Date: March 27, 2012
TO: David S. Ferriero, Archivist of the United States, National Archives and Records Administration (NARA); Jacob J. Lew, Director of the Office of Management and Budget (OMB); and Tony West, Associate Attorney General (Acting), Department of Justice (DOJ)
RE: MEMORANDUM TO FEDERAL AGENCY HEADS: Presidential Memorandum on Managing Government Records
On behalf of the board of directors of the National Association of Government Archives and Records Administrators (NAGARA), please consider this response to the November 28, 2011 directive from the President to Heads of Executive Departments and Agencies on Managing Government Records.
NAGARA, established in 1974, is governed by a board of directors drawn from its member organizations of local, state, and federal government archives and records programs. NAGARA’s committees, task forces, and other working groups champion excellence in the management of government records programs for the benefit of the American public.
NAGARA’s programs and initiatives engage issues at all three levels of government by fostering intergovernmental records projects and activities. There is an opportunity for the Records Management Directive to further expand improvements and cost savings for Federal records by also addressing state and local government records. The concomitant benefit would be to improve records programs and save money for state and local governments too.
For example, the NARA sponsored NAGARA Intergovernmental Cooperative Appraisal Project included the Food Stamp Records Project,* which resulted in the elimination of half a billion pages of unnecessary or duplicative records in storage nationwide and also advanced electronic recordkeeping in the welfare reform statute of 1996. Since then NAGARA’s studies and reports, some supported by NARA’s National Historical Publications and Records Commission, have successfully been used by agencies at all levels of government to promote 21st century approaches to managing government records. Parallel high level endeavors including the issuance of U.S. Office of Management and Budget circulars provide substantial information and guidance for oversight and operations of federal assistance programs administered by states that lay the foundation for sound information management. Also, currently many databases combine and cooperatively control information contributed by federal, state, and local programs. While laudable, one only has to read the news to know that these programs have yet to ensure that the majority of records are adequately managed to ensure efficient and trustworthy government for taxpayers.
Tackling the problem solely within federal agencies will not solve the federal problem or achieve the ultimate goal that citizens trust public records. The intergovernmental successes point out the potential for significant and essential improvements in coordinating records management to ensure that all levels of government services operate with integrity in the areas of education, health, public safety, public works and more.
Therefore, NAGARA’s response to Section 2(b)(3) Identify policies or programs that, if included in the Records Management Directive required by section 3 of this memorandum or adopted or implemented by NARA, would assist the agency’s efforts to improve records management:
1. Establish a commission or other group that includes partners from states and localities to address the records management paradigm with a mandate to reduce records redundancies and coordinate retention requirements among federal, state, and local governments especially in those areas where federal programs are implemented locally.
2. Create a comprehensive information management governance structure that partners with professional organizations, including NAGARA, to combine current advisory bodies such as the NARA Federal Records Council, the Office of Information and Regulatory Affairs and the CIO Council.
3. Restructure the NARA Federal Records Council to recognize the role of professional associations.
We are greatly supportive of the efforts of NARA and OMB to address records issues and needs and offer our services in the process in any way deemed appropriate. We look forward to reading the directive and helping as we can to implement the findings.
Paul R. Bergeron, President
National Association of Government Archives and Records Administrators
* Crossing Boundaries: Intergovernmental Records Cooperation, 1987-1997,
Marie Allen, The American Archivist; Vol. 60, No. 2, pp. 216-233