Gaining Internal Approvals and External Consents
Federal Agencies Follow Standard Procedure for Records Schedule Approval
Federal agencies adhere to a strict process when it comes to obtaining approval for a records schedule before submitting it to the National Archives and Records Administration (NARA). This process ensures compliance with Department of Defense (DoD) and federal records management regulations, incorporating financial regulations and oversight by the General Accounting Office (GAO) and NARA.
- Preparing the Records Schedule
The first step involves the records officer developing a detailed records schedule. This schedule identifies the types of records, their retention periods, and disposition instructions.
- Obtaining Internal Clearances
The schedule is then reviewed and cleared internally within the agency. This process typically involves coordination with relevant departments or stakeholders such as legal counsel, program managers, and compliance officers to ensure the records schedule meets regulatory and operational requirements.
- Submitting for GAO Approval
Once internal clearances are secured, the records schedule is submitted to the GAO for review. GAO assesses whether the proposed schedule aligns with government-wide records management policies and financial accountability standards.
- Incorporating GAO Feedback
The records officer addresses any comments or required changes from GAO.
- Submitting the Final Schedule to NARA
After GAO’s approval, the records schedule is forwarded to NARA for final approval and inclusion in the agency’s official recordkeeping program.
It is important to note that GAO's approval is not a mandatory step for all records schedules. However, when necessary, it is required for records schedules submitted to NARA.
- Seeking Input from Agency Departments
The records officer should also ask for comments on the entire schedule from the agency's historian and the agency's legal office, especially for records series or systems that involve legal rights. Each office should receive only those parts of the schedule relating to its records.
- GAO's Role in Approval
GAO has already approved, when necessary, the retention periods of records covered by the General Records Schedule (GRS). For program records with retention periods shorter than 3 years, agencies must justify these proposed retention periods. On the other hand, GAO does not approve or disapprove proposed retention periods for program records held 3 years or longer, but recommends short retention periods.
- Requesting GAO Approval for Shorter Retention Periods
When requesting GAO approval of a retention period shorter than that found in the GRS, agencies should indicate the particular General Records Schedule and item number.
- Resolving Differences
After all comments are received, any differences should be resolved with program officials or files custodians.
- NARA's Role in Approval
NARA processes records schedules with pending GAO approval, but withholds final approval until it receives GAO’s written concurrence.
This process helps to maintain financial accountability and adherence to records management regulations, ensuring the accurate and efficient management of federal records. For more detailed procedural references, specific DoD or agency records management policies and NARA guidelines on schedule approval would provide definitive steps.
Federal agencies incorporate financial regulations in the review process of their records schedules, ensuring compliance with financial accountability standards set by the General Accounting Office (GAO).
The records schedule is then submitted to the GAO for review, where it is assessed against government-wide records management policies and financial accountability standards.
