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than 20 years ago and includes nearly 200 unique records management functional requirements that are entirely based on outdated paper records management methodologies and early 1990’s information technology.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.
Don, we have had this discussion before. Vendors who have their product certified by JITC are demonstrating their long term commitment and understanding of RM for government, and particularly the special requirements of the DOD and Intel communities.
Readers, just do a search for “JITC RMA Register” and you will find a list of of certified products. Then ask yourself, for a 2019 solution why would I want to choose a product that is NOT on that list?
The DOD is required to use a product on that list. There is no requirement for an agency to follow any procedures specified in the 5015.2 spec, and in fact the spec is not proscriptive on how you use that system. The spec ensures that the RM solution can accomplish basic RM tasks, including records declaration, vital records processing, forensic destruction of electronic records, transfers, classified records handling and FOIA and Privacy Act request processing.
With products that have not been certified, you run the risk that the product has significant functionality gaps that will likely require the solution to be reworked in just a few years.
To say it is difficult or impossible to meet the spec for a 2016 or 2019 M-12-18 solution is simply incorrect.
Readers: Mark also commented in the Next Generation Records Management LinkedIn group. In order to avoid duplicating our discussion, I have responded to Mark’s comments there. You can find that discussion here: https://www.linkedin.com/groups/7442863/7442863-6222497511286796292