Managing Government Records

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"Maintaining accountability through documentation of agency actions" (Presidential Memorandum - Managing Government Records Sec. 3 (iii).)

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  Re-Write 36CFR, Subchapter B

  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 ...more »

  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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  Submitted by rimman.larry 1 year ago

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  Mandate compliance within IT Systems

  The Office of Management and Budget should require records identification and compliance with records policy for all deployments of information technology in the federal government. The Capital Planning and Investment Control (CPIC) process should do more than pay lip service to the records status of information managed in federal IT systems. Records Management is a requirement similar to the Section 508 requirements ...more »

  The Office of Management and Budget should require records identification and compliance with records policy for all deployments of information technology in the federal government. The Capital Planning and Investment Control (CPIC) process should do more than pay lip service to the records status of information managed in federal IT systems. Records Management is a requirement similar to the Section 508 requirements for accessibility. Currently, the CPIC process is biased against ensuring compliance with records management requirements. The process is focused on IT security and on compliance with mandates that are driven by technology. Records Management is riven by business needs and that is something IT managers have no direct understanding of. This is something that can be done but it will require IT managers to listen to and follow the direction of the business leads in agencies. That is something IT managers are not used to doing.

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  1 comment for Idea: Mandate compliance within IT Systems

  Submitted by Community Member 1 year ago

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