Although Subchapter B was reorganized in 2009 and went through the Federal Register process, little changed. The words were simply put in different places.
Existing practices as described may have suited the Federal Agencies in the past, but they haven't kept up with the times. Funding and staffing is shrinking and the manner in which records are created has changed completely from the manner in which the CFR was written to support.
When Part 1236 was added, it was written attempting to apply paper record processes and practices to electronic records and at that time, no one was aware it didn't work. Now, it has become painfully apparent that to apply the practices as written would be overly cumbersome, more costly than justified, and out of step with how ECMS, ERMS, RMAs and other products designed for the management of electronic information assets work.
As Agency staffing decreases, more work is being assigned to Contractors and many were/are unaware of the requirements contained in 36CFR for generation and management of records when they bid to perform work. Funding provided is never sufficient to establish RM Systems and Programs able to meet these requirements, which end up being seen as unfunded mandates.
Contractors seek relief from the requirements and Agencies, unable to force compliance with the requirements, largely due to a lack of funding, end up reducing the burden for compliance.
By re-writing 36CFR Subchapter B and focusing on WHAT needs to be accomplished rather than HOW to accomplish it, compliance will increase and a better system will be realized.
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