This is the accessible text file for GAO report number GAO-10-838T 
entitled 'Information Management: The Challenges of Managing 
Electronic Records' which was released on June 17, 2010. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 


Before the Subcommittee on Information Policy, Census and National 
Archives, Committee on Oversight and Government Reform, House of 

United States Government Accountability Office: 

For Release on Delivery: 
Expected at 2:00 p.m. EDT: 
June 17, 2010: 

Information Management: 

The Challenges of Managing Electronic Records: 

Statement of Valerie C. Melvin: 
Director, Information Management and Human Capital Issues: 


GAO Highlights: 

Highlights of GAO-10-838T, a testimony before the Subcommittee on 
Information Policy, Census and National Archives, Committee on 
Oversight and Government Reform, House of Representatives. 

Why GAO Did This Study: 

Federal agencies are increasingly using electronic means to create, 
exchange, and store information, and in doing so, they frequently 
create federal records: that is, information, in whatever form, that 
documents government functions, activities, decisions, and other 
important transactions. As the volume of electronic information grows, 
so does the challenge of managing electronic records. Both federal 
agency heads and the National Archives and Records Administration 
(NARA) have responsibilities for managing federal records. 

As requested, after providing some context about records management in 
the federal government and the roles of federal agencies and NARA, 
this testimony describes the challenges of electronic records 
management and potential means of addressing these challenges. 

In preparing this testimony, GAO relied primarily on its previous 
work, supplemented by analysis of publicly available documents. 

What GAO Found: 

Under the Federal Records Act, agencies are to manage the creation, 
maintenance, use, and disposition of records in order to achieve 
adequate and proper documentation of the policies and transactions of 
the federal government and effective and economical management of 
agency operations. If records are poorly managed, individuals might 
lose access to benefits for which they are entitled, the government 
could be exposed to legal liabilities, and records of historical 
interest could be lost forever. NARA is responsible, among other 
things, for providing records management guidance, assistance, and 

However, as GAO has previously reported, records management has 
received low priority within the federal government. Prior reports 
have identified persistent weaknesses in federal records management, 
including a lack of policies and training. GAO’s most recent report, 
in 2008, found weaknesses in e-mail management at the four agencies 
reviewed due in part to insufficient oversight and training. This 
year, NARA published the results of its first annual agency records 
management self-assessment survey, indicating that almost 80 percent 
of agencies were at moderate to high risk of improper disposition of 

Electronic records are challenging to manage, especially as electronic 
information is being created in volumes that pose a significant 
technical challenge to the ability to organize and make it accessible. 
Further, electronic records range in complexity from simple text files 
to highly complex formats with embedded computational formulas and 
dynamic content, and new formats continue to be created. Finally, in a 
decentralized environment, it is difficult to ensure that records are 
properly identified and managed by end users on individual desktops 
(the “user challenge”). E-mail is particularly problematic, because it 
combines all these challenges and is ubiquitous. 

Technology alone cannot solve the problem without commitment from 
agencies. Electronic recordkeeping systems can be challenging to 
implement and can require considerable resources for planning and 
implementation, including establishing a sound records management 
program as a basis. In addition, the “user problem” is not yet solved, 
particularly for e-mail messages. Further, automation will not solve 
the problem of lack of priority, which is of long standing. However, 
several developments may lead to increased senior-level attention to 
records management: NARA’s use of public ratings as a spur to agency 
management, growing recognition of risks entailed in poor information 
and records management, the requirements and emphasis of the recent 
Open Government Directive, and the influence of congressional 
oversight. Senior management commitment, if followed through with 
effective implementation, could improve the governmentwide management 
of electronic and other records. 

View [hyperlink,] or key 
components. For more information, contact Valerie C. Melvin, (202) 512-

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I appreciate the opportunity to discuss critical issues surrounding 
electronic records management in the federal government. As you are 
aware, federal agencies are increasingly using electronic means to 
create, exchange, and store information, and in doing so, they 
frequently create federal records. According to the Federal Records 
Act,[Footnote 1] federal records are information in whatever form that 
documents government functions, activities, decisions, and other 
important transactions, and such records must be managed and preserved 
in accordance with the act.[Footnote 2] As the volume of 
electronically stored information grows, so does the challenge of 
managing electronic records. 

