Records Managers

Disposition of Federal Records: A Records Management Handbook



2000 Web Edition (of 1997 printed publication)

Disposition of Federal Records - Table of Contents

V.   Schedule Preparation and Clearance

V.   Schedule Preparation and Clearance

  • The Standard Form 115 (SF 115) is used to request disposition authority for all records not covered appropriately by the General Records Schedules (GRS).

  • Usually the agency initiates the SF 115, but occasionally NARA does so.

  • The SF 115 is used to schedule both recurring and nonrecurring series and systems of records.

  • Completing the SF 115 properly can minimize delays during the clearance and approval process.

  • For records proposed as permanent, NARA requires information on the arrangement and total volume of all such records, the transfer date and annual accumulation of recurring records, and any access restrictions applicable to records proposed for immediate transfer, such as restrictions on classified information.

  • Following NARA's guidelines is especially important in scheduling electronic, audiovisual, and other special records.

  • Besides adequately describing the records, regardless of media, and proposing retention periods for them, the agency should provide necessary cutoff and transfer instructions.

  • Schedules can be arranged by organization, function, or a combination of these.

  • Assembling a draft comprehensive schedule can make it easier to issue the entire schedule once the agency has cleared the schedule and obtained NARA's approval of the SF 115.

  • The records officer needs to clear the comprehensive schedule within the agency and obtain any necessary approval from NARA and GAO before issuing the disposition standards it contains.

  • Before submitting an SF 115 for approval, the records officer should consult with the NARA appraiser and understand what NARA looks for in reviewing an SF 115 and what actions it may take.

Introduction

Besides applying appropriate General Records Schedule (GRS) authorities to as many administrative records as possible, the agency needs to schedule its program records and any remaining administrative records. To do so, it must complete, clear, and submit to NARA a Standard Form 115 (SF 115), Request for Records Disposition Authority. After NARA processes and approves the SF 115, the agency is ready to issue and apply a schedule consisting of an appropriate combination of GRS and SF 115 disposition authorities.

Like using the GRS, completing an SF 115 is based on previous steps in the overall scheduling process; namely, reviewing agency functions and recordkeeping requirements and practices and inventorying and evaluating agency records. Completing an SF 115 involves recording information from the inventory and recommending appropriate cutoffs, retention periods, and other disposition instructions.

Agencies initiate most SF 115's because they have detailed information on the records and generally have physical custody of them. Occasionally, however, NARA initiates an SF 115 when doing one of the following:

  • Carrying out projects to schedule unscheduled records or reduce apparently excessive retention periods. These projects often involve agency records stored in Federal records centers.

  • Proposing for disposal records already a part of the National Archives' holdings but reappraised and determined no longer to have sufficient value for continued preservation.

If NARA initiates the SF 115, it still must obtain the agency's written concurrence before final approval. If the agency initiates the SF 115, it needs to follow carefully the guidance given in this chapter.

After the disposition instructions are drafted, it is time to organize and clear the records schedule. By this stage, the agency should have determined the schedule's arrangement. It is often helpful to assemble the draft comprehensive schedule before clearing it within the agency and obtaining any necessary approval from NARA and GAO.

The draft schedule should be based on GRS and proposed SF 115 authorities for records, as well as on the agency's own disposition standards for nonrecord materials. The GRS authorities have already been approved by NARA and, if necessary, by GAO. The proposed SF 115 authorities, however, require NARA's approval and sometimes GAO's before they can be issued and applied.


Completing an SF 115

To complete the SF 115 properly, agencies need to follow the general and specific instructions given in this chapter and on the back of the form. (See figure 5-2 for a copy of the SF 115.) They should also carry out any new or revised instructions announced in NARA bulletins or incorporated into NARA regulations.

General Instructions

An SF 115 is required for all records not scheduled by the GRS and all records scheduled by the GRS for which the agency needs a different retention period. There are various ways in which this form is used:

  • To schedule recurring records as temporary or permanent.

  • To schedule nonrecurring records as permanent. Such nonrecurring permanent records are normally excluded from the agency's published schedule.

  • To schedule nonrecurring records for disposal. Sometimes called items on a disposal list, such records are normally excluded from the agency's published schedule if they are ready for immediate disposal.

  • To convert paper records or other originals (source documents) to microform records, and then destroy the originals, if the originals are unscheduled or scheduled as permanent. No SF 115 is required if the originals to be converted to microform are already scheduled for disposal.
Figure 5-1. Uses of the Standard Form 115

Figure 5-1 emphasizes the basic uses of the SF 115.

