARA.

We recommend that the Director of the National Science Foundation  take the following four actions:

Establish a date by which the agency will complete, and then  report to NARA, its plans for managing permanent records  electronically. The plan should describe, among other things, how  permanent electronic records are currently captured, retained,  searched, and retrieved; plans to digitize permanent records  currently in hard-copy format or other analog formats; plans to  manage all permanent electronic records in electronic format,  including how the plans will be implemented; and challenges the  agency faced in achieving the requirement of managing all  permanent electronic records in an electronic format.

Establish a date by which the agency will complete, and then  report to NARA on, its progress toward managing permanent and  temporary e-mail records in an electronic format, to include the  agency’s ability to retain e-mail records in an electronic system  that supports records management and litigation requirements,  including the capability to identify, retrieve, and retain the records  for as long as they are needed.

Report to NARA on the identification of its permanent records in  existence for 30 years or more, to include when no such records  exist.

Complete the identification of unscheduled records stored at  agency records storage facilities.

We recommend that the Archivist of the United States take the

Establish a time frame and revise NARA transfer guidance for  permanent electronic records to include all aspects of metadata  requirements.

Identify tools to assist agencies with addressing records  management challenges in cooperation with the Federal Chief  Information Officers Council, the Federal Records Council, and  other government-wide councils that express interest.

section_title: Agency Comments and Our Evaluation
paragraphs: We requested comments on a draft of this report from the 24 major  agencies included in our study and from OMB and NARA. We received  comments from the six agencies to which we made recommendations,  which included NARA. Among these, OPM, the Department of Veterans  Affairs, the General Services Administration, the National Science  Foundation, and NARA provided written comments. Further, on May 5,  2015, the Deputy Director of Audit Relations for the Department of  Transportation provided comments via e-mail. Four of the agencies and  NARA either agreed or generally agreed with our recommendations, while  one agency had no comments, as summarized below:

The Chief Operating Officer for OPM stated that the agency concurred  with our recommendation and plans to designate its Chief Information  Officer as the Senior Agency Official. According to the Chief  Operating Officer, the agency’s Chief Information Officer is the  equivalent of an assistant secretary, and is appropriately located  within OPM to make adjustments to the agency’s practices,  personnel, and funding to ensure compliance and support the  business needs of OPM. The official added that the Chief Information  Officer has direct responsibility for ensuring that OPM efficiently and  appropriately complies with all applicable records management  statutes, regulations, and NARA policy. OPM’s comments are  reprinted in appendix II.

The Department of Veterans Affairs’ Chief of Staff stated that the  department concurred with our recommendation. The Chief of Staff  added that the department plans to designate its Chief Information  Officer as the Senior Agency Official, with delegation of daily  responsibility for complying with applicable records management  statutes, regulations, and NARA policy to the Associate Deputy  Assistant Secretary for Policy, Privacy, and Incident Response. The  department’s comments are reprinted in appendix III.

The Acting Administrator of the General Services Administration  stated that the agency concurred with and is developing a plan to  address our recommendation. The Acting Administrator further stated  that the agency would accelerate efforts to identify the location of its  records by the end of fiscal year 2015. The agency’s comments are  reprinted in appendix IV.

The National Science Foundation’s Chief Information Officer stated  that the agency had no comments on the draft report but is committed  to the continual improvement of information technology management,  including its efforts related to records management. The agency’s  comments are reprinted in appendix V.

In its comments, the Archivist of the United States said that NARA  concurred with the recommendation to establish a time frame and  revise transfer guidance for permanent electronic records to include  all aspects of metadata requirements. The Archivist added that NARA  believed it had met the second recommendation related to identifying  tools to assist agencies with addressing records management  challenges. In this regard, NARA provided us with evidence  supporting its identification of tools, and in response we updated our  report to reflect the actions taken. As an additional comment, the  Archivist expressed concern that the report did not include a  recommendation for NARA to revisit its guidance for the Senior  Agency Official’s roles, responsibilities, and overall designation,  especially as it pertains to independent agencies. The Archivist  believed such a recommendation would further empower Senior  Agency Officials within their component agencies. With regard to this  comment, we believe clearly designated roles and responsibilities are  important to ensuring the effectiveness of all agencies’ Senior Agency  Officials and that NARA has taken an important step in recognizing its  need to revisit guidance for independent agencies. As for the study  results and recommendations included in this report, our work focused  on the actions of NARA and the 24 major federal agencies to  implement the specific requirements outlined in the Managing  Government Records directive. NARA’s comments are reprinted in  appendix VI.

