In this blog post, we explore the recommendations of a senior panel of end users convened to review the findings in the QAI/DocPoint report. Here are their recommendations with records to M-19-21 and M365 governance – in their own words.

1. Flexibility. My best answer to the migration challenge into M365 is – “It depends.” A cost benefit analysis must be done, because sometimes the cost and complexity may be much greater than the benefit. Does it make sense to migrate if you have a large-scale managed service that’s holding some of your information? It depends.
2. Start with the obvious. Start with shared drives. Microsoft is working towards a decent roadmap to move forward on the governance front. Start with what is utterly unmanaged – shared drives – and get information out of shared drives and into some sort of managed M365 environment. And use the system to govern it because all end users hate it when we ask them to do it.
3. Test, test, test before deploying. Fight for a development environment, so you can test everything. I set up a committee of our M365 team leads and we are diligently working through a transformation that includes file share cleanup, structured data, and all sorts of other things. M365 ended up being the driver for many of our conversations around governance. Don’t be afraid to pivot all your information governance conversations to M365, because M365 is so ubiquitous. Everybody touches M365 in some way.
4. Proceed at your own pace. One size does not fit all when it comes to G3 vs. G5. We still have G3 licenses for certain levels of the organization — the people that just need to use some of our stuff. You need to weigh the risks, benefits, the cost, and your company’s appetite for really digging into M365. It takes a lot to utilize all the functionality. It is easy to make infrastructure wide mistakes in the cloud. Plan properly, talk to others, and learn where the pitfalls are.
5. Commit to staying current. Microsoft offers a monthly roadmap review for each one of the major M365 workloads. That slide deck is crucial to understanding what is going on. If you get it, count yourself lucky. If not, ask for it. It can be up to 150 slides depending on the month, but it does annotate and describe every single change that is listed on the roadmap.
6. Think about HOW you will make decisions before you need to make them. Develop a decision matrix to help you decide what to do now and what can be put off to later. This is important because if you can decide on the matrix and the criteria before you face a decision, you will have a common frame of reference and strategy that is transparent to everyone.
7. Learn from others who have been there. Build your network within your industry and talk with them and see if they are willing to share their lessons learned.
8. Selectively use consultants. Utilize third party experts and consultants — first making sure they actually know something about M365 automated governance — to speed your journey. Make sure your advisors are committed to “teaching you to fish” rather than becoming a permanent part of your staff. Otherwise, there is no real benefit to embracing out-of-the-box solutions.
9. Get a seat at the table. Make sure you have a seat at the table during the discussions about the role and prominence of M365 – and the governance structure that goes along with it.
10. Start with processes. Look at your core processes and what the agency is doing before you bring in a new set of tools. At the end of the day, you’re trying to improve the processes in your organization and better support the people responsible for them. Look at processes and people first.
11. Think big. When M365 was first introduced, I went in and asked for the sun, the moon, and the stars. And I got one star. But I was happy when I got my one star. I’m still looking for the rest of the stars, and the sun and the moon. Ask your IT or leadership for what you need. Ask for it all and then work with the part you get.
12. Just do it. Be bold, be brave, and just get started. It is inevitable that some mistakes will be made and assembling an M365 governance strategy is built layer by layer, like a game of Tetris. It’s hard to go wrong with the out of the box stuff; just start toggling some things on. Are there tips and tricks? Absolutely. But find your courage and get started.

The post 12 Things Agencies Need to Know about M365 Governance and M-19-21 appeared first on Quality Associates Incorporated.

Even understanding the differences between G3 and G5 in the context of governance is a challenge for many organizations. If set up properly, organizations can accomplish a great deal with an G3 license and many organizations have yet to fully leverage this potential. However, to do Records Management requires a G5 license or an add-on to an G3 license.

Looking across the continuum of end users, there are a wide variety of experiences with M365, making general conclusions challenging. Some organizations have already made the decision to standardize upon the G5 platform and are now focused on adoption and integration issues. Others are still trying to make the decision whether to move from G3 to G5. And still others have not yet deployed M365 in a strategic fashion when it comes to governance, but rather in a piecemeal way to take advantage of individual components like email and the Office and Teams.

