Gaining Internal Approvals and External Authorizations
Streamlining Records Management: An Inside Look at Agency Procedures
Managing records effectively is crucial for any government agency. Here's a step-by-step guide on how agencies ensure their records schedules meet federal requirements and are approved by the National Archives and Records Administration (NARA).
1. Internal Reviews and Agency Records Officer Involvement
The agency records officer plays a pivotal role in coordinating the preparation of the records schedule. They ensure it aligns with the agency's mission and complies with existing federal requirements.
Internal reviews are essential to verify that all relevant program offices, legal counsel, and possibly Privacy Act officials have reviewed and cleared the schedule according to the agency's policy before submission. Once NARA approval is received, agencies issue internal records disposition instructions incorporating the approved schedule, often accompanied by training for staff on schedule use.
2. Submission and Appraisal by NARA
After internal clearances, the schedule is submitted to NARA for appraisal and determination of retention and disposition periods. NARA reviews the schedule for completeness, legal compliance, and appropriateness of retention terms.
Once NARA approves, the disposition authorities become mandatory nationally. Agencies must issue approved schedules internally within six months of NARA approval.
3. Role of GAO
The Government Accountability Office (GAO) may intersect with agencies in cases of audits or investigations related to record-keeping practices. However, GAO approval is not a routine step for schedule approval itself.
In some cases, such as special audits (e.g., DoD records related to UFO crash incidents), GAO may review agency compliance. But it's important to note that GAO itself does not provide routine approval for schedules submitted to NARA.
4. Documentation and Training
After clearance and approval, agencies often issue internal directives on how to manage records under the new schedule, including specifics on filing, handling non-record materials, Privacy Act considerations, and training requirements to ensure proper implementation.
Key Takeaways
- The primary clearance involves internal agency review led by the agency records officer, followed by submission to and approval by NARA.
- GAO involvement is limited to audit or oversight roles, not the approval process of records schedules.
- Agencies must request GAO approval for deviations from the General Records Schedule (GRS) for accountable officer records.
- After NARA approval, agencies must implement the schedule internally with clear instructions and training.
[1]: Agency Guidance on Records Management [2]: GAO Special Audits [3]: NARA Records Schedules [4]: Requesting GRS Deviations [5]: Agency Records Officer Contact List
- To effectively manage their records in accordance with business and financial operations, government agencies rely on the guidance provided in Agency Guidance on Records Management.
- The National Archives and Records Administration (NARA) plays a significant role in approving records schedules for the business sector, ensuring that retention and disposition periods are appropriate and comply with federal requirements.