If an agency automates its recordkeeping system, an SF 115 is required for disposition authority unless the resulting electronic records are already disposable under the GRS.

The agency should submit two copies of the SF 115 to NARA and retain one copy for its own use. Blank SF 115's may be obtained from GSA supply depots and stores, and blank SF 115A's (continuation sheets) from NARA. The SF 115 may be used either as the first page of a schedule or, in effect, as a cover sheet. When using the form as a cover sheet, the agency attaches it to a printed or processed copy of the draft schedule, arranged as it will be when incorporated into the agency's records disposition manual.

Specific Instructions

The following is a list of the numbered entries on the SF 115, along with instructions and comments. (See figure 5-2.)

  • ENTRIES 1, 2, AND 3: Under entry 1, give the name of the organization submitting the form. The organization may be an executive branch department or independent agency, a legislative branch agency, or the Administrative Office of the U.S. Courts for the judicial branch. Under entries 2 and 3, show the major and minor organizational subdivisions that create or maintain the records described on the form. If the organization is not the same one that originally accumulated the records, explain this under entry 8. If more than one subdivision maintains the records, specify the various office names under entry 8 of the form.

    If the agency's records schedule is arranged organizationally, list as the subdivisions the organizational units with custody of the records. Examples:

    Entry 1: Department of Commerce
    Entry 2: Bureau of the Census
    Entry 3: Geography Division

    Entry 1: Department of Agriculture
    Entry 2: Soil Conservation Service
    Entry 3: Technical Staff

    The schedule's coverage may not be so specific as to permit identifying under entry 3 the name of the minor organizational unit having custody of the records (e.g., Geography Division). If so, it may be possible to identify the organizational level of the offices with custody of the records (e.g., all field units or all state offices). If the current custodial unit did not originally accumulate the records, explain this under entry 8.

    If the agency's records schedule is arranged functionally, it is unnecessary to list the major and minor subdivisions under entries 2 and 3, provided that offices with custody of proposed permanent records are identified under entry 8, whenever possible.

  • ENTRIES 4 AND 5: Show the name and phone number of the person to contact about the records. This may be the records officer or the records custodian.

  • ENTRY 6: Show the agency representative's certification on the two copies submitted to NARA. Both copies must contain the signature (with at least one being original), date of signature, and title of the agency official authorized to certify that the proposed retention periods meet agency needs. After indicating the number of any schedule pages attached to the SF 115, the official must certify that the General Accounting Office's (GAO's) written concurrence, if required, is attached to the SF 115 or has been requested. One box under entry 6 must be checked. If no box is checked, NARA will return the form to the agency without action.

  • ENTRY 7: Number schedule items in sequence (e.g., 1, 2, 3, 4). Subitems, if any, may be numbered consecutively (e.g., 1a, 1b, 1c).

  • ENTRY 8: This is the heart of the SF 115 because it contains descriptions of each item (i.e., each record series or part of an information system), along with its proposed disposition. Under this entry include centered headings to indicate the office of origin if all records described on the form are not those of the same office or if they are records created by another office or agency. Describe the records clearly, including those on nonpaper media. For more guidance on describing records, refer to later sections of this chapter and to the instructions on the back of the SF 115.

  • ENTRY 9: Indicate for each item or subitem the General Records Schedule and item numbers, the previous NARA disposition job and item numbers, and the agency directive or manual and item numbers, whichever may be applicable. Leave entry 9 blank only if the records are being scheduled for the first time. If continuation sheets are used, provide the required citations in a format acceptable to NARA.

  • ENTRY 10: Leave this entry blank. It is for NARA's use.

NARA uses the space in the upper right corner for registering the request and notifying the agency of final action. In the box marked "Job No.," NARA assigns a transaction number to the request. For example, in N1-217-93-1, the symbol "N1" represents NARA and an internal classification number, the number "217" the record group number, "93" the fiscal year, and "1" the first SF 115 submitted for that record group during that year. The box marked "Notification to Agency" contains a statement of approval, disapproval, or withdrawal.


Description and Added Information

Describing records properly on the SF 115 makes it easier to determine their disposition. Furnishing additional information can speed NARA's approval of the SF 115. Adequate, clear, and accurate descriptions aid in implementing an approved schedule .