Only 21% of organizations report that they have fully optimized the automated governance, compliance, and records management capabilities of M365, and 22% report that they have not even begun.

A huge gap exists in most organizations between the reality of how extensively M365 automated governance has been adopted and perceptions among IT and business staff. This “wishful thinking” gap is fairly common on a variety of governance concerns but is particularly noteworthy with regards to M365 governance. A key challenge for IG professionals in getting funding for governance projects is to reposition governance — which is often viewed as a necessary evil among business executives — as an enabler for the objectives that senior agency executives do care about — security, user productivity, and customer value. Likewise, IG professionals need to help their IT colleagues better understand the unique challenges associated with managing unstructured information — content — at large scale.

This is the fourth in a series of posts based on a new QAI/DocPoint research study conducted by the highly respected MER Conference.

The post Most Agencies Have Not Caught up with M365 Governance Capabilities appeared first on Quality Associates Incorporated.

SharePoint was first introduced in 2001 — twenty-one years ago. The same year that SharePoint was introduced, Ray Kurzweil (of Singularity fame) noted, “The future will be far more surprising than most observers realize: few have truly internalized the implications of the fact that the rate of change itself is accelerating.”

The launch of SharePoint began a series of triennial versions and innovations over the course of two decades that seemed swift and accelerating. But in large-scale organizations, things moved a bit more deliberately. Most surveys taken in the year after one of those triennial SharePoint introductions found a bell curve of users — 10% on the newest and greatest version, and a long-tail of deployments still stuck in earlier versions. This created a vast number of unmanaged and subsequently abandoned SharePoint sites, leaving a significant gap in records management and increased organizational risk.

The shift to the cloud and M365 — dramatically accelerated by the pandemic and demands of remote work — changed everything. Deployment of M365 — fueled by Teams — exploded, often with little thought given to the governance implications created by the presence of such powerful tools in so many untrained hands.

Government information managers now have two sets of challenges: 1) reasserting control over the sprawl that occurred during the pandemic; and 2) keeping up with the pace of change on the M365 platform itself, now freed from the constraints of triennial updates. For 77% of organizations, the pace of change in the M365 cloud is a challenge, creating an additional set of challenges as all this change rolls down to unsuspecting end users.

In terms of end users, how are organizations addressing the change management challenge in M365? Even though the following items are those often found on many change management lists, they are worth reiterating in the context of M365.

1. Provide direct help and support as soon as the need arises. Through proactive action, organizations can keep isolated problems from becoming a tidal wave of concern.
2. Do not skimp on end user training, and more specifically end user training that is timely and in the context of the work that is being performed.
3. Get executives involved in the change you are trying to generate, and do not be shy about enlisting them in making the change happen.

This is the third in a series of posts based on a new QAI/DocPoint research study conducted by the highly respected MER Conference.

To get a copy of the full research paper – Click here

Post by:
John Mancini
Information Management Advisor
Former President, AIIM and President, Content Results, LLC

#NARACompliance #M-19-21

The post Meeting M-19-21 Deadlines AND Keeping up with M365 Change a Huge Challenge appeared first on Quality Associates Incorporated.

Leading edge government organizations are now not only thinking about how to better align business strategy and IT strategy, but how to extend the alignment even further into information governance, and more specifically M365 governance. The explosion of remote work necessitated by the pandemic accelerated this journey. Organizations suddenly woke up to the imperative of automating how they govern information, regardless of where users are located or where content is created.

During the pandemic, M365 capabilities – and especially Microsoft Teams – were deployed rapidly and without a lot of planning, out of the sheer necessity of getting “something” in place. The good news in all of this is that the pandemic finally woke up many senior executives to the need to manage their information more strategically.

Comments by survey participants reflect the transition point with regards to M365 facing many agencies:

• “The adoption of remote work for almost all employees made the company realize how important information/process management is.”
• I’ve seen tools that I requested for years be implemented in the past two, where previously it had been viewed as an unnecessary expense.”
• “Senior executives always had Information Governance initiatives floating on the periphery of their concerns, COVID slapped them in the face with it.”
• “C-level executives are interested in Teams but not so much in governance.”
• “Working remotely made us all dependent on being able to easily find information.”
• “Senior executives continue to ignore the problems and are determined to continue business as dysfunctionally ‘normal’ as it was before COVID.”

