NARA Schedule Review and Approval Process

Introduction

In accordance with Federal law (44 U.S.C. Chapter 33), Federal agencies may not destroy or otherwise dispose of records without specific authorization from the Archivist of the United States. Agencies need to submit a Request for Records Disposition Authority (also known as a records schedule, or simply schedule) to the National Archives and Records Administration (NARA) for all records not scheduled by the General Records Schedule (GRS).  Once received, NARA begins the review and approval process. This is a multi-step process that includes pre-registration review, followed by a more thorough review of the schedule and records appraisal by an appraisal archivist, posting for public comment (when required), and NARA management review and approval.

Submission and Pre-Registration Review

Federal agencies submit schedules for all series of records that are not covered by the General Records Schedules to NARA via the Electronic Records Archives (ERA). Detailed instructions on creating a schedule in ERA are found in the ERA Agency User Manual.  On receipt, a schedule is assigned to an appraiser, who conducts an initial review to determine if the schedule should be registered or returned to the agency. The schedule may be returned if it does not meet standards that are specified in 36 CFR 1225 and other formal NARA guidance.

Schedules must include:

• Clear descriptions of the records at the series or system level
• Clear and readily applicable cut-off and disposition instructions
• Adequate justifications for series that deviate from the GRS
• Citations to older schedule items if a proposed schedule has disposition instructions superseding or replacing older items
• Justifications for changes in the retention period or dispositions for series already scheduled
• Instructions for series that will be retired to a records storage facility prior to final disposition
• For those series proposed for permanent retention by NARA, the inclusive dates, the arrangement, the total volume, and the annual accumulation or growth
• Certification as to whether General Accounting Office (GAO) concurrence is not required, has been obtained, or has been requested.

Schedules that conform to NARA standards or need only minor modifications (inclusion of the phone number of a point of contact, etc.), are registered, and data about the schedule is entered into an automated tracking system.

Schedules with major deficiencies (failure to justify proposed GRS deviations, etc.) are returned to the agency, with a letter explaining why they could not be registered and the revisions or corrections that are needed.

Review

NARA appraisers review schedules to determine if the proposed disposition instructions are appropriate. Schedules are reviewed to ensure that records proposed for permanent retention warrant preservation in the National Archives and that files proposed for disposal lack historical or other research value and, therefore, may eventually be destroyed. NARA also reviews the retention periods proposed for temporary records to make sure they are retained long enough to protect the legal rights of the Government and private parties.

Approximately 25%-30% of all schedule items pertain to records that (a) have never been scheduled before but clearly are temporary or (b) merely increase or lower the retention period of series that already are approved for disposal. Review of schedules that fall into this category is normally undertaken very soon after registration and is typically completed quickly.

The review of schedules covering records with legal rights implications or potentially permanent series is more time consuming than the review of simple schedules. The time required for the review of such schedules depends on such factors as the number of items in the schedule and their complexity, how many separate agency offices must be contacted or visited, how quickly agency records officers can arrange for site visits and other needed agency contacts, and the appraiser's workload.

Appraisal Meeting

An appraisal meeting is usually arranged between NARA staff and agency personnel after an schedule is formally registered in NARA for processing. There are special situations where appraisal visits are arranged to assist in the development of a schedule (e.g., to brief agency program staff on NARA’s appraisal and scheduling procedures, to discuss access or special media concerns, or to informally train a new Records Officer, etc.). The Records Officer may also consult NARA informally in other ways during the development of the schedule.

NARA staff review record schedules submitted by the agency to determine if the proposed disposition instructions are appropriate. In order to make these determinations, NARA staff will request an appraisal meeting with records, program, and sometimes IT staff in order to understand business processes and to physically review agency records. During this meeting, other questions or issues may arise, for example, about the rationale behind a proposed disposition instruction, how to technically carry out a proposed transfer instruction, or how NARA handles access requests for records it will bring into its custody. The appraisal meeting is also a time for the agency to ask questions about retention and transfer.

After NARA contacts the agency to discuss and clarify schedule issues, an appraisal meeting is usually arranged by the agency records management staff with the program staff that create and maintain the records described on the schedule. Complex appraisal and disposition issues may require several agency meetings with various program offices.

