Frequently Asked Questions about GRS 6.2, Federal Advisory Committee Records
Updated: April 2024
DEFINITIONS
The Federal Advisory Committee Act (FACA) as amended (5 U.S.C. Appendix 2): The law outlining how agencies create and manage Federal advisory committees. Congress passed the FACA in 1972. The law ensures that advisory committees provide objective advice to the agencies they serve. It also ensures that the public can access that information. The Act formalized advisory body establishment, operation, and termination. It also created the Committee Management Secretariat to oversee compliance with the Act.
A Federal advisory committee has three defining characteristics:
- It is established by statute or reorganization
- It provides advice or recommendations to the President, any agency, or Federal Government officers
- It isn’t made up only of government employees
The legal definition includes more details and an exception for two organizations. Consult the Federal Advisory Committee Act (5 U.S.C. Appendix 2) or your agency’s General Counsel for more details.
A Presidential advisory committee advises the President. Congress or the President establish these committees. Some Presidential advisory committees are subject to the Presidential Records Act (PRA). You cannot use the GRS for Presidential records. Check with your general counsel before using the GRS for Presidential advisory committee records. For more information about records of Presidential advisory committees, see question 2 below.
A sponsoring agency or department supports a Federal advisory committee. They provide the staff, administrative, and monetary support for the Federal advisory committee.
Committee management officer (CMO): The person responsible for overseeing FACA administration in each agency. A CMO:
- establishes committees
- sets procedures
- determines goals
- monitors committee accomplishments
- assembles and maintains committee reports, records, and other papers
- carries out the FACA’s requirements related to records
- Implements recordkeeping requirements
- and any other delegated responsibilities
Designated Federal officer (DFO). The person responsible for implementing committee procedures. A DFO:
- approves or calls the meeting of the advisory committee or subcommittee
- approves the agenda (except for Presidential advisory committees)
- attends the meetings
- adjourns any meeting when he or she determines it to be in the public interest
- chairs the meeting when so directed by the agency head
GENERAL QUESTIONS
1. How do I know if a committee is a FACA committee?
Check with your agency’s General Counsel to determine if a specific committee falls under FACA. You can also check the Federal Advisory Committee Act (FACA) database. This database contains information about established FACA committees.
2. Are records of Presidential advisory committees covered by the GRS?
Generally no. The GRS covers records of Presidential advisory committees if they fall under the Federal Records Act (FRA). These committee's may fall under the Presidential Records Act (PRA) or the FRA. Check with your agency’s General Counsel to determine which act applies. If the records are Presidential, request information on disposition from NARA’s Presidential Materials Division at 202-357-5200 or presidential.materials@nara.gov.
3. Item 010 includes records related to committee hearings. What if my committee does not conduct hearings?
It is uncommon for FACA committees to have authority to hold hearings. Most committees will not have hearing-related records. Item 010 includes hearing records so that it is clear that when these records do exist they are permanent.
4. Are comments made by committee members on social media considered permanent?
If the comments reflect deliberations between committee members then they are substantive. Substantive records are permanent under GRS 6.2, item 010. For information on managing social media records, see NARA Bulletin 2014-02: Guidance on Managing Social Media Records.
5. Why are permanent audiovisual records (item 020) transferred earlier than other permanent records?
Audiovisual records are more fragile. They tend to be vulnerable to damage, loss, or inaccessibility over time. For these reasons, NARA prefers to get these records as soon as possible. Other records more likely include restricted information, such as personally identifiable information (PII). These records cannot be released until after a certain period of time. Audiovisual records are less likely to contain this restricted information.
6. Why are grant review FACA committee records (item 030) temporary?
These types of committees tend to create a lot of records that have limited information. NARA has also determined that grant applications are also not permanent records (see GRS 1.2).
7. How do I implement the instruction on item 050?
Item 050 covers a variety of records. Committees need to keep some of these records until they are superseded or obsolete. Other records have more flexibility and can be destroyed when they are no longer needed. At the very least, the records should be destroyed when the committee terminates. The disposition instruction allows for flexibility. Agencies may determine how long they need to keep these records.
8. Can my committee use other GRS to destroy its general administrative records?
Yes. GRS 6.2 does not cover general administrative records, such as procurement or payroll. These records do not document the work of the advisory committee. Committees should apply the appropriate GRS to these records. When the committee ends, transfer any of these records that have not yet met their retention period to the sponsoring agency. The sponsoring agency must then keep the records until the end of their retention period.
9. Can my committee destroy Federal Register notices announcing meetings once the meeting is over?
Yes. GRS 6.2, item 050, includes drafts and copies of Federal Register notices. The Federal Register itself is the recordkeeping copy. There is no need for agencies to keep copies or drafts of notices beyond their business use. In the case of copies of the notices, that would most likely be at the end of the meeting.
IMPLEMENTING GRS 6.2
10. We have agency-specific schedules for long-standing FACA committee records. These committees existed before creation of the GRS. Should my agency use the GRS or our agency-specific schedules?
GRS 6.2 applies to records of all FACA committees. It supersedes all existing schedules related to FACA committees, including agency-specific ones.
11. My committee is shutting down. We have administrative records covered by GRS other than GRS 6.2 that cannot be destroyed yet. What should we do with these records?
You should contact the Records Officer for your committee’s sponsoring agency. The Records Officer should be able to store and manage the records after the committee shuts down.
TRANSFERRING PERMANENT FACA COMMITTEE RECORDS
12. How are permanent FACA committee records transferred to NARA?
See NARA's Accessioning Guidance and Policy website for information on transferring records to NARA.
NARA also asks that you:
- Submit a copy of the committee charter that applies to the period in which the records were created.
- Fill out and submit the GRS 6.2 Transfer Checklist.
- Include box and folder lists in the transfer.
Consult with your sponsoring agency's Records Officer for more specific procedures. If you do not have a sponsoring agency, contact GRS_Team@nara.gov.
13. What if my agency wants to transfer permanent records earlier than 15 years?
Committees that are terminating may transfer their records upon termination. Ongoing committees seeking to transfer records early must submit a schedule to NARA. This schedule must say that you are requesting to deviate from GRS 6.2, item 010. A justification for this deviation is also required. Submit this schedule through your sponsoring agency's Records Officer.