Did you ever have one of those times when you are SURE that something was important, but you can’t quite seem to find anyone to pay attention? And you then appear to be one of those annoying people who can’t talk about anything else?

Well, I had a bit of that feeling after first reading the Joint OMB/NARA M-19-21 memo from June 28 re the transition of the federal government to electronic records — get it here! — hot reading — https://www.whitehouse.gov/wp-content/uploads/2019/06/M-19-21.pdf

The purpose of this short post is to find some fellow Information Governance/Information Management travelers, especially in the public sector, who also think SOMETHING significant is changed with M-19-21. 

[Warning for the meek of heart: I should point out that a search on both the AIIM and ARMA web sites for M-19-21 returns no hits, so I may very well be totally full of baloney.]

So particularly for my friends in the public sector and/or those who advise them, what are the implications of requirements like these:

  • Soon to be released new NARA metadata standards for permanent records and new digitization standards for converting paper to digital for permanent records.

  • By 2019, Federal agencies will manage all permanent electronic records in an electronic format. 

  • By 2022, Federal agencies will manage all permanent records in an electronic format and with appropriate metadata. 

  • By 2022, Federal agencies will manage all temporary records in an electronic format or store them in commercial records storage facilities. 

  • By 2023, all agencies must close agency-operated records storage facilities and transfer inactive, temporary records to Federal Records Centers or commercial records storage facilities.

I recently had the chance to speak with NARA’s Markus Most at a very interesting Harvey Spencer event and Lisa Haralampus at a Federal Computer Week Conference. My takeaway from the conversations is the following, noting in advance that any errors in transmission or interpretation are mine, not theirs):

  1. The previous Obama Administration directive (M-12-18) basically provided GUIDANCE (“You should”), while the new M-19-21 (which supercedes M-12-18) provides DIRECTION (“You must”) when it comes to the shift from paper to digital records.

  2. The new digitization standard for permanent records will be significant, because it will require that document and process auditability be verifiable at a level that many will find difficult to achieve, especially at scale.

  3. The shift generated by M-19-21 is significant, because the 137 independent executive agencies and 268 units in the Cabinet WILL NEED TO CHANGE THEIR BEHAVIOR IN SOME WAY.

  4. Nobody has any money specifically designated right now to achieve all this, so the funds will need to come from somewhere and likely repurposed from somewhere.

  5. All of this is ultimately significant because: a) the federal government is SO massive; and b) the new set of requirements will ultimately flow down to state and local governments.

What do you think? Is M-19-21 an inflection point, or am I making much ado about nothing?