As requested, after providing some context about records management in 
the federal government and the roles of federal agencies and the 
National Archives and Records Administration (NARA), my statement will 
focus on describing the challenges of electronic records management 
and potential means of addressing these challenges. 

My comments today are based primarily on our previous work, all of 
which was conducted in accordance with generally accepted government 
auditing standards, supplemented by analysis of information contained 
in publicly available documents, following appropriate GAO quality 
assurance processes. 


The federal government collects, generates, and uses large amounts of 
information in electronic form, from enormous geographic databases to 
individual e-mails. Much of that information can constitute official 
federal records, and agencies must have ways to manage such records. 

Federal Agencies and NARA Have Responsibilities for Federal Records 

Under the Federal Records Act,[Footnote 3] each federal agency is 
required to make and preserve records that (1) document the 
organization, functions, policies, decisions, procedures, and 
essential transactions of the agency and (2) provide the information 
necessary to protect the legal and financial rights of the government 
and of persons directly affected by the agency's activities.[Footnote 
4] If these records are not effectively managed, individuals might 
lose access to benefits for which they are entitled, the government 
could be exposed to legal liabilities, and historical records of vital 
interest could be lost forever. In addition, agencies with poorly 
managed records risk increased costs when attempting to search their 
records in response to Freedom of Information Act requests or 
litigation-related discovery actions. Finally, without effective 
management of the documentation of government actions, the ability of 
the people to hold the government accountable is jeopardized. 

Effective records management is also an important tool for efficient 
government operation. Without adequate and readily accessible 
documentation, agencies may not have access to important operational 
information to make decisions and carry out their missions.[Footnote 5] 

Accordingly, to ensure that they have appropriate recordkeeping 
systems with which to manage and preserve their records, agencies are 
required to develop records management programs.[Footnote 6] These 
programs are intended, among other things, to provide for accurate and 
complete documentation of the policies and transactions of each 
federal agency, to control the quality and quantity of records they 
produce, and to provide for judicious preservation and disposal of 
federal records. 

Among the activities of a records management program are identifying 
records and sources of records and providing records management 
guidance, including agency-specific recordkeeping practices that 
establish what records need to be created in order to conduct agency 

Under the Federal Records Act and the regulations issued by NARA, 
records must be effectively managed throughout their life cycle, which 
includes records creation or receipt, maintenance and use, and 
disposition. Agencies create records to meet the business needs and 
legal responsibilities of federal programs and (to the extent known) 
the needs of internal and external stakeholders who may make secondary 
use of the records. To maintain and use the records created, agencies 
are to establish internal recordkeeping requirements for maintaining 
records, consistently apply these requirements, and establish systems 
that allow them to find records that they need. Disposition involves 
transferring records of permanent, historical value to NARA for 
archiving and destroying all other records that are no longer needed 
for agency operations. 

One key records management process is scheduling, the means by which 
NARA and agencies identify federal records and determine time frames 
for disposition. Creating records schedules involves identifying and 
inventorying records, appraising their value, determining whether they 
are temporary or permanent, and determining how long records should be 
kept before they are destroyed or turned over to NARA for archiving. 
For example, one general records schedule permits civilian agencies to 
destroy case files for merit promotions[Footnote 7] (2 years after the 
personnel action is completed, or after an audit by the Office of 
Personnel Management, whichever is sooner). No record may be destroyed 
or permanently transferred to NARA unless it has been scheduled, so 
the schedule is of critical importance. Without schedules, agencies 
would have no clear criteria for when to dispose of records and, to 
avoid disposing of them unlawfully, would have to maintain them 

Scheduling records, electronic or otherwise, requires agencies to 
invest time and resources to analyze the information that an agency 
receives, produces, and uses to fulfill its mission. Such an analysis 
allows an agency to set up processes and structures to associate 
records with schedules and other information (metadata) to help it 
find and use records during their useful lives and dispose of those no 
longer needed. 