As a result of the pandemic, organizations have begun to think more strategically about information and records governance and the role of M365 in their overall IT strategy. Large organizations (over 1,000 employees) are in a better position post-pandemic to truly understand the key drivers for governance: regulatory compliance, privacy, security, cost, and process transformation. The opportunity now is to translate this increased awareness into actionable plans, which in most cases means using the levers that senior executives care about as a backdoor to achieve information governance ends.

This is the third in a series of posts based on a new QAI/DocPoint research study conducted by the highly respected MER Conference.

To get a copy of the full research paper Click Here.

The post The Missing M-19-21 Link – Alignment of Agency Priorities and M365 Capabilities appeared first on Quality Associates Incorporated.

We live in a time of exploding data and information flows, which are overwhelming our ability to effectively manage — and the worst is still to come. As agencies struggle to transition to digital government, most have an Achilles’ Heel that threatens even the most well-intentioned digital transformation initiatives. That vulnerability is out-of-control information.

We are facing a tsunami of information, and it just keeps getting bigger and bigger. We are in the digital age, but there are some agencies that are still dealing with paper. Many agencies are suffocating under the weight of paper, while simultaneously trying to embrace digital transformation. And they’re not sure how to get there.

In a digital age, information is the core asset creating constituent value; information is critical to how public sector organizations deliver value to constituents and taxpayers. This was clearly demonstrated during the pandemic, when agencies suddenly realized that unless they could rapidly digitize their processes, they could no longer operate.

Developing an approach to address this vulnerability is the fundamental challenge of the digital era. On average, organizations believe the volume of incoming information will grow four-fold in just the next 2-3 years, and they are realizing that the old, manual, paper-based approaches to information management no longer work.

Basing digital governance upon concepts like file folders alone will never be sufficient. Something needs to change. Without a strategy, government organizations will slowly sink under the accumulated weight of their exponentially growing digital landfills.

But the challenge is more complicated than just more data. The problem is that as technologies have spread everywhere, the type of information that must be managed is changing as well. Some of the incoming information is still in the form of pure data, streaming off of web interactions, connected devices, and mission-critical applications. Managing this structured data is a challenge, but one with which organizations have some familiarity. Organizations need to consider how these lessons from the world of data can be applied to exploding volumes of unstructured and semi-structured information.

Managing unstructured information like email, text messages, Office application files, images, and videos, and semi-structured information like forms and invoices is still a problem for most agencies. These types of information are just different from data. They carry greater compliance and litigation risk. They are difficult to manage, search, and protect. They are unorganized and require large amounts of storage. Applying manual governance methodologies based on the file cabinet have proven a failure. The problem is a significant one — unstructured and semi-structured information represent 50-60% of the rising wave of information coming into and being created by our organizations.

The post As M-19-21 Deadlines Loom, Many Agencies Lost in a Sea of Chaos appeared first on Quality Associates Incorporated.

Two key parts of the governance and records equation for every organization at scale are: 1) how to automate governance in M365; and 2) how to move unmanaged content into a managed M365 environment. Many organizations are now wrestling with how to leverage their M365 investments and optimize the new automated governance and records management capabilities of the platform. But a key first step is getting information into M365 in the first place.

So often, executives over-simplify this task. “Just lift and shift applications and information to the cloud,” say many well-intentioned C-level executives. However, the real life complexities in large organizations require a more nuanced approach than just “lift and shift.” The mistakes organizations have made in the past in migrating to the cloud are being repeated as organizations attempt to migrate information into M365 to take advantage of the new information management capabilities of the platform.

