Transitioning to a Fully Digital Government

This blog post is the first in a series focusing on specific areas agencies should consider in their transition to fully digital government.

Introduction to Fully Digital Government

OMB and NARA issued guidance that directed federal agencies to transition to electronic records. OMB/NARA Memorandums M-19-21 and M-23-07 set forth requirements for federal agencies and for NARA, including the June 30, 2024 deadline to manage federal records electronically to the fullest extent possible.

Ultimately, in a fully digital government, records are created digitally, used and maintained digitally, and those scheduled for permanent retention are transferred to NARA digitally. While NARA recently published 36 CFR 1236 providing instructions to digitize paper records, this regulation should not be used to continue paper-based business processes. 

Challenges in Transitioning from Paper to Digital

Over the past thirty years, most government records were initially created on computers or ‘born-digitally’, but many are still being printed on paper to meet specific business requirements. Documents are printed to receive a wet-ink signature, forms are filled out online but printed and mailed to an agency, and some agencies still accept comments on regulations in paper form. While in the short term agencies may choose to digitize these paper records according to the 36 CFR 1236 E standards, they should work to adopt all-digital workflows to eliminate paper from their business processes altogether. 

Considerations when Converting Between Paper and Digital Formats

Converting digital records to paper and subsequently digitizing them again is an inefficient process that introduces the risk of information loss or alteration. Agencies should review their business processes, specifically identifying those that still involve paper records. They should question whether these processes are necessary to meet legal requirements or if they are outdated legacy practices that need updating.

Agencies must transition to digital records unless they are granted an exception by NARA. Agencies should verify with their general counsel any cases where they believe they are legally required to maintain paper records and could include this information to support an exception request.  

Deadline for Transfer of Permanent Analog Records

Agencies are encouraged to transfer their permanent analog records to a NARA Federal Records Center in advance of the June 30, 2024 deadline. After that date, NARA will only accept permanent records in digital formats with required metadata.