Records schedules are based on content and are media-neutral; that is, 
electronic records are classified on the same basis--by content--as 
physical records. In addition, agencies are to compile inventories of 
their information systems, after which the agency is required to 
develop a schedule for the electronic records maintained in those 

NARA also has responsibilities related to scheduling records. NARA 
works with agencies to help schedule records, and it must approve all 
agency records schedules. It also develops and maintains general 
records schedules covering records common to several or all agencies. 
According to NARA, records covered by general records schedules make 
up about a third of all federal records. For the other two thirds, 
NARA and the agencies must agree upon agency-specific records 

Under the Federal Records Act, NARA is given general oversight 
responsibilities for records management as well as general 
responsibilities for archiving--the preservation in the National 
Archives of the United States of permanent records documenting the 
activities of the government.[Footnote 8] Of the total number of 
federal records, less than 3 percent are permanent. (However, under 
the act and other statutes, some of the responsibilities for oversight 
over federal records management are divided across several agencies. 
Under the Federal Records Act, NARA shares a number of records 
management responsibilities and authorities with the General Services 
Administration (GSA).[Footnote 9] The Office of Management and Budget 
(OMB) also has records management oversight responsibilities under the 
Paperwork Reduction Act[Footnote 10] and the E-Government Act. 
[Footnote 11]) 

For records management, NARA is responsible for issuing guidance; 
working with agencies to implement effective controls over the 
creation, maintenance, and use of records in the conduct of agency 
business; providing oversight of agencies' records management 
programs; approving the disposition (destruction or preservation) of 
records; and providing storage facilities for agency records. The act 
also gives NARA the responsibility for conducting inspections or 
surveys of agency records and records management programs. 

Federal Records Management Has Been Given Low Priority and Has Had 
Persistent Weaknesses: 

Historically, despite the requirements of the Federal Records Act, 
records management has received low priority within the federal 
government. As early as 1981, in a report entitled Federal Records 
Management: A History of Neglect,[Footnote 12] we stated that 
"persistent records management shortcomings" had been attributed to 
causes that included "lack of commitment by top management, emphasis 
on agency missions, and the low priority of records management." 
Almost 30 years later, the priority problem has remained remarkably 

For instance, a 2001 study prepared for NARA by SRA International, 
Inc., on perceptions in the federal government with respect to records 
management, concluded that recordkeeping and records management in 
general receive low priority, as evidenced by lack of staff or budget 
resources, absence of up-to-date policies and procedures, lack of 
training, and lack of accountability.[Footnote 13] This assessment 
also concluded that although agencies were creating and maintaining 
records appropriately, most electronic records remained unscheduled, 
and records of historical value were not being identified and provided 
to NARA for archiving. 

In 2002, drawing on the 2001 study, we reported that the low priority 
given to records management programs was a factor in program weaknesses. 
[Footnote 14] We noted that records management is generally considered 
a "support" activity. Because support functions are typically the most 
dispensable in agencies, resources for and focus on these functions are 
often limited. 

In 2008, we reported on weaknesses in federal e-mail management at 
four agencies.[Footnote 15] The four agencies reviewed generally 
managed e-mail records through paper-based processes, rather than 
using electronic recordkeeping. (A transition to electronic 
recordkeeping was under way at one of the four agencies, and two had 
long-term plans to use electronic recordkeeping.) We attributed 
weaknesses in agency e-mail management (such as senior officials not 
conforming to regulations) to factors including insufficient training 
and oversight regarding recordkeeping practices (as well as the 
onerousness of handling large volumes of e-mail)--similar to the 
effects of low priority described by SRA. Accordingly, we recommended 
that agencies with weaknesses in oversight, policies, and practices 
develop and apply oversight practices, such as reviews and monitoring 
of records management training and practices, that would be adequate 
to ensure that policies were effective and that staff were adequately 
trained and were implementing policies appropriately. 

Further evidence of the persistence of the priority issue was provided 
in 2008, when NARA surveyed federal senior managers about their 
perception of records management. According to the survey, only 64 
percent of managers saw records management as a useful tool for 
mitigating risk. 

In April 2010, NARA released a report on its first annual records 
management self-assessment, which analyzed responses to a survey sent 
in September 2009 to 245 federal cabinet-level agencies, agency 
components, and independent agencies.[Footnote 16] According to NARA, 
the survey results showed that almost 80 percent of agencies were at 
moderate to high risk of improper disposition of records.[Footnote 17] 
For example, the survey found that not all agencies had appropriate 
policies in place for handling e-mail, and that only a little over 
half of the responding agencies had training in place for high-level 
executives and political appointees on how to manage e-mail; this is 
consistent with the finding in our 2008 report on e-mail practices 
regarding insufficient training and oversight regarding recordkeeping 
practices. NARA rated almost half of the responding agencies (105 of 
221) as high risk in the area of e-mail. 