Importance of Describing Records Properly

It is important to describe clearly and accurately each record series or each part of an information system listed on the SF 115. This task is much easier if the agency has properly inventoried its record holdings. (See Chapter II.) The following guidelines are useful in describing series or systems under entry 8 of the SF 115:

  • Describe and title a series or system by the subject or function to which it relates.

  • Consider using a single schedule item to cover several closely related temporary series if the records will have the same retention period. If not, then subdivide the schedule item.

  • In scheduling the records in an electronic information system, describe all input records (source documents), all information recorded on electronic media, all output records, the documentation associated with the system, and any related indexes. Propose a specific retention period for each of these.

  • Identify each potentially permanent series as a separate schedule item.

  • Elaborate on any sampling criteria and procedures for selecting files within a series for permanent retention.

  • Identify reports as statistical or narrative and indicate their frequency.

  • Describe correspondence files more precisely as "program subject," "reading," or the like.

  • Instead of form numbers alone, use "such as" before the form number or use "forms relating to." Otherwise, changing form numbers can void disposition authorizations.

  • Consider ending a long description with words such as "related records" or "equivalent forms" if appropriate, provided the preceding description is adequate.

Need for Additional Information

Besides describing each item, agency records managers should include additional information to help in the appraisal process. They should assess the value of the records, describe the functions reflected in them, indicate any duplication of content, and document the relationship between that content and information maintained elsewhere in the agency. They should also indicate if the series is a Privacy Act system of records. Above all, they need to provide on, or with, the SF 115 the following information about permanent records:

  • The initial date, arrangement, and total volume of each schedule item proposed as permanent.

  • In functional schedules, the current organizational location of each series and system.

  • The transfer date and annual accumulation of recurring records proposed as permanent.

  • Any access restrictions consistent with the Freedom of Information Act that are to be imposed by NARA on records proposed for immediate transfer. Such restrictions include security-classified information.

Finally, if nonrecurring records are proposed on an SF 115 for immediate destruction or for immediate transfer to the National Archives, it is necessary to indicate both their volume and inclusive dates, along with any applicable NARA records center accession and box numbers.

Figure 5-3. Information Needed for Permanent Records


Electronic, Audiovisual, and Other Special Records

Introduction

Special records are records maintained separately from regular paper records because their physical form or characteristics require unusual care or because they have nonstandard sizes. They include electronic, audiovisual, microform, cartographic and remote-sensing imagery, architectural and engineering, printed, and card records. Description of these records must be accurate and complete, especially for records proposed as permanent. Before submitting an SF 115 to cover such records, agencies should make sure that the records are not already scheduled appropriately by the GRS. If they are, an SF 115 is unnecessary. If not, agencies should take the steps needed to schedule the records, including describing on the SF 115 each record series or each part of an information system.

Creation, maintenance, and disposition requirements for special records are prescribed by NARA in 36 CFR 1222 through 1234. Particularly important are the requirements for the maintenance and prompt transfer to the National Archives of permanent special records. Transfer instructions are discussed later in this chapter.

Special care should be taken to schedule electronic, audiovisual, and other special records maintained for the agency by contractors. The contract should clearly state the Government's ownership of such records, and the agency must take physical possession of the records if they are needed by the Government. (See 36 CFR 1222.)

More detailed guidance is contained in the NARA publications, specifically Managing Audiovisual Records and Managing Cartographic and Architectural Records.

Electronic Records

Electronic records are records stored in a form that only a computer can process. The systems containing such records must be designed so that adequate maintenance and disposition procedures are in place from the start. Some electronic records are scheduled for disposal under authorities prescribed by the General Records Schedule. An SF 115 is required for all other electronic records, including those requiring retention periods differing from the GRS standards. Agencies should schedule these records in the context of entire information systems, along with appropriate documentation and related indexes, and provide the necessary information elements as described in Chapter III under the information system inventory heading.

In scheduling an information system, it is important to describe each of the following:

  • All input records, or source documents.

  • All information recorded on electronic media.

  • All output records.

  • The documentation associated with the system.

  • Any related indexes.

Sometimes it is necessary to describe each of these as separate items. Otherwise two or more of these may be described together under one schedule item, provided they have the same proposed retention period. The records manager should consult with the NARA appraisal archivist in considering what approach to take in scheduling a particular information system.

The records manager should work with the information system manager and the information technology manager to schedule and otherwise manage electronic records. The information system manager, also called the program manager, oversees the creation and use of records in an information system. The information technology manager, also called the ADP manager, oversees the purchase and technical operation of an information system.

