Federal agencies must fully transition to electronic recordkeeping by the end of 2022, when the National Archives and Records Administration will stop accepting new paper records. As the change will make government more effective and efficient, complete the transition milestones set out by the Office of Management and Budget M-19-21 memo will force agencies to rethink how they manage electronic documents and content.
Just over a year into this process, GCN’s sister site, FCW, brought together a group of federal records management experts to discuss some of the challenges of transitioning to electronic records management. The discussion was recorded but not for individual attribution (see box for list of participants), and quotes have been edited for length and clarity. Here’s what the band had to say.
On track but lacking resources
Although agency readiness levels vary widely, most participants said they were on track to meet the M-19-21 deadlines. However, whether the tools and resources available are sufficient is another question.
“There are never enough resources,” one official said. “We have excellent resources to the extent that we have them,” referring to the record staff and schedules that have been developed, but the work will exceed them – and the adoption of remote working collaboration tools this year does not only increased the degree of difficulty.
The growing range of communication tools used by agencies complicates this resource challenge in terms of staff and money. Too often, participants said, the adoption and deployment of these tools happens before the requirements of the Federal Records Act are considered.
One manager called the SharePoint experience a cautionary tale: “People spent millions and millions and millions of dollars cleaning up SharePoint over a decade because they didn’t think about governance issues. who were associated with it upstream.” Yet with this year’s teleworking surge brought on by COVID-19, Microsoft saw its Teams collaboration suite grow “from 31 million users to 44 million users to 75 million users in six weeks. It will be a hell of a mess of governance downstream.
“Inevitably, as we move to the cloud and especially as applications move to the cloud, the pace of change accelerates,” another executive said. “And I think that comes with some risk of obsolescence and challenges in terms of third-party solutions connecting to cloud solutions because they don’t iterate at the same rate as the platform. I don’t have an answer to that except that it’s something that worries me as to how it ultimately fits together.
Even when a given application is nearly ubiquitous, there are complications. The group discussed the pros and cons of relying on the built-in records management capabilities of Office 365, for example. Several were skeptical of their sufficiency for their agencies’ needs, and one noted that not all of these capabilities were authorized under the Federal Risk Management and Authorizations Program during the first deployment.
Others, however, pointed to the broader ecosystem of tools available to do true document management in Office 365. “There are other players and partners that exist to fill in some of these gaps,” said l ‘One. Two.
Ultimately, another official noted, “It’s a community of systems supporting a business process. I think as a community we are still struggling to catch up with the speed and ever-changing landscape more than we had before. And we don’t have the luxury of time.
One participant suggested that the ongoing diagnostic and mitigation program – where the Department of Homeland Security and the General Services Administration have established a list of approved products, government-wide reporting requirements and even a centralized funding for cybersecurity tools – could be emulated for electronic records management.
“While I’m not looking to have NARA sponsored in the same way as DHS,” the official said, the idea of ”leveraging the CDM model of how we buy tools and integrate them and have a Integrated suite of tools is something we are heavily invested in.
Legacy archives vs future data
Ultimately, the group agreed that fundamentals are more important than specific technologies.
“What I’ve seen watching my compatriots in other agencies is that they’ve spent incredible amounts of money deploying technology,” said one attendee. “And those solutions weren’t as effective as they were sold because some of the fundamentals hadn’t been put in place – like understanding your registration timeline and organizational and institutional changes around processes and capabilities that really need to be in place to power good recordings.
“My rule is that no technology will last longer than three or five years,” another official said. ” It will change. And with that, you automatically enter the realm of a higher level of policies and data structures and naming conventions because you start thinking: how am I going to take what we have now and migrate it to the next tool, whatever it be?”
Additionally, agencies are racing towards two separate M-19-21 deadlines: converting legacy documents from paper to digital and ensuring that current and future business processes produce digital documents from the start.
“There probably aren’t enough resources in the world” to address each of these aspects individually, said one participant. “We’ve broadened our perspective” to establish governance, workflows and recording schedules that can apply at all levels.
“While it looks like it’s disparate projects and there’s some level to it, it’s a big Venn diagram,” another official said. “There are a lot of things you need to do for digitization and you also need to move towards new technologies. So I think it’s a mistake not to look where there are joint efforts that will address both.
“That won’t be all,” the official warned, and scope drift continues to be a concern. “I think there is some resizing around expectations that needs to happen. Just because the technology is there, Congress was never going to give us the budget to meet their expectations in terms of reproducibility of all the flotsams and jetsams that we created. We need to start having this honest conversation. Otherwise, we are doing both sides of the house a disservice.
This article was first published on FCW, a sister site of GCN.