NARA's survey also indicated, among other things, that a large 
proportion of agencies have not scheduled existing systems that 
contain electronic records. In December 2005, NARA issued a bulletin 
requiring agencies to have NARA-approved records schedules for all 
records in existing electronic information systems by September 30, 
2009. 27 percent of agencies responding to NARA's September 2009 
agency self-assessment survey indicated that fewer than half of their 
electronic systems were scheduled. Such large numbers of unscheduled 
systems are a problem for agencies because their records cannot 
legally be disposed of, with the consequences for increased cost and 
risk mentioned earlier. 

NARA concluded that the varying levels of agency compliance with its 
records management regulations and policies have implications for the 
government's effectiveness and efficiency in conducting its business, 
protecting citizens' rights, assuring government accountability, and 
preserving our national history. 

Our Previous Reports Have Recommended Strengthening NARA's Oversight 

The Federal Records Act gave NARA responsibility for oversight of 
agency records management programs by, among other functions, making 
it responsible for conducting inspections or surveys of agencies' 
records and records management programs and practices; conducting 
records management studies; and reporting the results of these 
activities to the Congress and OMB.[Footnote 18] 

We have made recommendations to NARA in previous reports that were 
aimed at improving NARA's insight into the state of federal records 
management as a basis for determining where its attention is most 
needed. In 1999, in reporting on the substantial challenge of managing 
and preserving electronic records in an era of rapidly changing 
technology,[Footnote 19] we noted that NARA did not have 
governmentwide data on the electronic records management capabilities 
and programs of all federal agencies. Accordingly, we recommended that 
NARA conduct a governmentwide survey of these programs and use the 
information as input to its efforts to reengineer its business 
processes. However, instead of doing a governmentwide baseline 
assessment survey as we recommended, NARA planned to obtain 
information from a limited sample of agencies, stating that it would 
evaluate the need for such a survey later.[Footnote 20] 

In 2002, we reported that because NARA did not perform systematic 
inspections of agency records management, it did not have 
comprehensive information on implementation issues and areas where 
guidance needed strengthening.[Footnote 21] We noted that in 2000, 
NARA had suspended agency evaluations (inspections) because it 
considered that these reached only a few agencies, were often 
perceived negatively, and resulted in a list of records management 
problems that agencies then had to resolve on their own. However, we 
concluded that the new approach that NARA initiated (targeted 
assistance) did not provide systematic and comprehensive information 
for assessing progress over time. (Only agencies requesting assistance 
were evaluated, and the scope and focus of the assistance were 
determined not by NARA but by the requesting agency.) Accordingly, we 
recommended that it develop a strategy for conducting systematic 
inspections of agency records management programs to (1) periodically 
assess agency progress in improving records management programs and 
(2) evaluate the efficacy of NARA's governmentwide guidance. 

In response to our recommendations, NARA devised a strategy for a 
comprehensive approach to improving agency records management that 
included inspections and identification of risks and priorities. 
Subsequently, it also developed an implementation plan that included 
undertaking agency inspections based on a risk-based model, government 
studies, or media reports.[Footnote 22] 

In 2008, we reported that under its oversight strategy, NARA had 
performed or sponsored six records management studies in the previous 
5 years, but it had not conducted any inspections since 2000, because 
it used inspections only to address cases of the highest risk, and no 
recent cases met its criteria.[Footnote 23] In addition, NARA's 
reporting to the Congress and OMB did not consistently provide 
evaluations of responses by federal agencies to its recommendations, 
as required, or details on records management problems or recommended 
practices that were discovered as a result of inspections, studies, or 
targeted assistance projects. 

Accordingly, we recommended that NARA develop and implement an 
oversight approach that provides adequate assurance that agencies are 
following NARA guidance, including both regular assessments of agency 
records and records management programs and reporting on these 
assessments. NARA agreed with our recommendations and devised a 
strategy that included annual self-assessment surveys, inspections, 
and reporting. It has now begun implementing that strategy, having 
released the results of its first governmentwide self-assessment 
survey, as mentioned earlier. 

Managing Records in Electronic Form Presents Major Challenges: 

As we have previously reported,[Footnote 24] electronic records pose 
major management challenges: their volume, their complexity, and the 
increasingly decentralized environment in which they are created. E- 
mail epitomizes the challenge, as it is not only voluminous and 
complex, but also ubiquitous. 

