Strategic Directions: Resource Allocation

National Archives and Records Administration
Strategic Directions: Resource Allocation

October 2003

NOTE: This document is based on Version 1 of the OMB Business Reference Model. Version 2 is now available at http://www.feapmo.gov.

I.  INTRODUCTION/OVERVIEW

As part of its Records Management Initiative, NARA will focus its limited records management resources according to a defined set of priorities. This approach entails focusing on program areas/work processes that are core functions of the Federal Government, as opposed to agency office units, using as a starting point the Federal Enterprise Architecture Business Reference Model (BRM) of governmental activity developed by the Office of Management and Budget (OMB). The work processes chosen for priority attention will be those essential for ensuring governmental accountability, protecting legal rights, and documenting the national experience. To establish priorities, NARA will look at work processes in terms of their implications for legal rights and accountability, the quantity and value of the permanent records they generate, and the degree of risk to which records are subject. This approach is not intended to assess the importance of any Federal agency or governmental function, nor is it about denying assistance. Rather, it will assist NARA in correctly prioritizing its use of records management resources.

This handbook spells out the procedures NARA staff will employ to assess agency work processes in accordance with the criteria outlined above. NARA management will make the final decisions concerning resource allocation. A core team of 5 or 6 members from the Office of Records Services - Washington DC (NW), the Office of Regional Records Services (NR), and the Policy and Communications Staff (NPOL) will make the initial assessment of agencies and work processes. However, their work will rest in large part on input provided internally by other NARA staff who are familiar with Federal agencies and their records. This larger group of experts will be drawn from Life Cycle Management Division (NWML) work groups, NR records management staff, and NR and NW reference archivists (these experts are collectively called agency/subject area experts in the remainder of this document). Finally, external input may be received from agency records officers.

This handbook is aimed both at the core team and the larger group of project participants. Its contents, in addition to this introduction/overview, are as follows:

Part II - This section focuses on how NARA will define the work processes to be assessed, using OMB's Business Reference Model (BRM) as a starting point. The BRM assigns the work processes performed by the Government to business lines and subfunctions that cut across agency lines. Part II explains how NARA will use the BRM to develop the units of analysis to be used in resource allocation decisions.

Part III - This section explains how the core team, assisted by agency/subject experts, will evaluate agencies and work processes in terms of risk to records, implications for legal rights and accountability, and the quantity and value of the permanent records.

The handbook also includes several attachments. The most important are questionnaires to be completed by agency/subject area experts (Attachments 1 and 2) and the criteria the core team will use to evaluate agencies and work processes for risk, legal rights/accountability (Attachment 3), and permanent records. Other attachments include: a sample subfunction definition to be used as a model (Attachment 4), the form the core team will use to document its rating decisions (Attachment 5), the BRM document issued by OMB (Attachment 6), and a detailed explanation of core team and agency/subject area expert responsibilities (Attachment 7).

The high level responsibilities of the core team and agency/subject area experts are as follows:

Core Team Responsibilities

• Define subfunctions
• Identify agencies
• Coordinate approval of subfunction definitions and agencies' list
• Provide participant training
• Analyze information, assign ratings, coordinate verification
• Generate reports for management review

Agency/Subject Area Expert Responsibilities

• Attend training sessions provided by the core team as well as any meetings specific to subfunctions in his/her area of expertise that may be scheduled.
• Conduct necessary background research to complete a questionnaire for each subfunction in which one of their agencies is involved; including getting input from agency records officers as needed.
• Provide completed questionnaires electronically and in paper to the chair of the core team on or before the specified due date.
• Review core team ratings and provide comments and recommend any revisions.

II.  DEFINING SUBFUNCTIONS AND IDENTIFYING AGENCIES

Background.  In establishing priorities for the allocation of records management resources, NARA focuses on broad activities and work processes that cut across agency lines. This approach is derived from the Business Reference Model (BRM) developed by the Office of Management and Budget (OMB). This document presents a functional overview of governmental activities, describing and defining these activities in terms of their purpose and effect, independently of which agencies are involved. The portion of the BRM specifically defining business lines and subfunctions is included as Attachment 6.

Defining subfunctions.  Deciding on and defining the subfunctions to be used as the starting point in resource allocation decisions is one of the core team's most important responsibilities. This work has three broad goals. First, for each subfunction the core team proposes to use as a unit of analysis in resource allocation, the core team must provide a concise definition that clearly identifies what work processes are included (in some instances, it may also be appropriate to indicate what activities are not included). This definition will stem from the subfunction description provided in the BRM but will typically be more specific. Second, the subfunctions as defined by the core team must be mutually exclusive. That is, subfunctions must be defined in such a manner that individual activities or work processes fall under only one subfunction. Third, all major activities of the Federal Government must be accounted for.

