Op-ed: NARA framework distorts records management

GSA has abdicated its records-management responsibilities, leaving NARA to set policies and issue rules, columnist Timothy Sprehe writes.

The National Archives and Records Administration recently issued a framework for developing records management guidelines. I see the framework as one more instance of how NARA distorts records management to the disservice of the entire federal government.

As always, NARA presents itself as being generally responsible for federal records management. That assertion is untrue, as NARA well knows.

The 1984 law that created the agency gave responsibility for federal records management to NARA and the General Services Administration. Whether by formal or informal agreement, GSA dropped out of any active role in records management after 1984, and NARA stands unchallenged in the field.

However, the agency represents only the half of records management that Congress assigned to it in 1984 — namely, documentation and preservation of records. That is the risk management side of the field: If you don’t keep good records, bad things happen. That is emphatically not the whole of records management.

The other half of the field, which was assigned to GSA, is economy and efficiency — the information management part of records management. That part deals with how agencies use records information every day in their business processes.

You find the GSA aspect still included in the Code of Federal Regulations provision that asks: What type of records management business process improvements should my agency strive to achieve? The key answer is: To give agency personnel the information needed in the right place at the right time and in a useful format.

In other words, federal records managers are responsible for feeding records information back into agency business processes and for being active in agency information management. Would you ever discover that from NARA’s records management guidance? No way.

And thanks to NARA, federal records managers are mostly unaware that they have any responsibilities in agency information management.

If NARA asserts its primacy in federal records management, the assertion should encompass the whole of the field, including GSA’s role. In the new NARA guidance, as in everything preceding it, you find not a word about the information management side of records. NARA preaches only half of the gospel, and that is dishonest.

No one fills the role of promoting the information management side of records management. No government entity advises agencies on best practices for integrating records information into their business processes. Nobody has developed guidance for how records information should contribute to efficiency and productivity in carrying out agency programs.

Sound financial management demands reliable internal controls, which depend on good financial records. Audits by inspectors general succeed only when they have good records to rely on. Yet chief financial officers, IGs and chief information officers never hear from NARA that good records management is crucial to doing their jobs and improves mission performance.

NARA argues only for the risks that occur when records are not documented and preserved. It never says that programs are more productive and efficient when a solid records management program exists.

In my judgment, records management has a low status at agencies because of NARA’s lopsided take on what it is all about. It is high time that the agency presented the whole picture.

Sprehe (jtsprehe@jtsprehe.com) is president of Sprehe Information Management Associates in Washington.

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