* Huge volumes of electronic information are being created. 

Electronic information is increasingly being created in volumes that 
pose a significant technical challenge to our ability to organize it 
and make it accessible. An example of this growth is provided by the 
difference between the digital records of the George W. Bush 
administration and that of the Clinton administration: NARA has 
reported that the Bush administration transferred 77 terabytes 
[Footnote 25] of data to the Archives on leaving office, which was 
about 35 times the amount of data transferred by the Clinton 
administration. Another example is the Department of Energy's National 
Energy Research Scientific Computing Center, which said that, as of 
January 2009, it had over 3.9 petabytes of data (that is, about 
4,000,000,000,000,000 bytes) in over 66 million files and that the 
volume of data in storage doubles almost every year.[Footnote 26] 

* Electronic records are complex. 

Electronic records have evolved from simple text-based files to 
complex digital objects that may contain embedded images (still and 
moving), sounds, hyperlinks, or spreadsheets with computational 
formulas. Some portions of electronic records, such as the content of 
dynamic Web pages, are created on the fly from databases and exist 
only during the viewing session. Others, such as e-mail, may contain 
multiple attachments, and they may be threaded (that is, related e-
mail messages are linked into send-reply chains). They may depend 
heavily on context. For example, to understand the significance of an 
e-mail, we may need to know not only the identity but the position in 
the agency of the sender and recipients. (Was it sent by an executive 
or a low-level employee?) In addition, new technologies, such as 
blogs, wikis, tweets, and social media, continue to emerge, posing new 
challenges to records managers. 

* Identification and classification of electronic records are 
difficult in a decentralized computing environment. 

The challenge of managing electronic records significantly increases 
with the decentralization of the computing environment. In the 
centralized environment of a mainframe computer, it is comparatively 
simple to identify, assess, and manage electronic records. However, in 
the decentralized environment of agencies' office automation systems, 
every user can create electronic files of generally unstructured data 
that may be formal records and thus should be managed. Documents can 
be created on individuals' desktop computers and stored on local hard 
drives. E-mail can come from outside the agency. In cases like these, 
the agency generally depends on the individual to identify the 
document or the e-mail as a record, and, through placing it in a 
recordkeeping system, associate it with its appropriate schedule, make 
it searchable and retrievable, and preserve it until it is due for 

As we reported in 2008,[Footnote 27] e-mail is especially problematic. 
E-mail embodies several major challenges to records management: 

* It is unstructured data, and it can be about anything, or about 
several subjects in the same message, making it difficult to classify 
by content. 

* There is a very large volume of it: one study estimates that a 
typical corporate user sends or receives around 110 messages a day. 
[Footnote 28] Further, there may be many copies of the same e-mail, 
which can increase storage requirements or require a means of 
determining which copy to keep. Keeping large numbers of messages 
potentially increases the time, effort, and expense needed to search 
for information in response to a business need or an outside inquiry, 
such as a Freedom of Information Act request. 

* It is complex: e-mail records may have multiple attachments in a 
variety of formats, they may include formatting that is important for 
meaning, and they include information about senders, recipients, and 
time of sending. Recordkeeping systems must be able to capture all 
this information and must maintain the association between the e-mail 
and its attachment(s). 

* Its relevance depends on context. It may be part of a message thread 
that is necessary to understand its content, or it may discuss other 
documents or issues that are not well identified. An e-mail that says 
"I agree. Let's do it" may be about a major decision or about going to 
lunch next week. 

* It may not be obvious who is responsible for identifying an e-mail 
as a record and at what point. NARA regulations require that both 
senders and recipients may be responsible for identifying records. 
However, an e-mail may have multiple recipients and be forwarded to 
still other recipients. 

Agency Commitment Is a Prerequisite for Addressing the Electronic 
Records Challenge: 

As NARA has pointed out, the decision to move to electronic 
recordkeeping is inevitable, but as we and NARA have previously 
reported, implementing such systems requires that agencies commit the 
necessary resources for planning and implementation, including 
establishing a sound records management program as a basis. Further, 
automation will not, at least at the current state of the technology, 
solve the "end user problem"--relying on individual users to make 
sound record decisions. Nor will automation solve the problem of lack 
of priority, which, as our previous work has shown, is of long 
standing. However, several developments could lead to increased senior-
level attention to records management: NARA's use of public ratings as 
a spur to agency management, growing recognition of risks entailed in 
poor information and records management, the requirements and emphasis 
of the recent Open Government Directive, and the influence of 
congressional oversight. Senior management commitment, if followed 
through with effective implementation, could improve the 
governmentwide management of electronic and other records. 

