The COVID-19 pandemic is demonstrating the need for agencies to make the shift from paper to electronic records.

The pandemic led to the temporary closure of federal facilities, and resulted in a backlog of requests for largely paper-based records. Some agencies are still addressing those backlogs.

Lisa Haralampus, the director of records management policy and outreach at the National Archives and Records Administration, said the pandemic accelerated the move to electronic records across the federal government.

“It was a driver far better than policy, but the consequence of the government’s posture is that we do see electronic records management happening more and more,” Haralampus said in a recent interview.

Even before the pandemic, NARA and the Office of Management set goals for agencies to phase out paper as part of their records management procedures.

Under M-19-21, the latest in a series of joint memos, NARA and OMB require agencies to convert all new permanent records to an electronic format. By the end of this year, NARA will no longer accept paper records from agencies for permanent archiving.

“The vision of all those memos is how you make the federal government fully digital, so that you can gain access, move at the speed of business, so that you can take the information you have, share it, use it [and] reuse it,” Haralampus said.

Haralampus said agencies who meet the goals of M-19-21 will improve the effectiveness and efficiency of their operations by making their records more accessible.

“I think we’re in the middle of the great transition, from where we were in the past — actually having paper records and managing paper records, printing things because we just didn’t trust the storage and the saving – to where we are now. There is a feeling of trust, that we know we can do it. We can use cloud storage. We’ve got the space, we’ve got the tools. How do we get to where it’s actually fully digital?” she said.

The pandemic, however, also stalled some agency efforts to digitize their records.

Haralampus said there’s been discussions between NARA and OMB about whether the M-19-21 deadline needs to be moved, since the pandemic impacted physical records management to a large degree.

“The government’s posture is changing. We see agencies returning to offices. We’re about to do more physical records management. So we want to be there right now and capture that momentum, to push records that are currently in analog format to digital format,” she said.

Michael Horsley, an electronic records management and policy analyst at NARA, said M-19-21 sets digitization standards based in part on the Federal Agencies Digital Guidelines Initiative (FADGI).

“We’ve taken the initiative to say, ‘We’re adopting and promulgating these standards that are based on well-known image science, and we’re saying it’s good enough for electronic records to serve the evidentiary and legal aspects,’ ” Horsley said.

FADGI outlines the steps organizations should take when it comes to scanning, processing and cleaning up digital scans of hard-copy records.

“Agencies really need to follow what’s in the regulations and use FADGI as a reference tool to inform a larger part of the process,” Horsley said.

Haralampus said FADGI standards, in some cases, exceed the records digitization standards NARA is setting for agencies.

“FADGI does more than NARA needs, so that’s why we’re writing our standards, to pull out the pieces that will apply to agencies,” she said.

NARA’s first round of guidance to agencies, she added, covered the digitization of paper-based text records and photographic prints. Those records make up the vast majority of agency records.

Records digitization requires more than a one-size-fits-all approach. Horsley said that FADGI standards set a high baseline for image quality, which is critical for archiving permanent records.

“To a relative degree, we’re able to capture what the human eye can see. The rule of thumb is that the experience digitally should be the same as you sitting down at a reference desk looking at the object in front of you,” he said.

On the other end of the digitization spectrum, Horsley said NARA worked with FADGI to create an entry-level mass digitization standard for “modern textual documents.”

“Image your laser-printed paper that has a completely white background and has black text. There’s not a lot of subtle color gradations in there. A lot of devices were failing, because they weren’t meeting kind of an arbitrary standard, but a standard that was fairly high,” he said.

Horsley said FADGI standards make sense for capturing the details in original, historical documents.

But by setting other standards for modern textual documents, he said NARA is trying to “balance two worlds” when it comes to records digitization.

“We’ve tried to make it more accessible to a wide range of imaging projects, so that it’s not just left in the realm of the high end, museums scanning a Rembrandt painting. We use the same principles,” he said.

NARA and OMB, under M-19-21, are directing agencies to maintain a FADGI 3-Star level of preservation for permanent records.

“To a certain extent, I can’t predict if it’s going to be future proof, but FADGI 3-Star allows you greater ability to employ, in the future, AI tools,” including optical character recognition , Horsley said.

“We’re not demanding OCR, but we found that a FADGI 3-Star and above opens up a whole new world of being able to apply things because the initial quality is good enough, and then you can expand off of that.”

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