In some instances, NARA will use the subfunctions as provided in the BRM with little or no revision. In other instances, however, this might not be appropriate. Some work processes fall under multiple subfunctions. When this is the case, the relevant subfunctions should generally be combined to avoid creating artificial distinctions (e.g., even though LEGAL INVESTIGATIONS, CRIMINAL INVESTIGATIONS, and APPREHENSION are separate subfunctions, they all stem from the same underlying work process). Likewise, in some instances, it may make sense to look at all the subfunctions that are subsumed within a specific business line (e.g., it may be appropriate to look at all Legal activities together, using the legal business line as the unit of analysis). Also, the core team should consider whether very broad, generic subfunctions, such as DATA COLLECTION or RESEARCH AND DEVELOPMENT, could best be looked at in the context of programmatic subfunctions. Thus, it may be appropriate to incorporate medical research and development (R&D) with other activities encompassed by the ILLNESS PREVENTION subfunction while R&D pertaining to space exploration might be looked at under the SPACE OPERATIONS subfunction.

All business lines and subfunctions must be carefully reviewed before a final set of subfunctions is defined. The core team will need to decide at the outset how it will carry out this work. Several options are available, including whether the development of subfunction definitions will be accomplished at meetings or through discussion of written drafts prepared by core team members prior to meetings. Whatever the process, an adequate amount of time and effort must be devoted to this phase of the larger project so that the broad goals outlined above are realized.

Identifying agencies.  Once the subfunctions have been set up and defined, the next step is identifying which agencies carry out activities associated with each one. Core team members will begin with the information developed by OMB which "maps" agencies to subfunctions. The NARA core team will supplement the OMB map with such other sources as the United States Government Organization Manual, agency annual reports, and its collective knowledge of the organization and functions of the U.S. Government generally. Core team members will also consult informally with agency/subject matter experts as needed and may also contact agency records officers for assistance.

Approval of subfunction definitions and agencies' list.  Based on the review of the BRM and of the sources noted above, the core team will prepare a consolidated list of subfunctions, as defined by the core team. This list will include, for each subfunction, the definition developed by the core team as well as a list of the relevant agencies as determined by the core team. See Attachment 4 for an example of a subfunction definition.

The core team will route the list to records management agency experts for review. In their review, staff will pay particular attention to whether the agency lists are accurate. Regional staff will indicate which subfunctions are primarily carried out in the regions, and, in such cases, which regions are of particular importance if there are variations (e.g., the generation of power is an activity that is limited to only two or three regions). Revisions suggested by staff will be incorporated if the core team deems them appropriate. Before proceeding with further work, the document will be submitted to higher level managers for review and concurrence.

III.  EVALUATING SUBFUNCTIONS

Assembling teams.  After the subfunction definitions and agency lists have been approved by higher management levels, teams will be assembled to evaluate each subfunction. These teams will include the core team as well agency/subject area experts drawn from other NARA internal units. Agency experts will serve on the teams for each subfunction in which one or more of their agencies are involved. If a subfunction involves significant regional activity, one or more regional staff with the relevant expertise will serve on the team. NARA reference specialists will also serve on teams in order to provide information concerning accessioned records. While the core team is responsible for rating subfunctions, their assessments will rest in large part on information provided by agency/subject area experts.

General orientation. After team members are identified, the core team will present a mandatory orientation and training session for all project participants. This session will provide an overview of the project as well as detailed information concerning the role of team members. A major focus will be the questionnaire agency/subject area experts will need to complete. If regional staff cannot come to College Park, they will participate via teleconferencing.

Team meetings.  Before any further work is done, the core team and the agency/subject area experts for each subfunction will hold an initial meeting to discuss the subfunction in question. The purpose of this meeting is to ensure that all team members clearly understand the nature of the subfunction and the roles/significance of the agencies involved, especially whether or not there is a lead agency warranting extra weight when ratings at the subfunction level are developed (e.g., the Department of Justice is the lead agency in connection with litigation involving Federal agencies).

At this meeting the core team and agency/subject area experts will also consider whether it would be appropriate to break down activities within the subfunction in order to arrive at more meaningful ratings. The core team will then decide if a subfunction should be divided. Finally, at the initial meetings, the core team will answer any questions the subject area experts have concerning the questionnaires and establish a deadline for their completion and submission to the core team.

Completing questionnaires.  The core team's evaluation of subfunctions will largely rest on the information provided by both the agency experts and subject area experts using the attached questionnaires (see Attachments 1 and 2). Questionnaires address such matters as risks involved with the creation, maintenance, and disposition of records; the degree to which records are needed to protect legal rights and/or ensure governmental accountability; and whether there are permanent records and if so, their volume and their significance. Completed questionnaires will be provided electronically and in paper to the chair of the core team on or before the specified due date.