1. Being a great whale, not a great white – In other words, large organizations are frequently defeated in well-intentioned strategies by their own scale.
2. Investing in tools, not people – Migrations are no different than any other enterprise effort; people do not willingly change, and thus change management must be baked into every project
3. Getting sucked down the short-term sinkhole – Migrations should not be undertaken solely by the need to save money or by some immediate need.
4. Treating cloud as an add-on – Migrating to the cloud needs to be viewed as a long-term strategic objective, not a short-term tactic.Source (for the data points, not the explanatory text): Four Common Mistakes When Organizations Go Cloud

Organizations at scale are complex beasts. I recently spoke with a Fortune 150 company about some of their information management challenges. Here’s a partial list of their challenges; the full list is HERE.

• Over 90% of our storage is ungoverned.
• No descriptive metadata in file shares or device drives.
• Minimal compliance with our internal policies on retention.
• Digital Landfills are everywhere [Editor’s note: The name of my first blog!].
• Little automation of retention applied to files.
• Little measuring and metrics of Enterprise Content Management (ECM) compliance.
• Confusing Business/IT model for ECM support.
• Too many Redundant, Obsolete, Trivial (ROT) files being kept for no reason.

And on and on their list of challenges goes. My point is that given this complexity, organizations looking to migrate information into M365 need to be clear about why and how they are going to pursue this task, and treat it as a strategic priority rather than a short term project.

Shelby Hiter (Datamation, Enterprise Networking Planet, and CIO Insight), describes eight key tips for enterprise data migration that are equally true in content land:

1. Develop a project plan with a clear scope and timeline.
2. Create a cross-departmental task force.
3. Evaluate what data needs to migrate.
4. Cleanse data before migration.
5. Check regulatory compliance requirements for migration.
6. Identify needed vendors, partners, and products.
7. Backup your data and develop a risk management strategy.
8. Review migration periodically with agile methodology.Source: Top 8 Data Migration Best Practices and Strategies

Of course, content migration — a subset of the broader area of data migration — carries its own special set of complexities:

• Content – especially in the world of COVID remote work — tends to multiply into multiple locations and devices.
• Content carries a unique set of challenges – frequently missing metadata, image blobs that are hard to penetrate, multiple inconsistent formats, massive file sizes — that require different approaches and tools than straight data.
• Content and documents often only have meaning in the context of other documents.
• A lot of content is still in paper form.
• Many documents tend to have multiple copies and versions, and it is often unclear which file is the right version.
• Most organizations have multiple content management platforms and repositories, and multiple application-specific repositories in which content is stored.

To illustrate some of the unique challenges associated with migrating content and documents (vs. data), consider some of the issues associated with moving file shares into a managed M365 environment. Brian Tuemmler at Infotechtion, “Even after years of migration to the cloud, the largest collection of unstructured content in the enterprise is the shared network drive. We know that it is insufficient for a wide variety of tasks and it is the single largest impediment to good Information Governance.” The challenges associated with file shares are complex:

• Shares tend to be allocated across servers and NAS devices to level workloads. All of one department’s files, therefore, can end up scattered across 100s of servers, and 1000s of shares. Finding “everything we know about xxx” can be extremely inefficient.
• No global controls between geo locations or functional areas means content is organized at the root level on different ad-hoc criteria (I.e. by function, system, event, entity, users or something else). This makes searching and classification efforts substantially less accurate.
• Security on users and groups can easily get so complex and nested that administration is fraught with complexity and open holes.
• It is a security risk just because there are so many ways to get to it, delete it, or exfiltrate it.
• It can be difficult for any one organization to keep up to date with the latest cybersecurity technologies, versions, or practices.
• It is not feasible to technically protect record immutability or legal holds preservation.
• Little protection from “Administrators” moving large clusters of information eliminating file ownership, create, and accessed date details. Often, 40% of file share content is “owned” by administrators.
• It is not easy to meet data privacy regulations requiring information about people to be produced or deleted as per privacy regulations like GDPR.
• No logical place to put event-based retention trigger details. How do you know what files belong to the people who recently left the organization? The content itself doesn’t say.–Source: The Problems of Network Shared Drives

So moving forward, here are 10 recommendations from QAI/DocPoint you need to consider as you migrate content into a managed M365 environment:

1. Plan the upgrade approach for your installation and servers.
2. Redesign and implement security management and infrastructure needs.
3. Prioritize the applications, databases, and content to migrate.
4. Manipulate and add associated metadata.
5. Adopt all post-upgrade best practices.
6. Leverage specific features for portals and sites relevant to your new M365 environment.
7. Analyze and reconfigure workflows to leverage new features and efficiencies in modern workflow applications.
8. Analyze functionality of your current 3rd party apps on new platforms.
9. Create functionally rich systems by using tools, methodologies and templates that will meet existing and future business demands.
10. Add business value through simplifying complexities, enhancing performance and quickly migrating and reengineering critical business applications.

