Section 1: General Questions about GRS 6.1
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1. What is the purpose of GRS 6.1?
This schedule:
- Provides disposition authority for email records managed by those agencies who wish to adopt a role-based (Capstone) approach. This is outlined in NARA Bulletin 2013-02: Guidance on a New Approach to Managing Email Records [Capstone].
- Provides disposition authority for certain other types of electronic messages, for those agencies who wish to expand their role-based approach beyond just email. This is outlined in NARA Bulletin 2023-02: Expanding the use of Role-Based (Capstone) Records Management Approach
2. Who should I contact for more information about this schedule?
You may contact NARA’s General Records Schedules Team at GRS_Team@nara.gov with questions about this schedule.
3. How does an agency document that it is using the Capstone GRS?
To ensure proper oversight and accountability, agencies wishing to use this GRS must first get approval of the form NA-1005, Verification for Implementing GRS 6.1 from NARA. This form will document:
- Whether or not the agency wishes to also apply this GRS to other types of electronic messages, as defined by the GRS scope;
- Which items from the GRS the agency wishes to use;
- General implementation scope and background information, such as cutoff and transfer instructions for permanent records; and
- Those roles and positions that fit the 10 categories defined in item 010, Email and Other Electronic Messages of Capstone Officials.
Instructions for filling out and submitting the form are available on the form NA-1005 itself. Please also see Section 10: Questions about Completing the form NA-1005 for additional information.
4. Do all agencies have to follow this GRS?
No. Agencies are not required to use this GRS. However, if an agency chooses to use one or more items in this GRS, it must submit a form NA-1005 and may not deviate from the schedule’s scope. If an agency wants to deviate from the GRS, then the agency may request authority to implement a Capstone approach that differs from this GRS by submitting an agency-specific records schedule to NARA.
Reasons agencies may wish to submit an agency-specific schedule can include, but are not limited to:
- The agency can justify that it is appropriate to exclude one or more of the officials required for inclusion in item 010, Email and Other Electronic Messages of Capstone Officials;
- The agency can justify a transfer date longer than the maximum in item 010;
- The agency can justify a shorter retention for records covered by items 011 and/or 012;
- The agency wishes to apply the Capstone approach to other types of electronic messages specifically excluded from this GRS; and/or
- The agency generally wants to propose a scope that differs from that of this GRS.
We encourage agencies to discuss scheduling options with their NARA Appraisal Archivist.
5. May an agency implement portions of this GRS?
Yes. An agency has important scope and implementation decisions to make when deciding to use this GRS, and must document these on the form NA-1005 for NARA review and approval.
First, an agency must determine if they are applying the GRS only to email records, or also to the other types of electronic messages included in the scope of the GRS. This is documented in the “GRS Implementation Scope” field of the form NA-1005. If an agency is not using the GRS for other types of electronic messages, they should select “no (email only)” for this field. Those agencies that select “yes” are required to complete the “Electronic Messages” tab on the form NA-1005. Please also see Section 10: Questions about Completing the form NA-1005.
Secondly, an agency must determine which of the three items from the GRS they are using. An agency may use any or all of the items on this GRS. If applying this GRS in part (for example, only using item 010), agencies must ensure that all other records are covered by other NARA- approved disposition authorities. Agencies that are using only item 011 and / or 012 may not dispose of the records of any official listed in item 010, Email and Other Types of Electronic Messages of Capstone Officials, without authority from NARA in the form of another GRS or an agency-specific schedule. An agency must still submit form NA-1005 for approval in order to use either only the permanent item or only the temporary items of this GRS.
This flexibility supports those agencies that may want to implement Capstone in phases. Some agencies may find it practical to initially limit their overall Capstone approach to permanent email (item 010) and add management of temporary email and other types of electronic messages within their overall Capstone approach later.
6. What does this GRS mean when using the term “official”?
In context of this GRS, the term “official” includes all federal agency employees, regardless of their appointment type (such as part-time employees, student employees, term employees, temporary employees, volunteers, interns, and members of the military), who create federal records.
Officials under this GRS also include contractors that create federal records in the course of performing their contract. Agencies determine whether contractor-created and -received records meet the definition of a federal record defined in the Federal Records Act. Agencies must capture and manage contractor-created or -received federal records appropriately, as with other federal records. In situations where contractor employees are embedded in the agency and assigned agency email accounts (in contrast to situations where contractors fulfill the terms of a contract by providing a service from outside of the agency), the agency should manage those accounts in accordance with the GRS. Agencies should include records management requirements and provisions on retaining federal records in contract agreements (36 CFR 1222.32).
7. Which officials are designated as Capstone (permanent) Officials by this GRS?
Your agency must document its Capstone officials and submit that information to NARA on the form NA-1005. This form includes detailed instructions to help you identify your agency’s officials.
Capstone officials are usually senior officials (such as those high on the organization chart) generally responsible for policy- and mission-related actions. Capstone officials vary agency by agency depending on an agency’s organization and how it carries out agency roles. Some agencies will have more Capstone officials than others.
Federal agencies utilize a variety of titles for Capstone officials. Agencies using item 010 of this schedule must identify their equivalents for those positions described within each category provided in the item’s description (when applicable).
Cabinet-level agencies implementing a Capstone approach that includes their components or operatives must apply the definition of official to each component separately. For this purpose, the agency should treat each component or operative as though it were a separate agency.
A general rule of thumb for identifying officials is that every record group (RG) the agency includes in the Capstone implementation should have its own group of Capstone officials.
If you need additional help to identify your agency’s Capstone officials, please also see Section 10: Questions about Completing the form NA-1005. You may also contact your NARA Appraisal Archivist or email the GRS_Team@nara.gov for advice.