Agency experts will complete a separate questionnaire for each subfunction to which their agencies are linked (e.g., if Army is involved in five subfunctions, Army experts will complete five separate questionnaires). In order to complete the agency expert questionnaires, NARA agency experts must review the following:

• the subfunction definition provided by the core team
• the project handbook
• unauthorized disposal files
• reference file of GAO and IG reports concerning records problems
• records schedules that pertain to the subfunction under review
• NARS-5 data concerning the retirement of permanent records to Federal Records Centers (FRCs)
• documentation concerning the transfer of permanent records to non-NARA records storage facilities

Agency experts may also need to consult agency organization manuals, handbooks, and other issuances as well as agency web sites. In addition, experts may need to contact agency staff to secure information.

Subject area experts will complete a separate questionnaire for each subfunction. In order to complete the subject area expert questionnaires, Reference staff must review the following:

• the subfunction definition provided by the core team
• the project handbook
• SF 258 logs or other documentation to determine date span of NARA's accessioned holdings
• statistics related to reference letters and pull slips

Rating agencies and subfunctions.  Core team members will carry out an initial review of questionnaires to determine if responses are clear and complete. If need be, additional information and/or clarification will be obtained from experts.

Using the completed questionnaires and other available information, the core team will rate agencies and subfunctions in terms of three components: risk to records, the degree to which records are needed to protect legal rights and/or ensure government accountability; and the significance and volume of the permanent records generated in connection with the subfunctions.

Ratings assigned by the core team will reflect the criteria outlined in Attachment 3. Using these criteria, a high rating for risk would be assigned if NARA knew of specific records problems or if four or more of seven risk factors were present. If records document activities that have a direct and significant impact on legal rights and/or people's well being or have an extraordinarily high public profile, a high rating would be assigned for the legal rights/accountability component. A high rating would be assigned to the permanent records component if the archival records at issue were so significant that their loss would severely diminish the historical records.

Core team assessments may differ from those proposed by experts. As noted in Attachment 3, the rating form completed by the core team will explain all such instances. Completed rating forms will be provided to all team members for review and comment. The core team will review all comments and revise forms if warranted.

Input of data into database.  The core team will enter the ratings it has assigned into an Access database. Reports and charts can be generated from this database at the subfunction or agency level. These will provide NARA management with relevant information to appropriately prioritize requests for assistance and assign resources.

ATTACHMENT 1

QUESTIONNAIRE FOR NARA AGENCY EXPERTS

BEFORE COMPLETING THIS QUESTIONNAIRE, YOU MUST REVIEW THE SUBFUNCTION DEFINITION, THE PROJECT HANDBOOK (ESPECIALLY THE RATING CRITERIA IN ATTACHMENT 3, RELEVANT SCHEDULES, UNAUTHORIZED DISPOSAL FILES, REFERENCE FILE OF GAO AND IG REPORTS), NARS-5 DATA CONCERNING THE RETIREMENT OF PERMANENT RECORDS TO FRC'S, AND FILES CONCERNING THE RETIREMENT OF PERMANENT RECORDS TO NON-NARA RECORDS STORAGE FACILITIES)

NAME OF SUBFUNCTION:

AGENCY (include name of regional agency office where pertinent)

GENERAL QUESTIONS

1.   Is this subfunction central to the mission of this agency?

2.   Which offices within this agency carry out the activities relevant to this subfunction?

3.   Describe the activities carried out by this agency that support this subfunction.

4.   Generally speaking, what kinds of records does the agency produce while performing this subfunction? You need not list all the series - just provide an overview (e.g., investigative case files, audit reports, statistical reports, annual reports, etc.)

RISK

5.   Have there been confirmed unauthorized disposals of records relating to this subfunction? If yes, provide details, including the basis of your knowledge (e.g., your own hands-on experience, an IG, GAO, or other reliable third party reports, confirmed accounts appearing in the media, your office's unauthorized disposal files, etc.).

6.   Do you have hands-on experience with the records in all media that relate to this subfunction? If yes, explain the nature and extent of your hands-on experience. If no, skip to question 8.

7.   Are there problems with the way records relating to this subfunction are managed or are these records managed well? In your response, be sure to specifically address such matters as whether or not records are disposed of in accordance with approved schedules (including schedules that call for selective retention/sampling), whether or not records can be located when needed, and whether or not records maintained in regional offices are managed properly. Also address the extent of any problems noted that put records related to this subfunction at risk? What are the problems?

8.   If you don't have direct knowledge related to the records in this subfunction, do you have hands-on experience with other areas of the agency? If yes, explain the nature and extent of your hands-on experience and identify any known problems that are producing a risk to records that would lead you to believe that there would be problems with this subfunction as well.

RISK FACTORS

If NARA has no relevant hands-on knowledge, ratings will reflect the risk factors specified below (consult the description of the risk factors contained in Attachment 3 for a fuller description). The questions relating to risk factors should be answerable even by those without direct knowledge of recordkeeping in the subfunction. However, it may be necessary for experts to consult with agency staff (records officers or program staff).

