B-153660, APR. 28, 1964

B-153660: Apr 28, 1964

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WE CRITICIZED YOUR ADMINISTRATION BECAUSE TITLE III OF YOUR REGULATIONS WAS SUBSTANTIALLY INCOMPLETE. THE PROPOSED ADDITION AND REVISIONS WILL EXPAND THE REGULATIONS IN THOSE AREAS WHICH WERE INCOMPLETE AT THE TIME OF OUR REVIEW. WE HAVE THE FOLLOWING SUGGESTIONS TO MAKE. OUR AUDIT ACTIVITIES IN THE FIELD OF RECORDS MANAGEMENT HAVE DISCLOSED CERTAIN WEAKNESSES IN THE AREA OF FILES MANAGEMENT.

B-153660, APR. 28, 1964

TO ADMINISTRATOR, GENERAL SERVICES ADMINISTRATION:

BY LETTER OF FEBRUARY 14, 1964, THE HONORABLE LAWSON B. KNOTT, JR., FORWARDED FOR OUR REVIEW COPIES OF PROPOSED NEW CHAPTERS II AND III, AND NEW SECTION 103.00, CHAPTER IV, TITLE 3, FEDERAL RECORDS, REGULATIONS OF THE GENERAL SERVICES ADMINISTRATION, TOGETHER WITH COPIES OF A PROPOSED REVISED SECTION 101.00, CHAPTER I, OF THE SAME TITLE.

IN OUR REPORT TO THE CONGRESS DATED OCTOBER 16, 1962, B-146743, ENTITLED REVIEW OF CERTAIN RECORDS MANAGEMENT ACTIVITIES, NATIONAL ARCHIVES AND RECORDS SERVICE, GENERAL SERVICES ADMINISTRATION, WE CRITICIZED YOUR ADMINISTRATION BECAUSE TITLE III OF YOUR REGULATIONS WAS SUBSTANTIALLY INCOMPLETE. THE PROPOSED ADDITION AND REVISIONS WILL EXPAND THE REGULATIONS IN THOSE AREAS WHICH WERE INCOMPLETE AT THE TIME OF OUR REVIEW. WE CONCUR GENERALLY WITH THE PROPOSED REGULATIONS AS PRESENTED. HOWEVER, WE HAVE THE FOLLOWING SUGGESTIONS TO MAKE.

IN ORDER TO REMOVE THE REMOTE POSSIBILITY THAT A FEDERAL AGENCY MIGHT MISCONSTRUE SOME PORTION OF CHAPTER II, PART 4, FORMS, WE RECOMMEND THAT A NEW SECTION 401.05 BE ADDED THERETO TO THE EFFECT THAT NOTHING IN THIS PART SHOULD BE CONSTRUED AS LIMITING OR IN ANY WAY AFFECTING THE AUTHORITY OF THE COMPTROLLER GENERAL OF THE UNITED STATES WITH RESPECT TO PRESCRIBING ACCOUNTING SYSTEMS, FORMS AND PROCEDURES.

IN CHAPTER III, SECTIONS 201.03A OF PART 2, 301.03A OF PART 3, AND 401.03A OF PART 4, REFER TO ,SECTION 101.04 OF THIS CHAPTER.' THIS REFERENCE APPARENTLY SHOULD BE TO SECTION 101.03.

WE SUGGEST THAT THE LAST SENTENCE OF SECTION 201.04B OF PART 2,CHAPTER III, BE CHANGED TO D,"LIMIT PREPARING LETTERS OF A PURELY ACKNOWLEDGMENT NATURE TO CASES IN WHICH CONSIDERABLE TIME MAY BE NEEDED FOR A SUBSTANTIVE REPLY.'

OUR AUDIT ACTIVITIES IN THE FIELD OF RECORDS MANAGEMENT HAVE DISCLOSED CERTAIN WEAKNESSES IN THE AREA OF FILES MANAGEMENT. TO HELP OVERCOME THESE WEAKNESSES, WE SUGGEST THAT SECTION 301.04A OF PART 3, CHAPTER III, BE EXPANDED TO READ SUBSTANTIALLY AS FOLLOWS:

"A. STANDARDIZE CLASSIFICATION AND FILING SCHEMES TO:

"1. ACHIEVE MAXIMUM UNIFORMITY AND EASE IN MAINTAINING AND USING AGENCY RECORDS.

"2. FACILITATE DISPOSAL OF RECORDS IN ACCORDANCE WITH APPLICABLE RECORDS DISPOSAL SCHEDULES.

"3.FACILITATE POSSIBLE LATER CONSOLIDATION OF IDENTICAL TYPE FILES PRESENTLY MAINTAINED AT DIFFERENT LOCATIONS.'