FADGI Compliance Timeline

“Agencies are all over the map with regards to digital maturity.”
- Jennifer Nnanna, Public Sector Business Development Manager at Kodak Alaris

Jennifer Nnanna

Public Sector Business Development Manager at Kodak Alaris

Digitalization Strategy

“There's quite a bit of work to do, to ensure the agency is setting up for future digitization in a strategic and efficient fashion.”
- Jennifer Nnanna, Public Sector Business Development Manager at Kodak Alaris

Jennifer Nnanna

Public Sector Business Development Manager at Kodak Alaris

A shift from paper to electronic records is underscoring the need for agencies to implement a broader digitization strategy.

A joint memo from the National Archives and Records Administration and the Office of Management and Budget, M-19-21, requires agencies to convert all new permanent records to an electronic format.

By the end of the year, NARA will no longer accept paper records from agencies for permanent archiving.

But beyond these deadlines, agencies should also think more broadly about how a digital records management strategy can improve mission delivery, said Jennifer Nnanna, public sector business development manager at Kodak Alaris.

The federal government spends millions of dollars and considerable effort every year creating and storing paper records, Nnanna noted. Meeting the goals of M-19-21, she added, will not only reduce those costs but will improve agency efficiency through easier access to records.

“Agencies are all over the map with regards to digital maturity. When most people of hear this, they assume a massive budget undertaking. But the reality is that the right technology, paired with the right process, does not have to be that overwhelming from a funding standpoint,” she said.

Although agencies have until the end of the year to comply with the year-end deadline, Nnanna said NARA and OMB have made it clear agencies should take the time to have a clear digitization strategy in place, rather than rush to meet the deadline.

Nnanna said M-19-21 compliance is “essentially an honor system,” and that NARA “doesn’t have the infrastructure to be hall monitors.”

NARA and OMB, in its guidance, have outlined several broad categories for exceptions to the M-19-21 year-end deadline. Those include cases where replacing analog records with electronic systems would be burdensome to the public or if the cost of digitization exceeds the benefit.

Nnanna 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.

That access to records also applies to members of the public, as underscored in the 2016 case, Robinson Jr. v. McDonald.

The case involved a veteran, Leroy S. Robinson Jr., seeking access to the original paper records he submitted as part of his application for benefits from the Veterans Affairs Department.

Robinson argued that VA was denying his claims in part because the agency was missing documents from the records he submitted.

He submitted a request to examine the documents in his original paper documentation, but VA told the court that documents had been “scanned and uploaded” and the original paper file was no longer available for review.

The court determined the Robinson had a right to inspect the paper source documents in VA’s possession. It said the ruling also applied in cases where  VA converted documents into electronic records for storage in the Veterans Benefits Management System and Virtual VA databases.

The case showcases the importance of an agency having a clear document management strategy that considers capture, storage and retention, Nnanna said.

“There’s quite a bit of work to do, to ensure the agency is setting up for future digitization in a strategic and efficient fashion,” she said.

Having a robust records management system is also critical for agencies that provide benefits in the aftermath of a disaster, like the Federal Emergency Management Agency, Nnanna said.

“With a records management system, where things are digital and you can easily find this information, it could literally cut down the amount of fraud and a lot of different things that are happening,” she said.

Nnanna said the M-19-21 mandate pushes agencies to think about a broader digitization strategy that requires careful planning and execution.

Key elements of that strategy include agencies maintaining a comprehensive records management program, naming a senior agency official for records management and providing annual training to staff.

“Without a detailed roadmap of when, where, how an agency is headed in its digitization journey, the odds of landing it and successfully taking care of it are unlikely. You need the proper documentation and process efficiencies as well as cost management,” Nnanna said.

An agency’s records management strategy should also consider a broad range of records.

Although a majority of agency records are subject to temporary retention standards, Nnanna said roughly 5% of all documents are permanent records that need to follow the stricter archiving standards.

In those cases, agencies are expected to comply with standards that stem from the Federal Agencies Digital Guidelines Initiative.

“If you had a coffee stain on a document, they want that original coffee stain to be on that document as well,” Nnanna said.

Agencies should ensure they invest in future-proof digitization tools that can handle both day-to-day records compliance and archival requirements, she said.

“If an agency is worried that we’re going to buy this piece of equipment, and we’re only going to use it for FADGI, no, you’re not. You can implement that into your day-to-day practice,” Nnanna said.

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