This update is from our General Records Schedule (GRS) Team
The GRS Team has recently been reviewing a number of schedules from agencies that bucket GRS items. (This review is part of the normal internal stakeholder review process that all schedules go through and any schedules superseding GRS items are reviewed by the GRS Team.) One of the problems we commonly encounter when doing these reviews relates to cutoff instructions, so we wanted to take a moment to remind agencies about why cutoff instructions—even in big bucket schedules—are important to consider, especially when bucketing GRS items.
We will often see cases where an agency has included a GRS item with a 3 year retention in a 5 year bucket item. This all seems well and good until you look at the cutoff instructions. Many bucket items just have a simple instruction like “Destroy when 5 years old.” But the GRS item it is superseding says “Destroy 3 years after superseded or obsolete.” One instruction has a cutoff at the beginning of the lifecycle (retention is based on when the record was created). The other is based on the end of the lifecycle. This can result in the 5 year retention actually being shorter than the 3 year retention. For example, say the records here are administrative policies. That policy may still be actively used 5 years after it is created. You don’t want to destroy it if it’s in use. That is why the GRS states that it should be destroyed a certain period of time after use has ceased (it is superseded or obsolete). The GRS Team would not concur with the proposed bucketing of this item to 5 years, unless the cutoff was changed.
So how do you resolve this issue in big bucket schedules: the most common way we have seen other agencies do it while not having to completely blow apart their buckets is to include specific cutoff instructions in their crosswalks. The disposition instruction states “Destroy 5 years after cutoff” and the cutoff instruction for the bucket item refers to users to the crosswalk. Then each item will indicate the cutoff.
If you have questions related to bucketing GRS items, please contact GRS_Team@nara.gov. We’re happy to help.