Records Managers

Frequently Asked Questions (FAQs) About Changes to Previously Approved Schedule Items

December 1, 2010

1. Can I make changes to previously approved schedule items?

Often referred to as "pen-and-ink" changes, you can make certain changes to previously approved schedule items without submitting a new Standard Form 115, Request for Records Disposition Authority (SF 115). These modifications, described in detail below, are permissible provided the content, subject, or function of the records has not changed.

2. What changes can I make to previously approved schedule items without submitting a new SF 115?

You can make the following changes to previously approved schedule items without submitting a new SF 115 to NARA:

  • revise the wording of the item title or description without substantially altering the content, function, and subject matter of the records;
  • change the instructions for retiring records to a Federal Records Center or other inactive records storage facility for records other than permanent electronic files;
  • modify accessioning instructions for permanent records;
  • add or change pre-accessioning instructions for permanent electronic records; or
  • change the numbering or organization of file codes in agency disposition manuals.

Other types of changes to records schedule items, such as changes to reflect the conversion of previously scheduled hard copy records to an electronic format, may require the submission of a new schedule or a notification (i.e., NARA Form NA-13171) to NARA. For guidance as to whether a new schedule or notification is required, agencies should consult General Records Schedule 20, Items 3 and 3.1 (http://www.archives.gov/records-mgmt/ardor/grs20.html), and 36 CFR 1225.24 (http://www.archives.gov/about/regulations/regulations.html). Other types of changes to records schedule items, such as changes to reflect the conversion of previously scheduled hard copy records to an electronic format, may require the submission of a new schedule or a notification (i.e., NARA Form NA-13171) to NARA. For guidance as to whether a new schedule or notification is required, agencies should consult General Records Schedule 20, Items 3 and 3.1 (http://www.archives.gov/records-mgmt/grs/grs20.html), and 36 CFR 1225.24 (www.archives.gov/about/regulations/regulations.html).

3. What types of changes to item titles or descriptions are covered by this guidance?

Agencies may wish to modify the titles or descriptions of previously approved schedule items so they reflect the current records more accurately. Changes not requiring the submission of a new schedule include:

  • changing form names or numbers,
  • substituting the new name of an electronic system that has been re-named,
  • editing the wording of items to make them clearer or more concise,
  • changing the names of agency components to reflect organizational realignments,
  • adding a new series or electronic system to a previously approved big bucket item, and
  • deleting a series or electronic system from an existing big bucket item.

4. Do I need to notify NARA if I make changes to approved permanent schedule items?

Although you do not need to submit an SF 115, we recommend that you notify NARA about the following changes:

  • If changing a permanent records schedule item, we recommend that agencies inform their appraiser of the change by sending an e-mail or letter that includes the new description as well as a citation to the SF 115 and item number that covers the records.
  • If adding a new electronic system to an existing permanent big bucket schedule item, agencies must submit a notification to NARA in accordance with NARA's flexible schedule guidance (NARA Bulletin 2010-03).

5. Do I need to notify NARA if I make change to the instructions for retiring records to a Federal Records Center or other inactive records storage facility?

Agencies should not submit an SF 115 or notify NARA if the only change they wish to make is to the instructions in an approved schedule item that relate to sending records to Federal records centers, agency-operated records centers, and commercial records storage facilities. This includes adding retirement instructions, deleting retirement instructions or modifying the time of transfer to inactive storage, in the case of a schedule item that initially contained retirement instructions.

Agencies should note, however, that in the case of permanent and unscheduled records retired to a non-NARA facility, they must provide NARA with copies of the documentation concerning each transfer and notify NARA in writing of the new location whenever the records are moved to a new storage facility. This requirement is specified in 36 CFR 1232.14 (http://www.archives.gov/about/regulations/regulations.html).

6. Do I need to notify NARA if I make changes to the accessioning instructions for permanent records?

Agencies should not submit an SF 115 if the only change they wish to make is to the accessioning instructions for records that were previously approved for permanent retention. (Accessioning instructions indicate when agencies will transfer legal custody of permanent records to the National Archives.) 36 CFR 1225.26 (http://www.archives.gov/about/regulations/regulations.html), agencies must notify NARA if they propose changing accessioning instructions. Agencies should contact their appraiser by e-mail or letter and provide the relevant SF 115 and item number citation along with the current and revised accessioning instructions. Appraisers will coordinate such proposals with the relevant NARA custodial unit(s) and inform the agency by e-mail or letter as to whether the change is acceptable to NARA.

7. Do I need to notify NARA if I make changes to pre-accessioning instructions for permanent electronic records?

Agencies should not submit an SF 115 if the only change they wish to make is to the pre-accessioning instructions for permanent electronic records. This includes:

  • adding pre-accessioning instructions to an electronic records schedule item that did not provide for pre-accessioning when it was approved,
  • modifying existing pre-accessioning instructions to increase or decrease the time at which records are pre-accessioned, or
  • removing instructions for pre-accessioning that were included in the item when it was approved.

However, agencies proposing to add or modify pre-accessioning instructions must notify NARA of the proposed changes. In the case of digital audiovisual or cartographic records, agencies should inform NARA's Special Media Archives Services Division (NWCS) by contacting Ken Heger either by e-mail at Kenneth.Heger@nara.gov or by letter to the Division at 8601 Adelphi Road, College Park, MD 20740-6002. Proposals to change pre-accessioning instruction for all other electronic records should be sent to NARA's Electronic and Special Media Records Services Division (NWME), either by e-mail at cer@nara.gov or by letter to the Division at 8601 Adelphi Road, College Park, MD 20740-6002. Such communications should include the item title and the relevant SF 115 and item numbers. NARA will review the proposal and let the agency know whether it is acceptable.

Additional information concerning pre-accessioning, including the criteria describing when it is appropriate, can be found in NARA Bulletin 2009-03 (http://www.archives.gov/records-mgmt/bulletins/2009/2009-03.htm).

8. Do I need to notify NARA if I make changes in the numbering or organization of agency disposition manuals?

Agencies should not submit an SF 115 when making changes to the organization or numbering of agency file manuals. Rather, agencies must provide NARA with a copy of the new manual when it is published as specified in 36 CFR 1226.12. If the new manual is maintained on a publicly available web site, agencies must send, via link or file, an electronic copy of each published agency schedule to NARA at RM.Communications@nara.gov when it is posted or distributed. The submission must cite the legal authority (GRS or SF 115 and item numbers) for each schedule item and include the name, title, agency, address, and phone number of the submitter. If the comprehensive records schedule is posted on a publicly available Web site, the agency must provide the full Internet address (URL).

Agencies are also encouraged to send NARA any crosswalks linking the old and new manuals if they are maintained separately from the published manual. This will help the NARA Federal Records Center Program update its database.

9. Who should I contact for more information?

If additional information is needed, or you have any questions, please contact your agency records officer or the NARA appraiser or records management contact with whom you regularly work. Please refer to the List of NARA Contacts for Your Agency at http://www.archives.gov/records-mgmt/appraisal/.

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