If a rating was possible based on hands-on experience, experts should still respond to the questions concerning risk factors. However, if the agency has already been rated, experts need not do additional research (e.g., consult agency staff) if they cannot answer these questions based on their knowledge or on readily available sources, such as schedules and NARS-5 data.

9.   Does this agency have more than the usual number of scheduling issues vis-à-vis records related to the subfunction? See Attachment 3 for what may constitute "more than usual issues."

10.   Are any records series in the subfunction scheduled for selective retention/sampling?

11.   Are records case filed?

12.   Are work processes well defined? That is, does the nature of the process lend itself to clearly delineated steps? Some evidence includes handbooks, procedures, directives, or other written instructions that pertain to the work processes associated with the subfunction.

13.   Are most paper records filed in a corporate file (i.e., a file maintained for the entire work unit) or are they maintained by individual staff at their own work stations? Are electronic records maintained in large centrally managed electronic recordkeeping systems or are they maintained in lower level work units (e.g., divisions, branches, etc) or on the computers of individual staff?

14.   Have permanent records been retired to FRCs or to non-NARA records centers in accordance with approved schedules?

15.   In light of your answers to questions 9 to 14, would you rate the risk to records component of this subfunction in this agency as low, medium, or high?

RIGHTS AND ACCOUNTABILITY

16.   Does this subfunction have a direct and significant impact on the rights, health, or well-being of citizens or foreign nationals (regardless of the number of people affected)? What is the nature of this impact?

17.   Are the work processes within this subfunction subject to considerable scrutiny by Congress, GAO or the media? Is this work process subject to high profile litigation?

18.   Do the work processes rise above the baseline level of government accountability? If yes, explain. Note that the baseline level of accountability is defined as the minimal level of accountability expected of all agencies (i.e., all agencies are subject to some oversight by Congress and such agencies as GAO and OMB, all agencies receive media attention at some time or another, all agencies are ultimately accountable to the public).

19.   In light of your answers to questions 16 to 18 (and given that the baseline level of government accountability expected of all agencies only warrants a low rating), would you rate the rights and accountability level of this subfunction in this agency as low, medium, or high?

PERMANENT RECORDS

20.   Roughly what percentage of the record series in this subfunction are scheduled for permanent retention?

21.   Do the permanent records for this subfunction accumulated in a five year period have a volume of 1,000 or more cubic feet?

22.   Roughly what percentage of the volume of the records accumulated in connection with this subfunction are permanent?

23.   Do you believe current approved schedules are appropriate in terms of designating records as permanent and temporary. In no, explain.

Note:  If records have not yet been scheduled, or if you believe the existing schedule is inappropriate, respond to questions 24 to 30, if possible, in terms of the volume of records that you believe warrant permanent retention.

24.   What is the level of research use of the permanent records relating to the subfunction?

25.   Are the products of research in these records (e.g., books, articles in the media, documentaries, etc.) of high public interest? If yes, explain.

26.   Are these records and/or the resulting research relevant to high profile litigation or congressional attention? If yes, explain.

27.   Does this agency play a pre-eminent or supporting role in Federal activities regarding the subfunction? Explain.

28.   Do records relate to matters where the Federal Government generally plays a pre-eminent role (e.g., foreign affairs) or do they relate to activities where non-Federal entities (state and local governments, private organizations and individuals) play the major role (e.g., the arts, education, etc.)? Explain your response.

29.   Are the permanent records of such research interest that their loss would significantly diminish the historical record or are other and/or better records available concerning the subjects with which records deal? Explain your response.

30.   What is the transfer date specified in schedules covering these records?

31.   In light of your answers to questions 24 to 30, would you rate the permanent records component of this subfunction in this agency as low, medium, or high?

ATTACHMENT 2

QUESTIONNAIRE FOR NARA SUBJECT AREA EXPERTS

BEFORE COMPLETING THIS QUESTIONNAIRE, YOU MUST REVIEW THE SUBFUNCTION DEFINITION, THE PROJECT HANDBOOK (ESPECIALLY THE RATING CRITERIA IN ATTACHMENT 3), SF 258 LOGS, FINDING AIDS, AND RELEVANT DATA CONCERNING REFERENCE USE (E.G., STATISTICS RELATED TO PULL SLIPS, REFERENCE LETTERS, ETC.). NOTE, TOO, THAT RESPONSES PROVIDED BELOW SHOULD ADDRESS ONLY RECORDS RELATING TO THE SPECIFIC SUBFUNCTION, NOT RECORDS ACCUMULATED BY THE AGENCY IN CONNECTION WITH OTHER ACTIVITIES.

NAME OF SUBFUNCTION:

AGENCY (include name of regional agency office where pertinent)

GENERAL QUESTION

1.   Does NARA hold permanent records accumulated by this agency in connection with this subfunction? If yes, complete the rest of this questionnaire. If no, stop here.