The recorded information associated with many systems should be proposed as temporary. The master files and appropriate documentation and indexes associated with some systems, however, may be permanent. Although it is impossible to compile a comprehensive list, these examples suggest the variety of potentially permanent electronic records:

  • Electronic records replacing paper or microform records, such as reports and indexes, already scheduled as permanent on nonelectronic media.

  • Automated indexes to permanent records.

  • Unique and important scientific and technical data resulting from observations of natural events or phenomena or from controlled laboratory or field experiments.

  • Management data having Government-wide coverage or significance.

  • Socioeconomic data on topics such as trade, education, health, or behavior.

  • Natural resources data related to land, water, minerals, or wildlife.

  • Data documenting military or civilian operations during times of war, civil emergency, or natural disaster.

  • Political or judicial data related to such topics as elections, special investigations, or court proceedings.

  • Digital cartographic data used to map the earth's surface and atmosphere, other planets, and planetary satellites.

  • Digital architectural and engineering data used to plan and construct selected buildings or other structures, complete major public works projects, and produce significant weapons and machines.

  • National security and international relations data documenting such activities as strategic or foreign policy assessments, intelligence collection, foreign public opinion, or international negotiations.

Audiovisual Records

Audiovisual records are records in pictorial or aural form. They include still and motion pictures; graphic materials, such as posters and original art; audio and video recordings; and combinations of media, such as slide-tape productions. It is important to identify and describe separately each series of these records and to avoid combining them into one item, such as all photographs or all motion pictures. In describing audiovisual records, agencies should follow these guidelines:

  • Identify the working title of the series, and indicate the physical form of the records: Motion pictures, still pictures, posters or original art, audio recordings, video recordings, or slide-tape productions.

  • Specify the kind of copy. For motion pictures, indicate black-and-white or color, sound or silent, the millimeter size, edited or unedited, and whether the copies are original negatives, master positives, with separate sound tracks, and/or projection prints. For still photographs, indicate black-and-white or color, the size and type of negatives (glass, nitrate, or acetate), and the availability of duplicate negatives, transparencies, or paper prints. For audio and video recordings, indicate disks (vinyl, compact disk, or laser) or tapes, the type of tape (reel-to-reel or cassette), and the availability of original, master, or use copies.

  • Describe the subject content, arrangement, and uses of the records.

  • Show the volume by giving both the cubic footage and an item count, including the number of reels for motion picture films, the number of negatives and positives for still photographs, and the number of disks or tapes for audio and video recordings.

  • For potentially permanent series, specify the physical location of all copies and give the inclusive dates.

  • Identify all related records, especially production files and finding aids. Production files include scripts, contracts and releases. Finding aids include indexes, catalogs, shelf lists, log books, caption sheets, and shotlists.

Microform Records

Microform records are records on any form containing greatly reduced images, normally on microfilm. If an agency plans to convert to microfilm paper records or other originals that are unscheduled or scheduled as permanent, it must submit an SF 115 requesting authority to destroy the originals (source documents). In some instances NARA may not approve the destruction of the original records because of their intrinsic value or because of special access problems or other considerations.

In requesting authority to destroy the originals, the agency must certify on the SF 115 that the microfilming will meet the standards set forth in 36 CFR 1230. That regulation also contains standards for storing and inspecting such microform records and taking proper steps for their use and disposition. Care should be taken to schedule related indexes along with the microform records, and to ensure their transfer to the National Archives if they are approved for permanent retention.

If NARA has already approved the originals for destruction, an SF 115 is not required to convert the records to microform. Agencies are authorized to apply the approved retention period for such temporary records to the microform. They may also destroy these disposable originals immediately after verifying the microform for quality and completeness, unless the originals are still required for legal purposes. NARA's regulations (36 CFR 1230) cover both temporary and permanent microform records.

Cartographic, Remote-Sensing Imagery, and Related Records

Cartographic records are graphic representations drawn to scale of selected features of the earth's surface and atmosphere and of other planets and planetary satellites. They include maps, charts, photomaps, atlases, cartograms, globes, relief models, and related records, such as field survey notes, map history case files, and finding aids. Also included are digital cartographic records, such as geographic information system records, which should be managed like other electronic records.

Remote-sensing imagery records are aerial photographs and other visual images of the surface of the earth and other planets taken from airborne or spaceborne vehicles to evaluate, measure, or map the cultural and/or physical features of the landscape. They also include related indexes.

