Federal Records Management

FAQs About Media Neutral Schedule Items

August 4, 2010

GENERAL INFORMATION

1. What are media neutral schedule items?

Media neutral schedule items are items on a records disposition schedule (i.e., SF 115, Request for Records Disposition Authority) that are applied to the described records regardless of their medium.

2. Where are NARA's media neutral scheduling policies found?

NARA regulations:

Make all records schedule items submitted on or after December 17, 2007, media neutral, except for those items that are explicitly limited to a specific recordkeeping medium. (36 CFR 1225.12(e))
Establish policy on when a new schedule is needed for electronic versions of previously scheduled hard copy records. (36 CFR 1225.24)
- Provide notification procedures for agencies when they implement electronic recordkeeping for records covered by previously approved permanent schedule items including instances where permanent hard copy records are replaced by electronic versions. (36 CFR 1225.24(a))

General Records Schedule (GRS) 20:

Implements the media neutral policies specified in 36 CFR 1225.24 (GRS 20, Items 2A, 3, 3.1)
Provides disposition authority for hard copy records that are converted to an electronic format (GRS 20, Item 2a)

NARA Bulletin 2010-04:

Contains additional guidance concerning notifications.

WRITING MEDIA NEUTRAL SCHEDULES FOR PERMANENT RECORDS

3. How should agencies write transfer instructions for permanent schedule items that are media neutral?

To ensure their preservation, transfer instructions for permanent electronic records should provide for their legal or physical transfer to NARA within 2-3 years of creation
Physically transferring a copy of the records to NARA prior to legal transfer is called pre-accessioning
NARA Bulletin 2009-03 provides guidance concerning pre-accessioning, including when it may be appropriate and when it is not. (http://www.archives.gov/records-mgmt/bulletins/2009/2009-03.html)

4. Does NARA require the pre-accessioning of permanent electronic records?

No. Pre-accessioning is not required. However, it may be an important tool to consider when agency business needs or security considerations preclude the legal transfer of permanent electronic records within 2-3 years.

5. May an agency propose the same transfer instructions for hard copy and electronic records that are permanent

Agencies may propose the same transfer instructions that they use for hard copy records only when the agency can ensure that the records will be maintained in the agency in accordance with 36 CFR 1236 until their transfer to NARA.

6. What are some examples of acceptable transfer instructions for permanent items that are media neutral?

Agencies may choose from several options:

An agency may propose disposition instructions that call for different transfer dates depending on whether the records are hard copy or electronic:

Transfer paper records to the Washington National Records Center 5 years after cutoff. Transfer electronic records to NARA 1 year after cutoff.

An agency may propose disposition instructions that call for NARA to accession the records after a specified period of time without any reference to the recordkeeping medium:

Transfer to the National Archives 3 years after cutoff.
[Note: Agencies may retain permanent electronic records in their custody only for as long as they can maintain the records properly in accordance with 36 CFR 1236.]

If the agency wishes to propose pre-accessioning for electronic records, the disposition instructions can be written to provide for it:

Transfer paper records to the Washington National Records Center 5 years after cutoff. Transfer electronic records to NARA as a pre-accession 2 years after cutoff. Transfer to the National Archives 30 years after cutoff.

If the records are currently hard copy, and the agency is not sure when they will want to transfer them if and when they become electronic, this can be provided for in the transfer instructions:

Transfer paper records to the National Archives 30 years after cutoff. If records are converted to an electronic format, a mutually agreeable transfer date will be determined at the time the records are converted to an electronic format.

APPLYING PREVIOUSLY APPROVED SCHEDULES TO ELECTRONIC RECORDS

7. Can agencies apply previously approved schedule items when they implement electronic recordkeeping?

The following table summarizes when agencies may apply an existing schedule to electronic records and when a new schedule is required:

TYPE OF RECORD	APPLY PREVIOUSLY APPROVED SCHEDULE?	CITATIONS
Scanned images of temporary hard copy records, including both program and administrative housekeeping records (see note below for definitions)	YES, except in the case of scanned images of program records maintained on an agency web site. See FAQ 9 regarding web records.	GRS 20, Item 3(a) 36 CFR 1225.24(c)
Electronic versions of temporary administrative housekeeping records covered by the GRS or an agency schedule, including records maintained on an agency web site and electronic records drawn from multiple temporary series.	YES, except in the case of electronic versions of series specified in GRS 20, Item 3(b)(2) that are not scanned images. If electronic records are drawn from multiple series, the longest previously approved retention period applies.	GRS 20, Item 3(b)(1) 36 CFR 1225.24(d)(1)
Electronic versions of temporary program records covered by a media neutral schedule item.	YES, except in the case of temporary program records maintained on an agency web site. See FAQ 9 regarding web records.	GRS 20, Item 3(b)(4) 36 CFR 1225.24(d)(2)
Electronic records covered by previously approved permanent schedule items, including electronic records drawn from multiple permanent series.	YES, except for records maintained on an agency web site. See FAQ 9 regarding web records. 1. Electronic records must meet NARA standards for permanent records. 2. Agencies must provide notification to NARA within 90 days of when electronic recordkeeping system becomes operational. Notification is not required if the records already were electronic when the schedule was approved or are already being transferred to the National Archives as electronic records.	GRS 20, Item 3.1 36 CFR 1225.24(a)
Records covered by previously approved schedule items that explicitly exclude electronic records.	NO. A new schedule is needed.	36 CFR 1225.22(h)(2)
Electronic records that consist of program records maintained on an agency web site.	NO. A new schedule is needed.	36 CFR 1225.22(h)(3)
Electronic versions, other than scanned images, of temporary program records covered by previously approved schedule items that are not media neutral.	NO. A new schedule is needed.	36 CFR 1225.22(h)(4)

Note: The term administrative housekeeping records refers to records accumulated in connection with facilitative activities that all agencies carry out to support their missions and programs, such as personnel administration, procurement, and information security. The term program records refers to the records agencies accumulate in connection with their distinctive missions and programs.

8. Does an agency need to submit a new schedule in order to dispose of hard copy records (inputs) used to create electronic records?

No, a schedule item is not needed:

Revisions to GRS 20, Item 2a, permit agencies to destroy hard copy records used to create electronic records, so long as the electronic records contain all of the information included in the hard copy records.
This includes hard copy records created solely as inputs to an electronic system, such as data entry forms, as well as records initially created in hard copy that are converted to an electronic format.

If hard copy records were previously approved as permanent, the electronic records must also meet NARA standards for permanent electronic records AND the agency must notify NARA within 90 days of the implementation of electronic recordkeeping (for additional information concerning notifications, see NARA Bulletin 2010-04, Guidance Concerning Notifications for Previously Scheduled Permanent Records (http://www.archives.gov/records-mgmt/bulletins/).

Please note that hard copy records may not be destroyed in those relatively few instances when the value of the original documents is such that a schedule mandates the permanent retention of the original hard copy records instead of or in addition to the electronic records.

9. Can a media neutral schedule item be applied to copies of the records maintained on an agency web site?

If the schedule item explicitly includes web site copies, then it may be applied to these records. If the schedule does not do so, it may not be applied, except in the case of administrative housekeeping records.

10. Where can agencies get more information about media neutral schedules?

For additional information, please contact the National Records Management Program staff member assigned to work with your agency. See http://www.archives.gov/records-mgmt/appraisal/index.html.

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