RIGHTS AND ACCOUNTABILITY

2.   Does this subfunction have a direct and significant impact on the rights, health, or well-being of citizens or foreign nationals (regardless of the number of people affected)? What is the nature of this impact?

3.   Is the work process within this subfunction subject to considerable scrutiny by Congress, GAO or the media? Is this work process subject to high profile litigation?

4.   To what extent are permanent records in NARA legal custody used by researchers (including Federal agencies) in connection with protecting rights and interests and/or ensuring government accountability (examples include use of military records by veterans seeking to establish the right to benefits, the use of records by government and private attorneys in connection with on-going litigation, the use of records by oversight agencies such as GAO)?

5.   In light of your answers to questions 2 to 4 (and given that the baseline level of government accountability expected of all agencies only warrants a low rating), would you rate the rights and accountability level of this subfunction in this agency as low, medium, or high?

PERMANENT RECORDS

6.   What is the date span of NARA's holdings? Are permanent records transferred in a timely fashion?

7.   Are you aware of any gaps in NARA's holdings?

8.   Do you agree that these records should be permanent?

9.   What is the relative level of use of these records (records are among the most frequently used, least frequently used, or somewhere in the middle)?

10.   Are the permanent records of such high research interest that their loss would significantly diminish the historical record of the United States? If so, explain. Are there other sources of information that may have more significance, including non-Federal sources?

11.   Have any publications (include articles in the media) been based on research done in these records? If yes, do you believe these publications reach a wide audience and/or have a high public profile?

12.   Is there any reason to believe that research in these records will increase or decrease in the future?

13.   In light of your answers to questions 6 through 12, would you rate the permanent records component of this subfunction in this agency as low, medium, or high?

ATTACHMENT 3

CRITERIA FOR RATING AGENCIES AND SUBFUNCTIONS

Introduction and definitions

To determine which subfunctions are of high priority for NARA, the core team will evaluate agencies and subfunctions using the following three components:

• records at risk - the degree to which records associated with the subfunction are in danger of improper disposition

• records needed to protect legal rights and/or ensure government accountability - the degree to which records associated with the subfunction have legal rights implications for either the government or private parties and/or are needed to ensure accountability and/or oversight of agency activities by either the Congress, oversight agencies (e.g., OMB or GAO), or non-governmental entities, including the media

• permanent records - whether or not records associated with the subfunction are permanent and, if there are permanent records, their volume and significance for research.

All three components have equal weight, and the core team should make no attempt to create a composite rating of the components. The core team will assess each component using the criteria as specified below. The core team will assign separate ratings of low (1), medium (3), or high (5) for each component in each subfunction. When a single rating is not possible for the entire subfunction, the core team will attempt to divide the subfunction further into two or more logical sub-units such as agency, record type, subject matter of records, or other division in an effort to obtain a rating at the sub-unit level. In discussing ratings, consensus among core team members is a goal, not a requirement. It is possible that a subfunction cannot be assigned a single rating, even when subdivided. For those cases, the core team should seek to eliminate either the "low" or "high" and assign a rating of low/medium (2) or medium/high (4).

Subfunction and component agency ratings will be documented using the rating form. Entries explaining/justifying ratings should be brief since the basic information underlying ratings will be available in the questionnaires to be completed by agency experts (see Section III of this report). The rating form should document highlights deemed significant by the core team. Such forms must, however, explain all instances where a single rating was not possible for an entire subfunction; likewise, if a subfunction was divided into logical sub-units, the basis for the division must be addressed. Also, the forms should explicitly discuss all instances where the core team rating for subfunctions and/or agencies differed from the agency agency/subject matter expert's assessment. A sample rating form is shown as Attachment 6. It is electronically available as an Excel spreadsheet.

Assessing Records at Risk

The focus in this component is not to attempt an evaluation of the relative importance of the records. The element of risk may be present regardless of whether the records have been appraised as temporary or permanent. Risk ratings will be assigned based on factors described below.

High
Known problems ¹ with records associated with the particular subfunction based on direct ² NARA experience or as a result of reliable third party accounts (e.g., GAO reports, congressional investigations, IG inspections, etc.). A high would also be appropriate if four or more of the risk factors identified below were present, unless NARA has direct knowledge that there were no problems. It is important to note that risk factors are only to be used to rate agencies where direct knowledge is not available.

Medium
NARA has no direct knowledge of a problem with records associated with the subfunction, but one to three of the risk factors were present.

Low
NARA has direct knowledge of records associated with the particular subfunction and no problems were found. A low would also be assigned if NARA has no direct knowledge of subfunction records but no risk factors were identified.