The following are some guidelines for scheduling such records on an SF 115:

  • Identify separate series of nondigital cartographic and remote-sensing imagery records and describe each series as a single schedule item. (Treat digital cartographic and remote-sensing imagery records as electronic records.)

  • Describe the subject matter, arrangement, and uses of each record series.

  • Provide any related file headings, numbers, or descriptive symbols for each series.

  • Provide titles or designations for the group of records.

  • State the origin of the records if they were not produced by the agency submitting the SF 115.

  • Show the physical form of the records, whether manuscript, annotated, or photoprocessed and whether filed, rolled, or in some other form.

  • Provide the approximate number of maps and the cubic footage.

  • Give inclusive dates.

  • Describe related indexes and other finding aids.

Architectural, Engineering, and Related Records

Architectural records are drawings and related records depicting the proposed and actual construction of stationary structures such as buildings, bridges, and monuments. Engineering records are drawings and related records depicting the planning and construction of such objects as roads, canals, ships, planes, weapons, and machines. They include design and construction drawings and related records. Also included are computer records relating to architecture or engineering, which should be managed like other electronic records.

The following are some guidelines for scheduling such records on an SF 115:

  • Identify separate series of nondigital architectural and engineering records and describe each series as a single schedule item. (Treat digital architectural and engineering records as electronic records.)

  • Provide file headings or symbols, if any.

  • Describe the subject matter, arrangement, and uses of the records.

  • State whether tracings or other types of reproductions are included.

  • Show the size of the records.

  • Describe origin of the plans, if they were not produced by the agency.

  • Provide the approximate number of architectural or engineering drawings and the cubic footage.

  • Give inclusive dates.

  • Describe related indexes and other finding aids.

Printed Records

Printed records are published materials (such as books, maps, and posters) or serial issuances (such as directives and press releases) produced by or for a particular agency, in contrast to extra copies kept in stock or distributed inside or outside that agency. Each issuing office should maintain, as potentially permanent records, a "record set" of each series of its publications. The following are guidelines for scheduling printed records on an SF 115:

  • Identify the office(s) responsible for maintaining the record sets of publications created by or for the agency.

  • List under separate schedule items the record sets of printed records published by the Government Printing Office (GPO) and those published by other sources.

  • Distinguish between the publication record sets and extra copies of the publication.

  • Describe and schedule related finding aids along with the printed records.

Card Records

Finally, in managing card records, an agency should follow these guidelines:

  • Because of their nonstandard size, maintain paper-based cards separately from regular paper records.

  • Except for their size, describe paper-based cards in the same way as regular paper records.

  • Note that paper-based cards are sometimes finding aids to related records and often have the same disposition as that of the related records.

  • Treat microform-based cards as microform records and digital cards as electronic records.


Other Considerations in Completing an SF 115

In completing an SF 115, agencies should follow the general instructions on scheduling records, especially the guidance on drafting disposition instructions. In addition, they should consider record cutoffs and transfers and the extent and limits of the schedule's coverage.

Importance of Instructions on Record Cutoffs and Transfers

SF 115's should include instructions for cutting off records and, if appropriate, for transferring them to agency holding areas or records centers for temporary storage and to the National Archives for archival preservation. Agencies may issue general instructions applicable to all their records with a particular retention period, incorporate specific instructions into each schedule item, or issue general instructions applicable except where unique cutoff and transfer instructions are included in individual schedule items. Figure 4-2 and figure 4-3 in chapter IV show examples of disposition instructions for permanent and temporary records.

  • Record cutoffs. All record series need to be cut off, or broken, before the approved disposition can be applied. In other words, the retention period normally does not start until the records have been cut off. Each agency should provide guidance to users on when to cut off records having a particular retention period. Cutoffs involve ending the old files and starting new ones at regular intervals. Unless unusual volume or other circumstances create a need for different cutoffs, the agency should consider following the guidelines given in figure 5-4. Series of nonrecord materials, such as technical reference files, do not need to be cut off but should be purged periodically of material no longer needed.

  • Transfers. Some noncurrent agency records are destroyed in current office space because their high reference activity or short retention periods make transfer unnecessary or inappropriate. But semicurrent records with longer retention periods and low reference activity are suitable for transfer to storage facilities for temporary storage. Still other records are scheduled for transfer to the National Archives for permanent retention, either directly from the agency or from a storage facility. The timing of the transfer to the National Archives should normally be within 30 years for paper records, within 5-10 years for audiovisual or microform records, and as soon as electronic records become inactive or the agency cannot meet maintenance requirements for them.