Electronic Recordkeeping Systems Are Challenging to Implement and Will 
Not Yet Solve the End User Problem: 

Moving to electronic recordkeeping is not a simple or easy process. 
Agencies must balance the potential benefits against the costs of 
redesigning business processes and investing in technology. Our 
previous work has shown that such investments, like any information 
technology investment, require careful planning in the context of the 
specific agency's circumstances, in addition to well-managed 

In 2007, a NARA study team examined the experiences of five federal 
agencies (including itself) with electronic records management 
applications, with a particular emphasis on how these organizations 
used these applications to manage e-mail.[Footnote 29] Among the major 
conclusions was that although the functionality of the software 
product itself is important, other factors are also crucial, such as 
agency culture and the quality of the records management program in 
place. With regard to e-mail in particular, the survey concluded that 
for some agencies, the volume of e-mail messages created and received 
may be too overwhelming to be managed at the desktop by thousands of 
employees across many sites using a records management application 
alone. A follow-up study in 2008 added that although a records 
management application offers compliant electronic recordkeeping, "it 
can be expensive to acquire, time consuming to prepare for and 
implement, requires user intervention to file records, and can be 
costly over the long haul for data migration and system upgrades." 
[Footnote 30] NARA found that in most instances agencies had to work 
to overcome user resistance to using the system. 

This user challenge has led records management experts to believe that 
end users cannot be relied on to manage e-mail records, or indeed any 
other types of records. A recent Gartner study concluded that user- 
driven classification of records, especially e-mail, has failed and 
will continue to fail;[Footnote 31] a study by the Association for 
Information and Image Management (AIIM)[Footnote 32] stated "it is 
simply not plausible to expect all creators of records to perform 
accurate, manual declaration and classification."[Footnote 33] 
According to Gartner, "What enterprises really need (and want) is a 
mechanism that automatically classifies messages by records management 
type...without user intervention."[Footnote 34] At the time of writing 
(August 2007), Gartner described such technology as "in its infancy," 
but expected it to mature rapidly because of high demand. 

This technology, automated records classification (sometimes called 
"autocategorization"), might help address the user problem. (The Air 
Force is currently working with autocategorization projects.[Footnote 
35]) However, like other information technology, it requires resources 
for setup and maintenance to be effective, and it is not simple to 
implement.[Footnote 36] Further, according to AIIM, autocategorization 
might not work for an agency's particular documents or file plan, and 
might not be sufficiently accurate or cost effective. 

Some proposals have been made to simplify the e-mail problem. Gartner 
recommends treating e-mail as a separate issue from general records 
management, perhaps by putting all e-mail in a single category of 
temporary records with a uniform retention period. Similarly, the 
Director of Litigation in NARA's Office of General Counsel has 
suggested keeping all e-mail created by key senior officials (with 
some additional designations by agency components) as permanent and 
treating all the rest as temporary. Both proposals would make managing 
e-mail simpler, but could increase the risk that significant 
information will not be preserved. 

Recent Developments Could Help Spur More Action on Information and 
Records Management: 

Raising the priority of records management has been and continues to 
be an uphill battle. As we have reported, government needs to 
prioritize the use of resources, and records management has not been a 
high priority. Further, records management can also be time--and 
resource--consuming and technically difficult to implement. 

NARA can influence this situation by providing effective guidance and 
assistance to agencies, as well as through its oversight and reporting 
activities. With its recently initiated annual self-assessment survey, 
NARA is responding to our earlier recommendations on oversight by 
beginning an effort to develop a comprehensive view of the state of 
federal records management as a basis for determining where its 
attention is most needed. Reporting the results of the survey, with 
scores for individual agencies and components, to the Congress, OMB, 
and the public is one way to help bring the records management issue 
to the attention of senior agency management. 

