For those of you who aren’t familiar with M-12-18, it is the Office of Management and Budget’s and NARA’s joint memorandum providing guidance for implementation of the Presidential Directive on Managing Federal Records released in November, 2011.
Among the many requirements included in M-12-18 are two critical deadlines. The first deadline is today, December 31, 2016. This deadline requires all Federal agencies to manage all email records (permanent and temporary) in an accessible electronic format.
The second deadline is three years from today, December 31, 2019. This is a much more significant deadline as it requires agencies to manage all of their permanent records in an electronic format and will require, in many cases, a complete redesign of their enterprise records management solutions.
No one has seen the official results yet, but I suspect that many agencies will not have met today’s deadline to manage email records electronically. As I stated last week in this Federal Computer Week article, one of the barriers to meeting the email records management deadline is agency’s self-imposed requirement to comply with the Department of Defense Electronic Records Management Software Applications Design Criteria Standard, the DoD 5015.2.
The DoD 5015.2 was originally created more than 20 years ago and includes nearly 200 unique records management functional requirements that are entirely based on outdated paper records management methodologies and early 1990’s information technology. (You can read more about my concerns with the DoD 5015.2 Standard in this article I posted in May, 2013 on AIIM’s Expert Blog website.)
Complying with the myriad email records management requirements of the DoD 5015.2 is virtually impossible given the huge volumes of email generated by Federal agencies today and any agency wishing to comply with the Standard and meet the email records management requirements of M-12-18 are going to face a very difficult (and costly) challenge.
Regardless of the outcome of today’s deadline, the greater concern for Federal agencies will be the 2019 deadline to manage all permanent records electronically. Simply put, no agency is going to be able to implement an enterprise-wide records management solution that is DoD 5015.2 compliant and effectively manages permanent records from their creation to their final transfer to the National Archives.
Given that planning for the December 31, 2019 deadline should already be underway, it is long past time for every Federal agency to reconsider DoD 5015.2 compliance for their enterprise records management solutions in favor of next generation solutions that can efficiently and inexpensively meet all their information lifecycle management needs.