Risk Factors

If it is not possible to rate a subfunction as described above (due to lack of direct knowledge of the records of a subfunction or some other reason), the core team will take into account the following seven risk factors. To the extent possible, the factors should be assessed against records of the subfunction. Absent any knowledge (by the NARA agency agency/subject matter expert or sources within the agency that performs the subfunction) of records of the subfunction, a generalization may be made based on knowledge of other subfunctions in that agency. This should, however, be done only if the agency expert believes that it is likely that the presence of risk factors in other subfunctions also applies to the subfunction under review. Written comments should always specify whether the rating is based on agency experience.

1.   Greater than average scheduling issues exist

Based on our experience with agencies, we know that certain scheduling issues increase the danger of improper disposition. These issues include, but are not limited to, unscheduled records, failure to schedule electronic records, out-of-date schedules, and inappropriate or difficult to implement disposition instructions. Most agencies have scheduling issues to some degree. For example, most agencies have not scheduled all of their electronic records. Absent other scheduling issues, an agency which has scheduled the major electronic data systems associated with a subfunction would be regarded as having only average scheduling issues even if the electronic versions of some formerly paper-based series have not yet been scheduled. However, an agency that has no approved or pending schedules for the basic electronic (or paper) records associated with the subfunction would be regarded as having greater than average scheduling issues. Similarly, scheduling issues would be deemed greater than average if the work processes associated with the subfunction have substantially changed in the last 5 years and the agency has made no effort to modify existing schedules. If schedules do not yet reflect relatively minor organizational re-alignments, we would not view this as a greater than average scheduling issue.

2.   Records are scheduled for selective retention (sampling)

When records are scheduled for selective retention, there is a high risk that agencies will not implement the selection/sampling properly, putting historical records at risk. In studies conducted in the early 1990s, NARA found very few instances where agencies were correctly implementing selective retention as called for in schedules. In some cases, all files were treated as permanent while other agencies retired as temporary some records that clearly met the criteria for permanent retention. There is no reason to believe that agencies are doing a better job at the present time, particularly since selective retention reflects, in almost all cases, the secondary value of the records, not agency business needs.

3.   Records are not case filed

NARA's experiences over the years have demonstrated that case files are generally well maintained and disposed of properly. On the other hand, subject/policy files are often maintained poorly and are more often subject to improper disposition. It should be noted that this criterion does not normally apply to policy files maintained at high levels within an agency or bureau (e.g., the Secretary's files in a cabinet level department). Rather, this criterion applies to planning, procedural, and decision-making records accumulated at lower levels (e.g., a division or section).

4.   Hard copy records are maintained by individual office staff at their own work station, as opposed to a corporate file that serves the entire work unit and/or electronic records are either maintained on staff members' desktops or in a database or directory that serves an individual office, as opposed to inclusion in a centrally-administered electronic recordkeeping system.

Records tend to be managed better in offices that maintain a corporate file than in offices where individual staff maintain the records at their own workstations. Files maintained by individual staff are often a mix of valuable information, transitory material, and reference papers arranged under idiosyncratic filing schemes. Regardless of the NARA approved retention period, there is a risk that such records will be disposed of when the individual staff member no longer needs the files to conduct his or her daily work or when he or she moves to another position. The medium in which records are maintained has an impact on how well or poorly they are handled. Not surprisingly, paper records were, as a rule, maintained better than electronic. However, large, centrally administered electronic databases are also generally well maintained but electronic records maintained solely by individual offices or at the desktops of individual staff are less likely to be managed in accordance with NARA standards.

5.   Work processes do not have clearly delineated steps.

NARA's experiences have clearly demonstrated a link between well-defined work processes and good recordkeeping; the reverse is true for work processes that by their nature are not well defined, particularly policy development.

6.   The subfunction, as carried out within an agency or among agencies, is in a state of flux as result of a major organizational realignment or significant changes in policies and procedures.

When there has been a major re-organization or significant change in work processes, there is an increased risk that records will be maintained and/or disposed of improperly. This is particularly the case when individual components of an agency are moved to another agency, especially if accompanied by physical moves, significant staff turnover, or consolidation with organizations moved from one or more other agencies.

7.   Permanent records have not been accessioned into NARA facilities (both records centers and archives) in a timely fashion according to approved disposition instructions.

The risk of damage, loss, or inadvertent destruction is higher when historically valuable records are maintained outside of NARA's control.

Assessing rights/accountability

Rights and accountability ratings will be assigned as follows based on factors described below.

High
Records document activities that have a direct and significant³ impact on the rights, health, and/or well-being of American citizens or foreign nationals (e.g., records relating to such matters as investigations and/or arrests of citizens, disposal of hazardous wastes, eligibility for retirement benefits, and development of plans for major military operations). A high rating would not usually be assigned to records falling short of this standard even if the records are needed to ensure government accountability. However, a high rating might be appropriate if records relate to matters having an extraordinarily high public profile and, as a result, records related problems would have a major adverse impact on governmental accountability (e.g., records pertaining to anti-terrorism).