Another factor that could help raise awareness of the value of records 
management is the growing recognition of the risks of weak electronic 
records and information management, as a result of fear of potentially 
large costs to organizations that have to produce electronically 
stored information to respond to litigation, as well as well-
publicized incidents of lost records, including e-mail. This 
recognition of risk is coupled with increased awareness of the value 
of organizations' information assets; according to AIIM, the field of 
enterprise content management (which includes records management) has 
been accepted, driven by the need to control the content chaos that 
pervades local drives, file shares, email systems, and legacy document 
stores. As a result, according to an AIIM survey, the highest current 
priorities for ECM activity are electronic records management and 
managing e-mails as records. 

Further, recent Open Government initiatives, which emphasize the 
importance of making information available to the public for 
transparency and accountability, could be an additional impetus to 
addressing electronic records management. OMB's Open Government 
Directive makes a direct link between open government and records 
management by requiring that each agency's Open Government Plan 
include a link to a publicly available Web site that shows how the 
agency is meeting its existing records management 
requirements.[Footnote 37] More generally, the directive urges 
agencies to use modern technology to disseminate useful information. 
According to an Administration official, records management plays a 
crucial role in open government by ensuring accountability through 
proper documentation of government actions.[Footnote 38] Increased 
attention to information and records management could provide another 
spur encouraging agencies to devote resources to managing their 
electronic records more effectively. 

Finally, the priority that agencies give to addressing weaknesses may 
be increased by hearings such as this, which show that the Congress 
recognizes the importance of good records management for the 
efficient, effective, and accountable operations of government. 

In summary, federal records management has been given low priority for 
many years. However, the explosion of electronic information and 
records is an increasing risk to agencies, and could even become a 
drag on agencies' ability to perform their missions if not brought 
under control. 

Raising visibility, as NARA is doing by publishing the results of its 
self-assessment survey, can raise the perception among senior agency 
officials of the importance of records management. Also significant is 
the push for Open Government, which, by heightening the importance of 
agencies' providing information to the public, makes information a 
more central part of their missions and could help highlight the 
actual importance to agencies of actively managing their information. 
Strong indications from the Congress that records management needs 
more attention could also raise the priority among agency management. 

Mr. Chairman, this completes my prepared statement. I would be pleased 
to respond to any questions you or other Members of the Subcommittee 
may have at this time. 

Contact and Acknowledgments: 

If you should have questions about this testimony, please contact me 
at (202) 512-6304 or Other major contributors include 
Barbara Collier, Lee McCracken, J. Michael Resser, and Glenn Spiegel. 

[End of section] 


[1] 44 U.S.C. chapters 21, 29, 31, and 33. 

[2] The definition of a record is given at 44 U.S.C. 3301. 

[3] 44 U.S.C. chapters 21, 29, 31, and 33. 

[4] 44 U.S.C. § 3101. 

[5] See, generally, Standards for Internal Control in the Federal 
Government, [hyperlink,] (Washington, D.C.: 
November 1999). 

[6] 44 U.S.C. § 3102. 

[7] That is, records relating to the promotion of an individual that 
document qualification standards, evaluation methods, selection 
procedures, and evaluations of candidates. Such records are covered 
under the General Records Schedule 1, Civilian Personnel Records. 

[8] 44 U.S.C. § 2904. Relevant NARA regulations implementing the 
Federal Records Act are found at 36 C.F.R. §§ 1220-1238. 

[9] These shared responsibilities are due in part to the origins of 
NARA. The 1984 National Archives and Records Administration Act, Pub. 
L. No. 98-497, 98 Stat. 2280 (Oct. 19, 1984), transferred the 
functions of GSA's National Archives and Records Service to the newly 
created NARA. 

[10] See 44 U.S.C. § 3504. 

[11] See 44 U.S.C. § 3602. 

[12] GAO, Federal Records Management: A History of Neglect, 
[hyperlink,] (Washington, D.C.: 
Feb. 24, 1981). 

[13] SRA International, Inc., Report on Current Recordkeeping 
Practices within the Federal Government (Dec. 10, 2001) [hyperlink,
practices.pdf]. This document reports on both a recordkeeping study 
performed by SRA International and a series of records system analyses 
performed by NARA staff. 

[14] GAO, Information Management: Challenges in Managing and 
Preserving Electronic Records, [hyperlink,] (Washington, D.C.: June 17, 

[15] GAO, Federal Records: National Archives and Selected Agencies 
Need to Strengthen E-Mail Management, [hyperlink,] (Washington, D.C.: June 13, 

[16] NARA, Records Management Self-Assessment 2009: An Assessment of 
Records Management Programs in the Federal Government (April 2010); 
220 agencies responded, for a response rate of 91 percent. 