In comments provided via email, the Deputy Director of Audit  Relations stated that the Department of Transportation concurred with  our recommendation and that the agency would provide a detailed  response to the recommendation within 60 days of our report’s  issuance.

We also received written comments from the Department of Defense  (reprinted in appendix VII) and the Social Security Administration  (reprinted in appendix VIII). In the comments, the Principal Deputy for the  Department of Defense stated that the department concurred with the  report as written. The Executive Counselor to the Commissioner of the  Social Security Administration stated that the agency had no comments  on the draft report.

Further, we received technical comments via e-mail from the Department  of Justice, NARA, and the National Science Foundation, which we have  incorporated, as appropriate.

In addition to the aforementioned comments, liaisons for 15 other  agencies sent e-mails stating that their agencies had no comments on the  draft report. These agencies were the Departments of Agriculture,  Commerce, Education, Energy, Health and Human Services, Housing  and Urban Development, the Interior, Labor, State, and Treasury; the  Environmental Protection Agency; National Aeronautics and Space  Administration; Small Business Administration; U.S. Agency for  International Development; and Nuclear Regulatory Commission.

Two agencies—the Department of Homeland Security, and the Office of  Management and Budget—did not provide any responses to our request  for comments.

We are sending copies of this report to the Secretaries of the  Departments of Agriculture, Commerce, Defense, Education, Energy,  Health and Human Services, Homeland Security, Housing and Urban  Development, the Interior, Labor, State, Transportation, the Treasury, and  Veterans Affairs; the Attorney General; the Administrators of the  Environmental Protection Agency, General Services Administration,  National Aeronautics and Space Administration, Small Business  Administration, and the U.S. Agency for International Development; the  Archivist of the United States; the Directors of the National Science  Foundation, Office of Management and Budget, and Office of Personnel  Management; the Chairman of the Nuclear Regulatory Commission; the  Commissioner of Social Security; and other interested parties. This report  also is available at no charge on the GAO website at http://www.gao.gov.

Should you or your staff have any questions on information discussed in  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. GAO staff who made  major contributions to this report are listed in appendix IX.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to (1) assess the extent to which federal agencies  have taken the actions called for in the Office of Management and Budget  (OMB) and National Archives and Records Administration (NARA)  Managing Government Records Directive, and (2) determine the extent to  which the Office of Personnel Management (OPM), OMB, and NARA  have taken actions called for in the directive, including overseeing  agencies’ compliance. The scope of our review included the 24 major  agencies covered by the Chief Financial Officers Act of 1990, as well as  OMB and NARA.

To address the first objective, we took the following steps for each of the  24 agencies:

Compared agency documentation, such as records management  policy and departmental regulations to the requirements specified in  the directive that were required to be completed by the December 31,  2014, deadline. These requirements pertained to: (1) designating a  senior agency official, (2) managing permanent electronic records, (3)  managing permanent and temporary e-mail records, (4) identifying  permanent records and reporting on that information to NARA, (5)  identifying unscheduled records, (6) obtaining the NARA certificate of  Federal Records Management Training, and (7) establishing records  management training.

Obtained and reviewed records management policies, procedures,  and guidance.

Collected and analyzed documentation that described actions each  agency had taken to meet requirements of the directive, such as the  annual records management self assessment and Senior Agency  Official report.

Conducted structured interviews with records management officials  from each agency to discuss steps taken to address directive areas  and obtain additional supporting documentation to determine the  agencies’ status in implementing the directive requirements.

Followed up with those agencies that did not fully meet the directive  requirements to determine reasons for their noncompliance.

For the second objective, regarding NARA’s, OPM’s, and OMB’s  implementation of their responsibilities under the directive, we took the  following steps:

Collected and analyzed documentation on senior agency official  meetings held by NARA and records management communities of  interest and the Federal Records and Information Management  Program Maturity Model tool to evaluate agencies’ records  management programs.

Obtained and analyzed NARA documentation, to include transfer  guidance for permanent electronic records; guidance for managing,  disposing of, and transferring e-mail; the Senior Agency Official  template; and the results of a feasibility study on establishing a cloud- based service.

Obtained and reviewed NARA’s records management policies, plans,  and other documentation related to electronic recordkeeping.

Conducted structured interviews with NARA’s Chief Records Officer  and other agency officials regarding their interactions with the 24  agencies on the use of electronic recordkeeping and implementation  of federal records management policies and practices.