Medium
Records document activities that have an important⁴ impact on the rights, health, and/or well-being of American citizens or foreign nationals but that impact is less direct and/or less significant than is the case for records warranting a high rating (e.g., records relating to cost of living increases geared to the consumer price index, applications for Federal employment, records relating to the level of benefits [as opposed to eligibility], highway construction projects, and grant applications). A medium rating would also be appropriate for subfunctions subject to considerable oversight by Congress, GAO, and/or the media largely because they involve high dollar amounts.

Low
Records document activities that have little or no direct impact on rights, health, and/or well being (e.g., records relating to such matters as the management of parks and other recreational facilities, agency public affairs programs, and facilities management). A low rating is also appropriate if the government accountability implications for a subfunction are no higher than is the case for any other government activity. Agencies characterized by only the baseline level of government accountability (i.e., all government agencies have congressional oversight committees, all agencies are audited by certain oversight agencies, all agencies are accountable to the public) warrant a low Rights and Accountability rating absent a direct impact on legal rights.

Finally, in assigning rights and accountability ratings, the core team will consider only the impact of a subfunction, not the number of people affected. Such governmental actions as payments made to individual Indians and the use of human subjects in medical research, for example, have significant implications as well as a high public profile. Therefore, a high rating for legal rights/accountability is warranted even though the number of people impacted by these activities is relatively small.

Assessing Permanent records

Permanent records are rated in accordance with their relative importance as well as their quantity. Taking into account the significance of the records is analogous to the identification of vital records. Identifying records needed for the continuity of Government operations and/or the protection of legal rights does not diminish the importance of other records. A vital records program, rather, recognizes that priorities must be set and that certain records must be selected for priority protection (and restoration if need be). Since NARA traditionally has not differentiated among permanent records based on their relative significance, additional discussion of this concept is warranted.

All permanent records are not equal in importance. Many permanent series, especially many retained solely to document functioning of government, are of modest interest to the research community and/or the general public. Likewise, the research studies that they support are of interest only to a relatively small constituency. Other permanent series are of considerable outside interest and concern. That is, the records support research that is of considerable interest to scholars and the public at large. Given the scarcity of NARA resources, the relative importance of the permanent records associated with a subfunction must be considered in the resource allocation process.

The ratings for Permanent records will be determined in accordance with the factors described below.

High
A high rating is appropriate when the records are of such high research interest that their loss would significantly diminish the historical record. That is, records support research in which there is extremely great interest. A high rating would also be appropriate for permanent records having a high public profile (e.g., records are the subject of litigation, congressional attention, significant media coverage, etc.). In most, though probably not all, instances, records warranting a high rating pertain to functions and activities where the Federal government plays a pre-eminent role (e.g., defense, foreign relations, intelligence gathering, space exploration, protection of the environment, etc.). Consequently, most studies of such matters focus on the actions of Federal agencies and reflect research in Federal records since the information contained in Federal records is not duplicated in other sources

Medium
Records that do not meet the standard for high but are of moderate research interest or significance should be rated as medium. Such records generally pertain to functions and activities where state and local governments and/or private sector entities are at the fore, with the Federal government playing a limited role (e.g., urban development, the arts, education, popular culture). Most studies of such matters do not focus on the actions of Federal agencies nor do they rest in large part on research in Federal records.

A medium rating is also appropriate where records are voluminous, even if a medium rating is not warranted based on the level of research interest. Permanent records are deemed voluminous when the volume that is accumulated over a five-year period is 1,000 cubic feet or more (or its electronic equivalent). Permanent records would also be considered voluminous if more than 25% of the records are permanent in terms of volume or number of series

Low
Permanent records have little or no research interest and the quantity is not voluminous (i.e., less than 1,000 cubic feet (or its electronic equivalent) is accumulated over a five year period and less than 25% of the records are permanent in terms of volume or number of series.

ATTACHMENT 4

EXAMPLE OF SUBFUNCTION DEFINITION INCLUDING RELEVANT AGENCIES

WEAPONS CONTROL: WEAPONS CONTROL pertains to actions taken to ensure that actual or potential foes of the U.S. do not acquire or maintain conventional, biological, chemical, and nuclear weaponry that could be used against the U.S. and its allies. This subfunction includes such activities as monitoring treaties and other agreements that limit the maintenance of weapons as well as efforts to ensure that U.S. materiel and technology are not exported or otherwise provided to actual or potential enemies, including review and approval/disapproval of export licenses. Not included are activities associated with the negotiation of arms limitation treaties and agreements, which are covered by the TREATIES AND AGREEMENTS subfunction. Also excluded are physical/facilities security activities designed to protect stocks of U.S.-held weapons and materiel from alienation (these activities fall under the PROPERTY PROTECTION subfunction).