Agencies should provide instructions on all such transfers. For information on transferring records to NARA records centers, they should consult publications of the records centers and NARA regulations and bulletins. For information on transferring records to the National Archives, they need to consult NARA regulations and bulletins along with Chapter VI of this handbook.

In short, records personnel need to know when and how to transfer records out of the office. The records manual is the place to give such instructions, both in the general introduction and, if appropriate, under specific schedule items. If it is necessary for an agency to change transfer instructions contained in an approved SF115, a new SF 115 is not required. Instead the agency should address a letter of request to the appropriate NARA office.

Extent and Limits of a Schedule's Coverage

One SF 115 can cover the program records of an entire agency or only part of it, or else it can cover the records of one or more functional areas within the agency. Thus, except for records covered appropriately by the GRS, an SF115 may include all agency records, central office records only, field office records only, or one organizational unit's records only. But an agency must schedule all of its records regardless of the number of SF 115's generated.

Certain limits apply to the schedule's coverage. As already indicated, if the NARA-approved disposition authorities specify an organizational component as creator or custodian of the records, the same agency may apply such authorities to the same records after internal reorganization but only if the nature, content, and functional importance of the records remain the same.

One department or independent agency must not apply disposition authorities approved for another. If interagency reorganization reassigns functions to an existing department or agency, the gaining organization may not use the disposition authorities approved for the transferring one. Instead it needs to submit an SF 115 to NARA within 1 year of the interagency reorganization. If a new department or a new independent agency assumes functions from an existing one, it has 2 years to schedule such records and all its other records by applying the GRS to eligible records and submitting an SF 115 to NARA to cover the remainder.

Unless the schedule specifies otherwise, disposition authorities apply retroactively to all existing records described in the schedule. Such records include those previously acquired by transfer of function within or between agencies and then scheduled by the receiving organization, with the usual proviso that the nature, content, and functional importance of the record series or system must remain the same.


Arranging a Records Schedule

Before the draft schedule has been assembled and cleared, its arrangement should already have been decided on. The schedule is usually arranged primarily by organization or function.

Organizational Arrangement

This is a hierarchical listing arranged by name of organizational unit (by each bureau or other major unit and thereunder by its subordinate units). It shows as separate items the record series and systems maintained by each major and subordinate unit. To prevent confusion, agencies need to update schedules promptly after internal reorganization either by amending them when the changes do not affect the nature, content, and functional importance of the records or by submitting an SF 115 when they do. (See figure 5-5.)

Functional Arrangement

A functional schedule combines series or systems serving the same purpose. Records described in the schedule items are covered regardless of where they are created and maintained. For example, many of the General Records Schedules are arranged by function. A functional approach may be suitable for a number of offices performing the same work. For permanent records, however, the organizational location should be given in the schedule for all permanent records series and systems. (See figure 5-6.)

Other Arrangement Patterns

Some agencies may find it desirable to make their schedule's arrangement partly organizational and partly functional. In addition, the schedule's basic arrangement can be supplemented with other arrangement patterns, such as:

  • By Files Commonly Held Within an Agency. This is a listing of records and nonrecord materials commonly held by most or all offices. This approach avoids repeating the same items throughout the schedule. Such a schedule, entitled "Files Common to Most or All Offices" (see, for example, GRS 23), may include:

    • Nonrecord materials, such as extra copies of publications and reference copies of directives.

    • Certain temporary program records, such as general correspondence files and case files documenting program functions.

    • Office administrative files, which relate to the internal housekeeping activities of an office, such as staffing, supplies, and space, rather than the functions for which the office exists.

  • By Coordination With the Filing System. The agency may combine its comprehensive schedule with its files manual to make a single document. Retention periods are prescribed for each entry, whether it is subject-numeric, numeric only, or otherwise. A disposition-filing system arrangement requires that:

    • Case files are clearly identified and scheduled. Most agency records are case files.

    • All offices use the prescribed filing system. Those not using the system will find application of the schedule difficult, if not impossible.

    • Identical retention periods apply to small groups of records whenever possible. Otherwise, the disposition process can become too costly.

For example, in the Modern Army Recordkeeping System (MARKS), the disposition plan determines the filing system. Folders or other file units are identified by the schedule's "file numbers," which correspond to the Army's system of regulations. They are then arranged in the same order as the schedule items. (See figure 5-7.)