Interviewed OPM’s Chief of Records Management and other agency  officials to discuss the development of the records management  occupational series, and obtained and evaluated related  documentation.

Interviewed officials within OMB’s Offices of Information Regulatory  Affairs and E-Government & Information Technology to discuss  OMB’s efforts to update Circular A-130 and actions taken to assist  agencies with meeting the goals of the records management directive.

To assess the reliability of what agency officials told us about how they  met the requirements specified in the directive, we collected and analyzed  documentation from the 24 agencies to determine the steps that each  agency had taken to meet the requirements of the directive. We also  collected and reviewed documentation that NARA provided regarding the  status of agencies’ implementation of the directive areas.

Our study was conducted to determine whether the agencies in our  review had complied with requirements of the directive agency-wide, and  did not include a comprehensive assessment of all actions that agencies  may have taken to carry out responsibilities at the branch or sub-agency  levels.

We conducted this performance audit from March 2014 to May 2015 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 Office of Personnel Management

section_title: Appendix III: Comments from the Department of Veterans Affairs

section_title: Appendix IV: Comments from the General Services Administration

section_title: Appendix V: Comments from the National Science Foundation

section_title: Appendix VI: Comments from the National Archives and Records Administration

section_title: Appendix VII: Comments from the Department of Defense

section_title: Appendix VIII: Comments from the Social Security Administration

section_title: Appendix IX: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, the following staff made  significant contributions to this report: Anjalique Lawrence, Assistant  Director; Sharhonda Deloach; Elena Epps; Angel Ip; Lee McCracken; and  Robert Williams.


Question-summary annotations: questions: question: Why were some requirements not fully met?
answer: However, certain requirements were not fully met by 5 of the agencies because these agencies were either still working on addressing the requirement, or did not view the requirement as mandatory.
child_questions: question: What are examples of unmet requirements?
answer: For example, while all 24 agencies designated a senior official to oversee records management, 2 did not designate the official at the assistant secretary level, and 1 did not reaffirm the official by the specified deadline. Further, at 2 agencies, records management officers did not obtain the NARA training certificate or had not been granted an exemption.
child_questions: question: By when will these agencies complete their training?
answer: These agencies expect to complete their training by the end of fiscal year 2015.

questions: question: What have OPM, OBM, and NARA done regarding oversight?
answer: The Office of Personnel Management (OPM), OMB, and NARA took steps to implement 11 required oversight actions, although not all actions had been completed.
child_questions: question: What actions has OPM taken?
answer: For example, OPM finalized an occupational series to elevate records management roles, responsibilities, and skill sets for agency records professionals.

question: What actions has OMB taken?
answer: In addition, OMB was in the process of updating its Circular A-130 to include records management requirements for agencies when moving to cloud-based services or storage solutions.

question: What actions has NARA taken?
answer: Lastly, NARA, in consultation with other stakeholders, produced a plan to move agencies toward greater automation of records management. However, it did not include metadata requirements in its guidance, as required.

question: How does the lack of full implementation affect the federal government?
answer: Until agencies, OMB, and NARA fully implement the directive's requirements, the federal government may be hindered in its efforts to improve performance and promote openness and accountability through the reform of records management.

questions: question: How does the federal government use information?
answer: The federal government collects large amounts of information, increasingly in electronic form, to accomplish its missions.
child_questions: question: How has the transition to electronic data affected federal agencies?
answer: This greater reliance on electronic communication and information technology systems has, as a result, radically increased the information that agencies must manage.

question: What action have NARA and OMB taken regarding federal records management?
answer: In 2012, NARA and OMB issued a directive to reform federal records management in response to a 2011 presidential memorandum on managing government records.
child_questions: question: What does this directive mandate?
answer: The directive requires federal agencies, NARA, OMB, and OPM to take actions toward reforming records management policies and practices.

questions: question: What was GAO asked to review?
answer: GAO was requested to evaluate federal agencies' implementation of the directive.
child_questions: question: What were GAO's objectives?
answer: GAO's objectives were to (1) assess the extent to which federal agencies have taken the actions called for in the directive and (2) determine the extent to which OPM, OMB, and NARA have taken actions called for in the directive.

question: What data did GAO review for this report?
answer: To do this, GAO reviewed policies, guidance, and other documentation of actions taken through December 31, 2014, by 24 selected federal agencies, NARA, and OMB, and interviewed the agencies' records management officials.