Agencies:

CIA
State Department
Defense Department (Defense Threat Reduction Agency)
Energy Department
Commerce Department

Note: This example is provided for illustrative purposes only and is not necessarily the definition that will be used when a comprehensive resource allocation exercise takes place.

ATTACHMENT 5

Business Line or Subfunction name

ATTACHMENT 6

The OMB Business Reference Model is being distributed in hard copy. For an electronic version, see:

http://www.feapmo.gov/resources/fea_brm_release_document_rev_1.pdf

ATTACHMENT 7

Core Team Responsibilities

1.   Define subfunctions

• For each subfunction the core team proposes to use as a unit of analysis in resource allocation, the core team must provide a concise definition that clearly identifies what work processes are included.
• The subfunctions as defined by the core team must be must be defined in such a manner that individual activities or work processes fall under only one subfunction.
• Where activities are inextricably linked, the core team may choose to use the business line rather than the subfunction as a unit of analysis. Any activity mentioned in the remainder of this document as applicable to a subfunction is also applicable to the business line when it is used as the unit of analysis.
• The core team must account for all major activities of the Federal Government.
• The core team will need to decide at the outset how it will carry out this work and how it will be allocated among its members.

2.   Identify agencies

• Identify which agencies carry out activities associated with each subfunction by applying the OMB map of agencies to subfunctions.
• Supplement the OMB map with such other sources as the United States Government Organization Manual, agency annual reports, and its collective knowledge of the organization and functions of the U.S. Government generally.
• Consult informally with agency agency/subject matter experts as needed and contact agency records officers for assistance.
• Prepare final list of agencies.

3.   Coordinate approval of subfunction definitions and agencies' list

• The core team will route the list to records management agency experts for review.
• Revisions suggested by staff will be incorporated if the core team deems them appropriate.
• Before proceeding with further work, the document will be submitted to higher level managers for review and concurrence.

4.   Provide participant training

• The core team will present a mandatory orientation and training session for all project participants.
• The core team and the agency/subject area experts for each subfunction will hold an initial meeting to discuss the subfunction in question.
• At the initial meetings, the core team will answer any questions the subject area agency/subject matter experts have concerning the questionnaires and will establish a deadline for their completion.

5.   Analyze information, assign ratings, coordinate verification

• Core team receives completed questionnaires per established deadlines.
• Based on the information gathered by the agency/subject area experts via the questionnaires, meetings with subject area experts, and core team meetings, the core team will meet to develop ratings for risk, rights and accountability, and continuing value.
• Core team ratings will be provided to all agency/subject area experts for each subfunction for review and comment. The core team will review all comments and revise ratings if warranted.

6.   Generate reports for management review

Agency/Subject Area Expert Responsibilities

1.   Attend training sessions provided by the core team as well as any meetings specific to subfunctions in his/her area of expertise that may be scheduled.

2.   Conduct necessary background research to complete a questionnaire for each subfunction in which one of their agencies is involved.

• If a subfunction has been broken down, experts may need to complete more than one questionnaire.
• In order to complete questionnaires, NWML and NR agency records management experts must conduct background research, including
  • subfunction definition and the project handbook before completing questionnaires
  • records schedules that pertain to the subfunction under review
  • NARS-5 data concerning the retirement of permanent records to FRCs
  • any available agency-specific information
  • contact with agency staff to secure information.
• Reference staff will need to review
  • subfunction definition and the project handbook before completing questionnaires
  • SF 258 logs and other documentation to determine date span of NARA's accessioned holdings
  • Statistics related to reference letters and pull slips

3.   Provide completed questionnaires electronically and in paper to the chair of the core team on or before the specified due date.

4.   Review core team ratings and provide comments and recommend any revisions.

¹  Known problems include, but are not limited to: unauthorized destruction of records, whether deliberate or inadvertent; failure to create adequate documentation; inability to locate critical information; mismanagement; waste, fraud, or abuse; and known physical danger.

²  "Direct" knowledge is defined as having hands-on experience with records related to the particular subfunction or its corresponding business line. This experience may derive from agency visits for scheduling or appraising records, a targeted assistance project, or an agency evaluation. Corresponding experience with records for other subfunctions in an agency cannot be considered direct.

³  "Significant" is defined as profound or momentous. Changes to the criminal justice laws could result in a profound change to the rights of a citizen. Conversely, promoting education, while certainly having some impact cannot be described as having significant impact. Some subfunctions could require subunit ratings. For example, research to perfect a new medical procedure could result in momentous changes to citizens' health but research on the origins of the universe, while interesting, will not likely have any impact at all.

⁴  According to the dictionary, "important" is meaning a great deal or having much significance, consequence, or value. The distinction between "significant" and "important" is subtle at best. A high public profile may influence the core team rating for other subfunctions where there is not a clear distinction. The example most often used is that getting (or not getting) a benefit is significant while the dollar amount of that benefit is important.