Managing Government Records

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  Enabling Agencies to Fulfill Missions »

  The Comments are Coming in- Time to Move Forward!

  HAving seen comments submitted by a couple of Agencies, it is apparent they want to see not only RM processes updated, but a total revamp of guidance provided by NARA. They also see a need for an acknowledgement of the immense cost associated with improving RM at the Federal level. I can guarantee you, they didn't pull their punches. It is time for many of the ideas being submitted here to be taken seriously. This ...more »

  HAving seen comments submitted by a couple of Agencies, it is apparent they want to see not only RM processes updated, but a total revamp of guidance provided by NARA.

  They also see a need for an acknowledgement of the immense cost associated with improving RM at the Federal level. I can guarantee you, they didn't pull their punches.

  It is time for many of the ideas being submitted here to be taken seriously. This has been a great place to rebut those who have spent too much time working for NARA and are trying to defend the status quo. Those of us who have worked in both public and private sectors can truly point out the flaws in the Emperor's New Wardrobe.

  No idea at this point where the money is going to come from to make the changes needed- some may be realized by discontinuing/improving existing inefficient practices, but that won't scratch the surface. These improvements are going to take staff within Agencies and at NARA that have KSAs that do not currently exist, and they will require FRESH thinking.

  Much of it is going to have to start with suspending the use of and rewriting 36CFR, Subchapter B, to be more consistent with more effective RM practices used in corporate settings and ESPECIALLY those related to how electronic content is created, used and managed.

  Another major effort is going to be the overhaul of the General Records Schedules and completing earlier work that had begun to establish larger aggregations of records retention periods ("Big Buckets") to enable the application of retention periods to electronic content in a more automated manner.

  Just like Rafiki told Simba in the Lion King when he came of age... "It is TIME".

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  Submitted by rimman.larry 1 year ago

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  Accountability through Documentation »

  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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