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Action Item:

Ready for a webinar with a twist? How about a webinar WITHOUT canned presentations?
QAI and DocPoint will host an “Ask Us Anything” session about migration into M365 on February 22 at 11 am.

Industry analyst John Mancini will moderate the session, which will include experts from QAI, DocPoint and AvePoint and address questions like these:

• Should I migrate content from an existing ECM system into M365? What are the factors I should consider in making this decision?
• What factors should I consider in digitizing paper documents to meet M-19-21 requirements to make sure that I can also migrate them into M365?
• How can I migrate my file shares into a managed M365 environment?
• When migrating, why can’t I just “lift and shift” and leave everything else to later?

Plus whatever is on your mind!

Join us; it’s free. Registration is HERE.

The post 10 Tips for Starting That M365 Migration Project appeared first on Quality Associates Incorporated.

There is a lot of conversation in the M-19-21 world right now about “FADGI 3 compliance.” This may seem like some sort of mystery code to the uninitiated, so let’s see if I can take some of the mystery out of the conversation.

1 – What exactly is FADGI?

In 2007, the federal government began a collaborative effort to articulate “common sustainable set of technical guidelines, methods, and practices for digitized and born digital historical, archival and cultural content.” This effort led to the creation of FADGI (Federal Agencies Digital Guidelines Initiative) standards—a four-star ranking system for digital capture image quality.

FADGI defines four quality levels of imaging, from one star to four stars. Higher star ratings relate to better and more consistent image quality, but require greater technical competence of the operators, more detailed quality processes, and increased capabilities from the imaging systems.

ONE STAR – Should only be considered informational, in that images are not of a sufficient quality to be useful for optical character recognition or other information processing techniques. One-star imaging is appropriate for applications where the intent is to provide a reference to locate the original, or the intent is textual only with no repurposing of the content.

TWO STAR – Appropriate where there is no reasonable need or expectation of achieving three or four star performance. These images will have informational value only, and may or may not be suitable for Optical Character Recognition (OCR).

THREE STAR – A very good professional image capable of serving almost all use cases. This includes being suitable for OCR as well as for reprint on the best commercially available printers.

FOUR STAR – Images created to a four-star level represent the state-of-the-art in image capture and are suitable for almost any use.

2 – Why am I suddenly seeing “FADGI 3 compliant” labeling on scanners?

In December 2020, NARA issued draft standards “proposing to amend our electronic records management regulations to add a subpart containing standards for digitizing permanent Federal records so that agencies may dispose of the original source records, where appropriate and in accordance with the Federal Records Act amendments of 2014.”
The proposed standards (currently under final review by OMB) require that permanent federal records meet quality requirements that equate to FADGI three-star aimpoints and tolerance ranges. This is why there is so much current conversation about “FADGI 3 compliant scanners.”

NARA Chief Records Officer Laurence Brewer summarized the current status of the standards at the August BRIDG meeting:

“We are still in the last stages of reviewing and adjudicating the comments to the standard, and expect that they will soon be sent over to OMB for final review. We need to wait and see what concerns OMB may have when they see our final adjudication of all the comments that we have received. We’re actively working on it, and hope that we can get this resolved and published and final as soon as possible.”

3 – What kinds of records are covered by the new standard?

There is a lot of confusion about the kinds of records impacted by the new digitization standards.