[17] NARA assessed risk by calculating a weighted score based on 
agencies' responses to the 34 survey questions. Scores above 90 of 100 
possible points are considered low risk, 60 to 89 are moderate risk, 
and below 60 are high risk. NARA also identified issues that impact 
the reliability of the data including not covering the full universe 
of agencies, issues relating to the roles of department vs. component- 
level records officers, and problems involving some questions being 
unclear. NARA did not validate agencies' self-reported results. 

[18] In particular, the reports are to include evaluations of 
responses by agencies to any recommendations resulting from 
inspections or studies that NARA conducts and, to the extent 
practicable, estimates of costs to the government if agencies do not 
implement such recommendations. 

[19] GAO, National Archives: Preserving Electronic Records in an Era 
of Rapidly Changing Technology, [hyperlink,] (Washington, D.C.: July 19, 

[20] In 2001, as mentioned earlier, the NARA-sponsored SRA study was 
released [hyperlink,
mgmt/faqs/pdf/report-on-recordkeeping-practices.pdf]. This document 
reports on both a recordkeeping study performed by SRA and a series of 
records system analyses performed by NARA staff. 

[21] GAO, Information Management: Challenges in Managing and 
Preserving Electronic Records, [hyperlink,] (Washington, D.C.: June 17, 

[22] GAO, Electronic Records Archives: The National Archives and 
Records Administration's Fiscal Year 2006 Expenditure Plan, 
[hyperlink,] (Washington, D.C.: 
Aug. 18, 2006). 

[23] GAO, Federal Records: National Archives and Selected Agencies 
Need to Strengthen E-Mail Management, [hyperlink,] (Washington, D.C.: June 13, 

[24] GAO, Information Management: Challenges in Managing and 
Preserving Electronic Records, [hyperlink,] (Washington, D.C.: June 17, 

[25] A terabyte is about 1 trillion bytes, or 1000 gigabytes. 

[26] We did not verify the specific numbers, which are provided for 
illustrative purposes only. 

[27] GAO, Federal Records: National Archives and Selected Agencies 
Need to Strengthen E-Mail Management, [hyperlink,] (Washington, D.C.: June 13, 

[28] The Radicati Group, Inc., Email Statistics Report, 2010 (Palo 
Alto, Calif.: April 2010). 

[29] NARA, A Survey of Federal Agency Records Management Applications 
2007 (Jan. 22, 2008). 

[30] NARA, Continuing Study of Federal Agency Recordkeeping 
Technologies 2008 (Washington, D.C.: 2008). 

[31] Gartner Research, How to Address the Federal Government's Records 
Management Challenges, G00165869 (Mar. 14, 2009). 

[32] AIIM is a nonprofit organization focused on the management of 
documents, content, records, and business processes, as well as 
enterprise content management (ECM). 

[33] Richard Medina, David Gaffaney, and Linda Andrews, 
"Autocategorization: One Key Component for Enterprise Records 
Management," AIIM E-Doc Magazine, Vol. 20, Iss. 4 (July/August 2006). 

[34] Gartner Research, Best Practices in Records Management: FAQs, 
G00149526 (Aug. 17, 2007). 

[35] Michael Corrigan and J. Timothy Sprehe, "Intelligent 
Categorization: Air Force Information Asset Management," presentation 
delivered at FIRM Council March Program, (Mar. 4, 2010). [hyperlink,

[36] Automated classification systems may for example depend on sets 
of rules, such as the appearance of specific key words, to determine 
whether a document is a record and what series of records it belongs 
to. (For example, the words "litigation" and "plaintiff" appearing in 
a document might identify it as a legal record.) 

[37] OMB, Open Government Directive, M-10-06 (December 8, 2009). 

[38] Cass R. Sunstein, Administrator of the Office of Information and 
Regulatory Affairs, OMB, "Open Government and Records Management," 
Keynote, NARA 2010 Records Administration Conference (May 12, 2010). 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink,]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink,] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAO’s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO’s Web site, 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 

To Report Fraud, Waste, and Abuse in Federal Programs: 


Web site: [hyperlink,]: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: