We have received a number of comments from agencies about the new flexible disposition instructions in the GRS and want to provide some additional explanation as to why we have taken this approach and how agencies can use and benefit from these instructions.
Purpose of Flexible GRS Instructions
The GRS is not like agency schedules. It has to apply to all agencies throughout the federal government and not all agencies have the exact same retention needs for records. We have approached the GRS instructions as guidelines for agencies in retaining their records: we establish basic retention requirements, usually minimum retentions, but otherwise leave it to the agency to determine their business needs for the record. In other words, NARA sees no need to review disposition instructions for records covered by the GRS as long as they meet basic retention requirements.
The benefits of this approach are:
- GRS disposition instructions make it clear what the basic retention requirements are and when they can be longer or shorter.
- Agencies don’t have to request deviations to the GRS as long as their retention falls within the parameters of the GRS instruction.
- The new instructions make clear which items can be bucketed to the longest common retention.
- We can potentially cover more temporary items in the GRS, even if agencies have different retention needs.
- Agencies may find that all they have to do to implement the new GRS is update disposition authorities.
How to Implement Flexible Instructions
Implementation is going to take some work, but then updating agency schedules to match the new GRS is going to take some work anyway. Agencies should update their schedules to reflect new GRS items and in doing so determine what the appropriate retention is for your agency. You may:
- Use only the minimum retention: do not use “Longer retention is authorized for business use” in disposition manuals.
- Set a specific retention or retention band within the parameters established by the GRS.
- For example, if the GRS says “Destroy when 3 years old; longer retention is authorized for business use,” then the agency may say “Destroy when 5 years old.”
- Use disposition instruction exactly as written, leaving specific retentions up to offices or individual users.
In some cases you may not have to do anything other than update the GRS disposition authority. The flexible instructions should benefit agencies that have or are implementing bucket schedules. For example, an agency that has scheduled procurement records in a 7 year bucket can cite new GRS 1.1, item 010, because it sets a minimum retention of 6 years, but allows for longer retention. It will also benefit agencies that have their own items for records that are new to the GRS. As long as the agency retention falls into the parameters of the GRS you can site the GRS instead of informing NARA that you will be using your own authority.
We understand that the flexible disposition instructions may still cause some confusion. We will be conducting a customer satisfaction survey in 2015 to get some feedback from agencies on how implementation of new GRS, including the flexible schedules, is going. In the meantime, if you have any questions, please contact GRS_Team@nara.gov. We are happy to be of assistance.