Acquiring Internal Approvals and External Authorizations
Preparing and Submitting Records Schedules: A Guide for Agencies
Managing records effectively is crucial for any government agency, and one of the key steps in this process is the creation and submission of a records schedule to the National Archives and Records Administration (NARA). In this article, we'll walk you through the steps involved in preparing, reviewing, and submitting a records schedule, as well as the role of the Government Accountability Office (GAO) in the process.
Preparation and Internal Coordination
The first step in creating a records schedule is internal preparation. Agencies develop a schedule that outlines disposition authorities for the records they manage, ensuring it aligns with their records management policies and includes any Privacy Act restrictions or non-record materials handling instructions. This schedule may be issued through records management directives or issuance documents that incorporate both agency-specific and General Records Schedule authorities.
Internal Review and Clearance
Before submitting the records schedule to NARA, it's essential to ensure all internal reviews and clearances are obtained. This involves coordination among records officers, legal, privacy, and possibly program offices to ensure compliance and completeness. These reviewers evaluate the business need, legal considerations, and classification of the records.
Submission to NARA
Once the records schedule has been internally reviewed and cleared, it's submitted to NARA for written approval. NARA reviews the schedule to determine if the records are eligible for transfer and retention according to federal laws and regulations. Agencies must receive NARA approval before applying disposition instructions or transferring permanent records.
GAO's Approval Process
If the records schedule impacts financial records or audits, the GAO may be involved for approval or review of schedule provisions relevant to auditing and financial accountability. While the exact GAO approval steps are not detailed explicitly, agencies generally coordinate with GAO to ensure that the schedule aligns with audit requirements and any necessary controls over records reliability and access. GAO's review would focus on ensuring records management practices support oversight and accountability functions effectively.
Post-Approval Implementation
Once NARA (and possibly GAO) approvals are obtained, agencies must implement the records schedule within six months, issuing internal directives with instructions on management, access controls, and disposition of records as approved by NARA. Agencies remain responsible for updating schedules and ensuring compliance during electronic records or other records management initiatives.
Seeking Internal Review
In addition to the standard review process, agency records officers may seek internal review from other offices, such as the agency historian, Information Technology, Chief Information Office / Chief Data Officer, and legal counsel, especially when records involve legal rights. Program offices should also review draft records schedules before submission to NARA.
GAO Approval and Deviations
It's not necessary to have GAO approval at schedule submission, as long as it has been requested. Agencies must receive GAO approval before NARA can approve the schedule. If an agency needs to deviate from the General Records Schedule for accountable officer records, they must follow the records scheduling process, provide documentation of GAO's concurrence, and send requests for GAO approval to the GAO Records Officer. Accountable officer records are covered by GRS 1.1, item 010.
Resolving Concerns and Contacting NARA
Any concerns about the schedule should be resolved before submission to NARA. If you need further help, contact your agency's assigned NARA appraiser. Once you've completed these steps, you'll select the status of GAO approval on each item of a proposed records schedule and return to The Inventory, Scheduling, and Disposition of Federal Records (ISD) for more information.
In summary, preparing and submitting a records schedule involves internal preparation, review, and clearance, submission to NARA for approval, potential GAO review and approval, and post-approval implementation. By following these steps, agencies can ensure their records management practices are effective and compliant with federal laws and regulations.
- The records schedule, which outlines disposition authorities for the records managed by agencies, needs to align with their records management policies and include any Privacy Act restrictions or non-record materials handling instructions, as this schedule may be used for business purposes and is crucial in the realm of finance.
- If the records schedule being reviewed impacts financial records or audits, the Government Accountability Office (GAO) may be involved for approval or review of schedule provisions relevant to auditing and financial accountability, to ensure that the records management practices support oversight and accountability functions effectively in the finance sector.
