So riddle me this, Batmen...
The present requirements for Federal Records Management are codified in 36CFR, Subchapter B
The Presidential Directive sets new guidance, and establishes dates by which the requirements must be met.
Generally, if a CFR is to be changed, the proposed changes must be posted in the Federal Register allowing time for a formal review and comment period, but in this case, the review and comment has already been completed by Agencies. Still, there is a period of time typically afforded for public review and comment. IF during the public review, issues are raised that may require some rethinking of the guidance in the Presidential Directive.... how will this be addressed?? And given some things may change, but many items have a rather short deadline... wouldn't it be advisable to WAIT to begin implementation until after the guidance is in the CFR?
I'm still at a complete loss for understanding how these target dates are intended to be met when there is no real understanding of the scope of the volume of either active or legacy electronic information held by agencies, declining staffing and insufficient funding to hire, train, procure equipment and start the work to move forward and achieve most of what is in this directive. Past partial efforts to stand up the ERAS and the FBI digital record keeping systems alone show the Federal Government is not prepared for this, even in pilot instances. And this report from the VA http://goo.gl/op2JP gives decent insight into the scope, complexity and effort required to do this work in one facet of an agency alone.
Larry
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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of John Milligan
Sent: Friday, August 24, 2012 8:37 AM
To: [log in to unmask]
Subject: [RM] Presidential Directive on Managing Government Records
Finally here - Presidential Directive on Managing Government Records - http://www.whitehouse.gov/sites/default/files/omb/memoranda/2012/m-12-18.pdf .
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