• This rulemaking covers only permanent paper and photographic records, including paper and photographs contained in mixed-media records.
• NARA previously amended 36 CFR part 1236 to add standards for digitizing temporary records, which constitute the majority of Federal records (RIN 3095-AB98, 84 FR 14265 (April 10, 2019), effective May 10, 2019).
• The standards in the proposed rulemaking apply retroactively to digitized permanent records that have not been transferred to the National Archives.

Permanent records are those approved by the Archivist of the United States as having sufficient historical or other value that warrants continuing to preserve them beyond the time agencies need the records for administrative, legal, or fiscal purposes. Agencies retain permanent records for administrative, legal, or fiscal purposes for a specific period of time. At the end of the scheduled retention period, they then transfer permanent records to the legal custody of the National Archives.

The proposed new FADGI 3 compliance standards apply only to permanent records as approved by NARA – a tiny portion of the overall percentage of federal records. Per 84 FR 14265, “While permanent records require more rigorous quality standards for archival reasons, most temporary records do not need to meet those standards. Because the needs and uses for temporary records differ vastly across the Government, it is not reasonable to set a single baseline image quality or other similar standards; different standards will serve to meet the business needs for different records.”

However – and this is a big however — given the application of FADGI 3 standards to permanent records, and the absence of overall standards for all other records, it is likely that over time, the FADGI 3 requirement will bleed down into RFPs regardless of record type.

Hence the scramble to gain FADGI 3 certification.

4 – How does a scanner get certified F-3 compliant?

Don Williams at Image Science Associates is perhaps the foremost authority on image quality specification and certification. Image Science Associates, LLC (ISA) was founded by Don Williams in 2006 after a career at Kodak interfacing with the digital image archiving industry. Much of this work was done within the AIIM standards program and actually originated with the creation of test targets to measure image quality back during the microfilm days. Since founding ISA, Don’s mission has been to educate the industry on the protocols, tools and best practices used to evaluate digital image quality.

ISA’s Golden Thread software specifies and assesses the quality of an imaging system – including consistency with FADGI 3 quality standards. The software is typically used in two ways.

1. For acceptance testing of scanners and cameras. Before signing off on an expensive and complex scanning device, customers should make sure that it is performing as expected. In this way, scanner vendors can demonstrate that their equipment meets FADGI 3 image quality standards, and agencies can make sure that the FADGI 3 standards are met in their operating operating environment.
2. For periodic image quality monitoring and audits. Any number of imaging inconsistencies can creep, unnoticed into digitizing workflows of an agency or service provider. These can range from incorrect exposure selections to inappropriate image processing choices. Meeting FADGI 3 quality standards is not just required at the point a system is initially implemented, but also must be measured over time.

5 – How difficult is it for a scanner to get F-3 certification?

Don Williams believes that FADGI 3 certification is possible for many scanners, even at large scale and high speed. “Sometimes it requires some coaching, and often we need to work with the engineering teams to make sure FADGI 3 levels of quality are achievable in specific environments and/or workflow processes. Many scanners are capable of achieving FADGI 3 quality standards — if they are configured properly. Vendors will need to demonstrate that the workflows actually meet the FADGI specifications in real life, and as time goes on.”

Finally, it is important for future planning to keep in mind that the FADGI standards apply to the integrity and quality of the overall scanning and capture process, not just the scanner. It is equally important to understand that the FADGI requirement includes ongoing monitoring of the capture process, not just a one-time hardware certification.

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This just in…Don Williams will be joining me on the seminar on Nov 16 – Find out about FADGI from the expert! – https://us02web.zoom.us/webinar/register/WN_C3iuMtrnTSysynSOXSOqXw

Don worked as a research imaging scientist for Kodak for 25 years until he left the company in 2006. His work there focused on both digital and traditional imaging practices across a number of disciplines that included reconnaissance, microfilm, consumer photography, and professional photography sectors. His passion lies in the digital image archiving community and in providing resources by which good imaging can be easily practiced and understood. In partnership with his associates, he has frequently taught and provided educational tools on digital imaging. Don has also published extensively on both technical and policy matters as they relate to digital image fidelity and metrology. He sits on international standards committees and is fully immersed and involved in the digital image archiving community, frequently contributing to the Federal Agencies Digitization Guideline Initiative and sits on the Still Image Working Group advisory board.

