As the deadline to meet the requirements set in Memorandum-19-21 (M-19-21) approaches, some Federal agencies are struggling to meet the remaining requirements. However, during an FCW virtual summit on Sept. 21. the National Archives and Record Administration’s (NARA) chief record officer, Laurence Brewer, said the agency is aware of these challenges and is prepared to have those conversations, but there is currently no plan for a deadline extension.

“We recognize agencies are feeling some stress because of the impact of the pandemic on these agencies working to meet the requirements on the M-19-21,” Brewer said. “COVID-19 has made some significant impacts to these efforts. Like there’s been limited access to the records centers, and [agencies] haven’t been able to transfer records on schedule. We all had plans to digitize records. But we haven’t been able to do that. So, we know that there’s been an impact on agencies being able to meet these target requirements.”

Before the pandemic, Federal agencies were making progress on going paperless to meet the December 2022 deadline set M-19-21, a joint memo put forward by NARA and the Office of Management and Budget (OMB). But when the pandemic hit, Federal agencies were forced to work from home, facing limited access to record centers and the records they needed to digitize.

However, NARA cannot independently revise the requirements in M-19-21. NARA and OMB must discuss the possibility of an extension before any decision.

“It’s going to take some discussions with OMB, but we’re prepared to have those discussions and see what we can do to introduce some flexibility into where we are as a result of all of the pain that we felt working in the pandemic,” Brewer said. But there are no plans for an extension or plans to discuss an extension at the moment, he added.

There are still four target requirements in the M-19-21 remaining. First, Federal agencies must manage all temporary records electronically or store them in commercial records storage facilities. Second, all agencies must close agency-operated records storage facilities and transfer inactive temporary records to Federal Records Centers or commercial records storage facilities. Third, NARA will no longer accept transfers of permanent or temporary records in analog format and will accept records only in electronic format and with appropriate metadata. And finally, Federal agencies will manage all permanent records in an electronic format with appropriate metadata

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Lisbeth Perez
Lisbeth Perez
Lisbeth Perez is a MeriTalk Senior Technology Reporter covering the intersection of government and technology.