Directive Established Federal Records Management Requirements

In response to the November 2011 presidential memorandum to begin an  executive branch-wide effort to reform records management policies and  develop a framework for the management of electronic government  records, the Director of OMB and the Archivist of the United States jointly  issued a directive to heads of federal departments and agencies. However,  certain requirements were not fully met by 5 of the agencies because  these agencies were either still working on addressing the requirement, or  did not view the requirement as being mandatory. Until agencies fully  implement the directive’s requirements, the federal government may be  hindered in its efforts to improve performance and promote openness and  accountability through the reform of records management. All Agencies Designated a Senior Agency Official to Oversee Records Management Activities, but Not All Designated the Official at the Appropriate Level

According to the directive, by November 15, 2012, and every year  thereafter, each agency is required to name or reaffirm the Senior Agency  Official who is responsible for coordinating with the agency records officer  and other appropriate officials to ensure the agency’s compliance with  records management statutes and regulations. In those cases, it agreed to grant the officer an exemption  from obtaining the certificate of Federal Records Management Training. OPM, OMB, and NARA Took Actions to Oversee Agencies’ Implementation of the Directive, but Not All Specified Actions Were Completed

OPM, OMB, and NARA had taken steps toward implementing the 11 of  13 actions specified in the directive as their responsibility, but selected  requirements had not been fully addressed by the specified deadlines. For example, OPM had finalized an occupational series to elevate  records management roles, responsibilities, and skill sets for agency  records professionals. In addition, according to an official in OMB’s Office  of Information and Regulatory Affairs, that agency was still in the process  of updating its Circular A-130 to include records management  requirements for agencies that are moving to cloud-based services or  storage solutions, with the updated circular expected to be released by  the end of calendar year 2015. Further, NARA had met with Senior  Agency Officials and produced a plan to move agencies toward greater  automation of records management. However, it had not included metadata requirements in its guidance, as  required. Also in December 2012, NARA completed a review of its records  management reporting requirements. Agency Comments and Our Evaluation

We requested comments on a draft of this report from the 24 major  agencies included in our study and from OMB and NARA. Appendix I: Objectives, Scope, and Methodology

Our objectives were to (1) assess the extent to which federal agencies  have taken the actions called for in the Office of Management and Budget  (OMB) and National Archives and Records Administration (NARA)  Managing Government Records Directive, and (2) determine the extent to  which the Office of Personnel Management (OPM), OMB, and NARA  have taken actions called for in the directive, including overseeing  agencies’ compliance.
Why GAO Did This Study

The federal government collects large amounts of information, increasingly in electronic form, to accomplish its missions. This greater reliance on electronic communication and information technology systems has, as a result, radically increased the information that agencies must manage. In 2012, NARA and OMB issued a directive to reform federal records management in response to a 2011 presidential memorandum on managing government records. The directive requires federal agencies, NARA, OMB, and OPM to take actions toward reforming records management policies and practices.
GAO was requested to evaluate federal agencies' implementation of the directive. GAO's objectives were to (1) assess the extent to which federal agencies have taken the actions called for in the directive and (2) determine the extent to which OPM, OMB, and NARA have taken actions called for in the directive. To do this, GAO reviewed policies, guidance, and other documentation of actions taken through December 31, 2014, by 24 selected federal agencies, NARA, and OMB, and interviewed the agencies' records management officials.

What GAO Found

The 24 federal agencies took actions toward implementing each of the seven requirements set forth in the National Archives and Records Administration (NARA) and Office of Management and Budget (OMB) directive on managing government records (see table).
However, certain requirements were not fully met by 5 of the agencies because these agencies were either still working on addressing the requirement, or did not view the requirement as mandatory. For example, while all 24 agencies designated a senior official to oversee records management, 2 did not designate the official at the assistant secretary level, and 1 did not reaffirm the official by the specified deadline. Further, at 2 agencies, records management officers did not obtain the NARA training certificate or had not been granted an exemption. These agencies expect to complete their training by the end of fiscal year 2015.
The Office of Personnel Management (OPM), OMB, and NARA took steps to implement 11 required oversight actions, although not all actions had been completed. For example, OPM finalized an occupational series to elevate records management roles, responsibilities, and skill sets for agency records professionals. In addition, OMB was in the process of updating its Circular A-130 to include records management requirements for agencies when moving to cloud-based services or storage solutions. The agency expects to release the updated circular by December 2015. Lastly, NARA, in consultation with other stakeholders, produced a plan to move agencies toward greater automation of records management. However, it did not include metadata requirements in its guidance, as required. Until agencies, OMB, and NARA fully implement the directive's requirements, the federal government may be hindered in its efforts to improve performance and promote openness and accountability through the reform of records management.

What GAO Recommends

GAO is making 10 recommendations to 5 federal agencies and NARA to ensure records management directive requirements on designating senior officials and identifying, reporting, and managing records are met. In commenting on a draft of this report, the agencies and NARA generally agreed with the recommendations.