Headshot of Laurence Hart

Laurence Hart

Director Consulting Services

Three years ago, Office of Management and Budget Memorandum M-19-21 directed all agencies to manage and submit all records to the National Archives and Records Administration electronically by the end of 2022. Initial optimism for meeting the deadline has gradually grown into trepidation. It became clear that many agencies were not going to be ready in time, which has led NARA to extend the December deadline by 18 months to June 2024.

We cannot blame the difficulties on COVID-19. While the pandemic had a significant impact on agencies’ efforts, the task of moving to a fully digital workplace using electronic records is much harder than simply procuring software and digitizing existing paper. The larger— and more critical—hurdle is ensuring that current processes do not generate new paper.

The reality is that in many agencies, paper has always been the universal standard. Paper makes in-person interactions with the public easy, regardless of the setting. To meet the deadlines set out in M-19-21, federal agencies need to determine how to reduce their use of paper and share electronic records without creating redundant records. Agencies that haven’t already fully assessed the scale of this challenge will still not be ready in 18 months.

What does M-19-21 require?

Issued in June of 2019, M-19-21 outlined a plan for transitioning to electronic records in the federal government, culminating in NARA exclusively accepting electronic records. M-19-21 outlined four critical steps agencies needed to accomplish:

  • By the end of 2019, federal agencies will manage all permanent electronic records in an electronic format
  • By the end of 2022, federal agencies will manage all permanent records in an electronic format and with appropriate metadata
  • By the end of 2022, federal agencies will manage all temporary records in an electronic format or store them in commercial records storage facilities
  • Federal agencies will maintain robust records management programs that comply with the Federal Records Act and its regulations

To stress the importance of the two December 31, 2022 deadlines above, M-19-21 also stated that NARA would no longer accept analog records after December 31, 2022. This makes sense, since agencies should not be generating new paper records after 2022. NARA’s unwillingness to accept paper records after the deadline has forced agencies to take the transition to electronic records seriously.

The records management challenge

Electronic records management is not a new concept. Some agencies began deploying the technology in the 1990s. Success has been hard to achieve, especially for those agencies who interact with citizens as part of their mission. Successful programs have taken years to reach that point, often after more than one false start.

Moving to 100% digital processing is a challenge for many agencies, even with a three-year head start. In a digital world, all the interactions with the digital record have to be mapped out and fit into how work is done. Agencies must understand the different technical capabilities of the citizens they are serving. When sharing records with other agencies, discussions as to who is holding the record versus a copy of the record and how those external agencies can update the record can be complicated.

Simply dropping in a technology solution will neither answer these questions nor help drive compliance. That approach has been tried—and failed—over the decades. People simply will not use the technology if they perceive it as hindering the achievement of the mission. Agencies taking that approach to meet the M-19-21 compliance are setting themselves up for continuing the pattern of failure that has persisted for decades.

Take time to understand the problem

The first step to not repeating the mistakes of the past is to analyze and plan. Learn how your agency manages all your records, decide what a future digital state looks like and map out the steps you need to take to get there.

Eighteen months is not a lot of time in the federal IT world. It is important to ensure that current efforts are well directed and focused towards the right work. If you don’t already have a well-formed strategy and plan, now is the time to put them together.

NARA will be granting agencies extensions as warranted, which many of them will need. However, NARA is not going to hand extensions out freely. As Laurence Brewer, Chief Records Officer at NARA, said recently: “For the time period beyond the 18 months we’ll be looking for detailed plans on the work that you will be doing to meet the goals for the transition to fully electronic government and those goals that are currently in M-19-21.”

To be successful in eventually meeting the goals and gaining needed time via an extension, a well- thought-out strategy and plan need to be in place first. If you want to know how CGI Federal can help you find the right path forward, contact us today.

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About this author

Headshot of Laurence Hart

Laurence Hart

Director Consulting Services

Laurence Hart is a proven leader in enterprise content management (ECM) and information governance.