Assembling a Draft Records Schedule

After the schedule's arrangement has been determined but before the SF 115 is cleared and approved, it is often useful to combine into one draft document the components of the agency's proposed comprehensive records schedule or of the schedule being prepared for records relating to a particular function or organizational unit. These components are:

  • The records disposition authorities proposed in the SF 115, along with any SF 115 authorities approved earlier that require no substantive change in their descriptions and no change in their retention periods. One-time authorities are normally excluded from this draft document and later from the published version of the agency's schedule. To these disposition authorities it is usually necessary to add cutoff instructions and, if appropriate, transfer instructions.

  • The applicable records disposition authorities already approved in the GRS, especially if they are to be dispersed item by item throughout the schedule. For GRS items, it is usually necessary to add specific retention periods, cutoff instructions and, if appropriate, instructions for transfer to an agency storage area or a records center.

  • The disposition instructions proposed for the agency's nonrecord materials.

Assembling this draft document will make it easier to issue the schedule once the agency has cleared it and obtained NARA's approval of SF 115 items.


Obtaining Internal Clearances and GAO's Approval

After completing a draft records schedule and before submitting the SF 115 to NARA, the records officer needs to obtain clearances from agency program offices and to request GAO's approval, if necessary.

Internal Clearances

To obtain internal clearances, the records officer should send the completed draft schedule to liaisons in program offices for circulation and comment. Each office should receive only those parts of the schedule relating to its records. Program officials should be asked if:

  • All records are covered.

  • Descriptions are clear.

  • Retention periods are adequate.

  • Cutoff and transfer instructions are clear.

  • Nonrecord materials are covered.

The records officer should also ask for comments on the entire schedule from the agency's historian and, especially for records series or systems that involve legal rights, from the agency's legal office. After all comments are received, any differences should be resolved with program officials or files custodians. These internal clearances are necessary to avoid having to recall the SF 115 after it has been sent for approval or having to submit a new SF 115 to revise an inappropriate disposition.

GAO's Approval

The GAO requires that agencies obtain its written approval for SF 115 items falling under three general categories:

  • Administrative Records Proposed for Retention Periods Shorter Than Those Prescribed by GRS 2 Through GRS 10. GAO has already approved, when necessary, the retention periods of records covered by the GRS. Therefore agencies should not request GAO's approval of retention periods meeting or exceeding GRS standards. They must, however, obtain GAO's written approval when proposing retention periods shorter than those prescribed by the following:

    • GRS 2, Payrolling and Pay Administration Records
    • GRS 3, Procurement, Supply, and Grant Records
    • GRS 4, Property Disposal Records
    • GRS 5, Budget Preparation, Presentation, and Apportionment Records
    • GRS 6, Accountable Officers' Accounts Records
    • GRS 7, Expenditure Accounting Records
    • GRS 8, Stores, Plant, and Cost Accounting Records
    • GRS 9, Travel and Transportation Records
    • GRS 10, Motor Vehicle Maintenance and Operation Records

    Agencies should indicate the particular General Records Schedule and item number in requesting GAO approval of a retention period shorter than that found in the GRS.

  • All Program Records Having a Proposed Retention Period of Less Than 3 Years. GAO requires the agency to justify fully any such retention period. It neither approves nor disapproves proposed retention periods for program records held 3 years or longer, although it recommends that their retention periods be as short as practicable.

  • Records Relating to Claims or Demands by or Against the Government. Excluded from this category are any such records covered by the GRS, provided that the proposed retention period is not shorter than that prescribed by the GRS.

If GAO's approval is necessary, the agency must request it when submitting an SF 115 to NARA. While GAO's approval is pending, NARA processes the SF 115 but withholds approval until it receives GAO's written concurrence. Title 8 of the "GAO Policy and Procedures Manual for Guidance of Federal Agencies" contains further details on GAO requirements and related program information.


Submitting an SF 115 for NARA's Approval

Introduction

Agencies need to submit an SF 115 to NARA to request disposition authority for all records not scheduled by the GRS. (See figure 5-8 for an example of a completed and approved SF 115.) To avoid unnecessary delays, they should consult with NARA appraisers beforehand and understand what NARA looks for in reviewing an SF 115 and what actions it may take.

