“This is not a governmentwide game of kick the can,” Brewer said in an interview. “This is a limited amount of time where we really want . . . and expect agencies to prioritize the work on these requirements that are still intact in M-19-21 and accelerate their progress towards achieving these goals.”
Brewer said the shift to remote work, due to the pandemic reinforced why moving to fully electronic records is an imperative for agencies. Some agencies told NARA that the shift to remote work helped accelerate the transition to electronic recordkeeping.
“As most of us were working off site in our kitchens, in our dining rooms, we learned that paper-based processes, or pushing paper around is no longer viable,” Brewer said. “Through our reporting data, we learned that agencies that had already made investments in electronic records management, prior to the pandemic, were much more successful in meeting their agency goals.”
But COVID-19 also tripped up many agencies’ digitization projects. Fewer employees could go to their offices to access hard copy records and either digitize them or send them to one of NARA’s 18 federal records centers. Which were also closed for months during the height of the pandemic.
Beyond the pandemic’s effects, however, agencies faced long-term challenges in meeting the original 2022 deadline. One issue, Brewer said, is a long history of paper-based processes. Many agencies still traffic in “large volumes” of legacy paper records and legacy systems that need updating.
“There is still this culture of paper in a lot of agencies,” Brewer said. “It’s really a change management issue in overcoming that. And while the pandemic I think did really significantly push agencies forward, even the ones who haven’t invested prior to the pandemic. There are still a lot of change management and process improvement work that needs to be done.”
But funding the shift to electronic recordkeeping remains a major challenge at many agencies. In NASA’s 2021 report to the Archives, the agency’s top records official said the pandemic presented the “largest challenge” in meeting the e-records deadline.
“However, while NASA has been a prolific records originator, financial priorities of the agency are in meeting agency space and science missions,” the report continues. “Thus, even without the pandemic, NASA would likely not have had the necessary resources to either fully digitize all legacy analog records, or to finance their movement to [federal records centers (FRC)] or commercial records centers.”
Brewer acknowledged funding and staffing digitization projects is a major challenge.
“We’ve certainly acknowledged along with the Office of Management and Budget that this is work that is important, but does require some investment,” he said.
“For the most part, agencies get the value proposition of working electronically and fully electronically,” Brewer added. “For most agencies, the motivation is there. It’s how do they get there? How do they resource it?”
The latest directive from NARA and OMB will allow agencies to request exceptions to the June 2024 deadline. In cases where replacing paper with digital records “would be burdensome to the public, the cost would exceed the benefit. Statutory or regulatory barriers impede implementation, or there is exceptional intrinsic value in the original format,” the memo states.
Brewer said he expects exceptions to be “fairly limited in nature” and based on an agency demonstrating headway toward fully electronic records.
“As we provide responses back to agencies on requests for exceptions. We are building in a process where those approvals are contingent upon reporting of progress, so that we can monitor how the agency is continuing to make improvements,” he said.
New digitization standards
NARA is helping agencies achieve the digitization goals on a few different fronts, Brewer said. He expects NARA will finalize a long awaited rule this year for digitizing permanent records that will eventually be transferred to the Archives. The agency issued a proposed rule in December 2020.
The regulations should give agencies more leeway to move away from managing paper. As NARA had previously advised agencies against getting rid of permanent records they had digitized prior to the final rule’s release.
“They cover everything that an agency would need to do as part of the digitization process, including the technical standards. But also the quality control, the metadata, and everything else that you would have to have, as you are making the digital copy the replacement for the paper copy,” Brewer said.
NARA also plans to finalize standards for electronic records management (ERM) tools and services in 2023, as part of the Federal Electronic Records Modernization Initiative (FERMI). The initiative is part of the Archives’ effort to provide “governmentwide, modern cost-effective, standardized, and interoperable set of records management solutions and services to federal agencies,” according to NARA.
Brewer said NARA is continuing to work with the General Services Administration to provide agencies with options for ERM tools and products.
“We’re trying to deal with it on a number of different fronts, always looking for opportunities where we can leverage what we do well. Which is requirements and our knowledge of records management, and seeing how we can build some momentum with the private sector and with other agencies who want to require the kinds of tools that they need to better manage electronic records,” Brewer said.
Meanwhile, agencies are also preparing to transition to a new system for scheduling and transferring electronic records to NARA. The Electronics Records Archive (ERA) 2.0 system is set to go live in the “March/April time frame,” Brewer said.
NARA is currently migrating data into the new system. And Brewer said the Archives will shut down the legacy ERA system for about “three to four weeks” just prior to launching ERA 2.0 to complete the data migration.
“We’ll also be providing updates to federal agencies during this process on the timing, and the launch of ERA 2.0. And we’re working on training to make sure that our agency customers will be ready to go once it goes online,” he added.