To prepare for appraisal meetings, agencies should:

• Discuss and clarify specific schedule appraisal issues with NARA staff
• Identify for each specific issue:
  • all key program officials, including regional staff (directors, managers, staff, IT, access and privacy officials, etc.) and collect contact information (names, job titles, e-mail addresses, and telephone numbers)
  • any technical information required for transfer and accession
  • any regulatory or statutory access concerns
  • all locations where the information is maintained (web pages, databases, headquarters and regional offices, data warehouses, off-site storage, etc.)
  • all formats of information (electronic database, source documentation, scanned versions, microfilm, paper, etc.)
• Arrange access to the records, in all formats, and have appropriate staff available to answer questions
• Finalize meeting dates with agency and NARA staff
• Finalize and disseminate meeting location and time, and identify any building access instructions for all invited parties
• Prepare sign-in sheets, formal or informal agenda, and related handouts (e.g., schedule) for appraisal meeting
• Arrange any follow-up meetings as needed and ensure appropriate
• staff are available to answer additional questions

Appraisal Report

After reviewing schedules and completing any necessary records inspections, appraisers prepare analytical reports that describe the records and their informational or evidential value, the organizational context within which they are generated, and whether the agency-proposed disposition instructions are appropriate. These reports, and the schedules to which they relate, are sent for review and comment to other NARA offices with specialized knowledge of the records.

Federal Register Publication and Public Comment

NARA is required by law to publish notice in the Federal Register of schedules proposing (a) the disposal of unscheduled series or (b) a reduction in the retention period of a series already approved for disposal. These notices provide the public with the opportunity to request copies of pending schedules from NARA and provide comments. Input from the public contributes to better appraisal decisions by bringing a non-governmental perspective to bear. Federal Register notices are available online.

Notices of pending schedules are published at least monthly. For each schedule, notices include such information as the name of the submitting agency and a brief description of the records. Schedules and appraisal reports are published on the Federal government’s eRulemaking portal, regulations.gov for public review. Each records schedule contains a full description of the records at the file unit level as well as their proposed disposition. The appraisal memorandum for the schedule includes information about the records. Members of the public have 45 days from date of publication to submit comments. Comments can be submitted using the commenting tools on regulations.gov or via mail.

We will consider all comments submitted by the posted deadline and consult as needed with the Federal agency seeking the disposition authority. After considering comments, we will post on regulations.gov a “Consolidated Reply” summarizing the comments, responding to them, and noting any changes we have made to the proposed records schedule. You may elect at regulations.gov to receive updates on the docket, including an alert when we post the Consolidated Reply.

For records schedules of unusual public interest, NARA may pursue additional strategies to elicit public comment, such as posting the entire schedule and appraisal report on the NARA web site, sending notices about the schedule to pertinent listservs, and soliciting comment through letters to interest groups, professional organizations, or other entities.

The Federal Register stage is generally the lengthiest portion of the schedule review process.

Revision and Approval

In most cases, NARA concurs in the disposition instructions agencies propose. However, issues may arise during the appraisal process that require revisions to a schedule prior to approval. These can stem from the appraiser's review of the schedule and/or the records they include, from input received from other NARA units which reviewed the schedule and appraisal report, or from the public.

Most often, revisions to schedules that stem from the review and Federal Register steps outlined above involve changes in the ultimate disposition of a series (from temporary to permanent or vice-versa) or modifications in the retention period for a temporary series (either a reduction or an increase). Adding schedule items for additional records discovered during visits to the agency or modifying series descriptions to reflect the actual content of the file or system are other changes that may be needed. All modifications to the schedule are implemented by working cooperatively with the agency and obtaining its concurrence.

After NARA and the agency resolve any issues arising from NARA review and Federal Register publication, the schedule is finalized and a dossier is created. The dossier is reviewed by several managers in NARA's Office of the Chief Records Officer for the U.S. Government before being sent to the Archivist of the United States for approval. After the schedule is approved, NARA maintains the original (a permanent record) and posts a copy to the web.

From receipt to final approval, it generally takes NARA approximately six months or less to process simple schedules that pertain to records that are clearly temporary and do not have legal rights implications, with roughly two months of this time period taken by the public comment process. It may take up to one year for NARA to process large and complex schedules requiring closer review or eliciting critical public comments.  To ensure the likelihood that a schedule is processed as quickly as possible, agency records officers should closely review the schedules to ensure that they are well-written, completely describing the records and the process that generate them.

Related Resources

• NARA Appraisal Policy
• Examples of Series Commonly Appraised as Permanent
• Records Schedule Quality Control Checklist
• Records Schedule Quality Control Checklist (Video)
• Virtual Appraisal Checklist

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