NARA's Review of the SF 115

When NARA receives an SF 115, it determines whether the SF 115 should be rejected, treated as a draft, or formally registered. If rejected, the SF 115 is returned to the agency with a letter of explanation. If NARA treats the SF115 as a draft or a formally registered job, it so notifies the agency. In the process, before appraising the records, NARA normally examines the completed SF 115 for features such as the following:

  • Contact person's name and telephone number.

  • Centered headings if the records of more than one subdivision are described.

  • Indication of any differences between the custodial agency and the agency of origin.

  • Agency representative's signature, with date, on NARA's two copies of the form. At least one copy must have an original signature.

  • Indication whether GAO concurrence is attached, has been requested, or is unnecessary.

  • Sequential numbering of all pages and schedule items.

  • Clear description of each item.

  • Clear retention period for each item.

  • Instructions, where appropriate, for cutting off and transferring records.

  • Citation, if appropriate, of the most recent GRS or SF 115 item covering the records. (The cited item will be superseded if NARA approves the new disposition request.)

  • Citation of any Privacy Act restrictions on records proposed for eventual destruction.

  • Exclusion from the SF 115 of any items unchanged from previously approved dispositions, including those items involving only editorial changes or changes in transfer instructions.

  • Written justification of any proposed exceptions to GRS disposition standards.

  • Inclusion of a review cycle in the disposition instructions for contingent temporary records to be retired to a records center.

  • Arrangement and total volume of each schedule item proposed as permanent.

  • Transfer date and annual accumulation of recurring records proposed as permanent.

  • Volume and inclusive dates and, if applicable, NARA records center accession and box numbers for all nonrecurring records proposed for immediate destruction or for immediate transfer to the National Archives.

  • Any access restrictions on nonrecurring records proposed as permanent and ready for immediate transfer to the National Archives, including restrictions on classified information.

  • Certification of compliance with 36 CFR 1230 if proposing to convert permanent or unscheduled originals to microform records and then to destroy the originals.

  • Citation, whenever applicable, of statutes or regulations governing records retention and also justification of any longer retention periods.

NARA Actions

In processing the SF 115, NARA takes one or more of the following actions:

  • Consultation and Examination. After reviewing the SF 115 for completeness, NARA appraisers may need to consult with agency officials and either see samples of the records or examine them at the agency or a records center.

  • Publication of Disposal Notices in the Federal Register. According to Federal law (44 U.S.C. 3303a(a)), NARA must publish in the Federal Register a notice of agency requests for the disposal (i.e., destruction or donation) of records. If NARA has previously approved disposal of the records covered in an agency request, a notice is published only if the proposed retention period is shorter. The publication of these notices allows interested persons to submit written comments on the records to NARA before disposal is approved or else reapproved with a shorter retention period.

  • Changes in Disposition Requests. To improve clarity and accuracy, the NARA appraiser may make changes to a completed SF 115 but only with the agency's approval. Minor changes, such as renumbering the items or correcting punctuation or typographical errors, require only the agency's oral approval. Major changes, such as modifying the description or the disposition instructions, require the agency's written approval on the SF 115.

  • Withdrawn Requests. If both the agency and NARA agree to withdraw an entire SF 115 or individuals items, NARA will mark the job or the items "withdrawn" and request a new SF 115 if the records require scheduling.

  • Disapproved Requests. If NARA disapproves an entire SF 115, it will return the SF 115 to the agency with a letter requesting appropriate revisions and submission of a new SF 115. Sometimes disagreements or revisions result in a substantial delay in approving an entire schedule. In such instances, NARA stamps the questionable items "disposition not approved" in entry 10 of the SF 115 to the agency with a letter requesting submission of a new SF 115 covering the disapproved items. Normally the agency should submit the new SF 115 within 6 months.

  • Approved Requests. If NARA approves the request, it sends the agency a copy of the approved SF 115 and, if necessary, a letter outlining any special steps to take in its implementation.


Conclusion

This chapter has explained how to complete an SF 115 covering those records whose dispositions are not prescribed, or appropriately prescribed, by the GRS. The agency also should receive NARA's approval before issuing and applying these SF 115 authorities as part of its comprehensive records schedule. This chapter has also explained how to organize and clear a records schedule and to obtain SF 115 approval from NARA and, if required, from GAO.

Once the schedule has been drafted, organized, cleared internally, and approved externally, the agency is ready to implement the schedule and take steps to keep it current. This process involves issuing the approved schedule as a directive, training employees in its use, and applying it to appropriate documentary materials. It also involves reviewing and, if necessary, updating the schedule as part of a coordinated effort to manage the records disposition program.

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