The post What is FADGI, and why should you care? appeared first on Quality Associates Incorporated.

In addition to the formal presentations, the meeting (and especially the Q&A) provided insights into a number of current M-19-21 topics of particular interest to federal records officers.

M-19-21 Deadlines: The elephant in the room for many federal agencies is whether the NARA/OMB deadlines in M-19-21 will be adjusted as a result of the disruptions caused by the pandemic. For those needing a quick update on those deadlines:

NARA Chief Records Officer Laurence Brewer noted, “We do understand the impact that COVID has had on all of us as we work towards these goals.” He noted that NARA “does expect to have discussions with OMB about where we are with the requirements andd targets that were established in M-19-21, but that they have not yet had those conversations at a very detailed level.” Brewer reiterated that because M-19-21 was a joint memo with OMB, NARA cannot unilaterally change the targets.

Exceptions to the M-19-21 Deadlines: There were a number of issues raised about the process for requesting exceptions to the M-19-21 deadlines, and the net-net of the comments about exceptions were: 1) every exception request is different, therefore there is no single template for exceptions; and 2) get your requests in early.

Per Laurence Brewer:

When it comes to exceptions, they are all different. They’re all very unique and represent case by case scenarios that we need to think through together….Everyone is looking for an easy path for how to submit exceptions….While there are some basic pieces of information like the scheduling authority, scope, and complexity that needs to be a part of the justification that goes along with exception requests, it’s very difficult to apply a standardized template for agencies to use when submitting these requests.

The process tied to declassifying documents and then accessioning those documents to NARA is one that is particularly challenging right now given COVID-related delays at the Federal Records Centers (more on that to follow). Per one questioner,

It takes time for a Federal Agency to pull classified hardcopy permanent records from a Federal Records Center, declassify the records, then offer the declassified records to NARA for accessioning. As OMB Memorandum M-19-21 currently stands, that process won’t work if a Federal Agency tries to accession declassified hardcopy permanent records after 31 Dec 2022 unless the Federal Agency takes the extra step to digitize the declassified hardcopy permanent records. Will there be an allowance in such cases?

The short answer is that no blanket exceptions have been made to deal with this situation, and agencies that face this challenge need to make their exception requests — and the sooner the better.

Pending NARA Standard for Digitization of Permanent Records: Past QAI posts (HERE and HERE) have discussed the core elements of the pending standard and the role that FADGI certification will play in the process. In terms of the formal timetable for release of the standard, Laurence Brewer notes,

We are still in the last stages of reviewing and adjudicating the comments to the standard, and expect that they will soon be sent over to OMB for final review. We need to wait and see what concerns OMB may have when they see our final adjudication of all the comments that we have received. We’re actively working on it, and hope that we can get this resolved and published and final as soon as possible.

COVID-related Delays at the Federal Records Centers (FRC): During the first webinar in the QAI Industry Briefs series (link HERE), Dave Simmons (GSA) and Mark Patrick (Joint Staff) raised the question of processing delays at the Federal Records Centers.

Gordon Everett (Director of the Federal Records Center Program) noted that nine of the FRC buildings are currently closed, and eight are in phase 1 of reopening COVID. “We’re not doing it at the level that we normally are in each of the centers. But there is some disposal that is being done. Transfers are going to be delayed because of resources. It is just something that we’re trying to work through.”

In response to whether the Federal Records Centers will be able to meet the deadlines in M-19-21, Gordon Everett noted, “We’re still on target for M-19-21, but It depends on when we open up. We’re still on target… Will all the records be in the door by December 31, 2022? Not likely. But obviously we will have the approvals of those that are coming in, although it may take some time to actually bring all of them in.”

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Action Item:

Industry Briefs is an exclusive series of short discussions about the M-19-21 directive, records management and digitization. Mark your calendars for the next QAI Industry Briefs webinar, focused on whether, how, and where to digitize paper records.

Date: September 14
Time: 11 am eastern

Register Here

The post Update on M-19-21 Deadlines appeared first on Quality Associates Incorporated.