We’ve had this question from a few local governments and state agencies, who wonder whether the directive for federal agencies to manage all email and permanent records electronically by 2019 (known as the Managing Government Records Directive) will extend to state or local governments. The answer is a resounding no. State and local governments will not be required to manage permanent records electronically.
Some governments have asked whether the directive will affect state and local governments – for example, if a state or local government has to submit certain reports to a federal agency, will they be required to submit those records electronically? The answer to that is also no. First of all, the directive is only aimed at permanent records and email. Secondly, the directive is aimed only at federal agencies. If you submit a report to a federal agency, and that report happens to have a permanent retention period, then it is the federal agency’s responsibility “to develop policies and procedures to meet the requirements of the Directive,” according to an email I received from a NARA official. In theory, that could mean that a federal agency will require reports to be submitted in an electronic format as part of their policy. However, as of right now, it appears that if a state or local government submits a paper report to a federal agency, it will be the responsibility of the federal agency to convert it to an electronic format and to subsequently manage the electronic record during its entire life cycle.
There may be another effect of the directive – when federal agencies start implementing the Directive, state and local governments will likely benefit from what federal agencies will learn in the process. We will be able to look at the policies, procedures, and tools that they use, and we hope that we will be able adopt similar methods for our state and local governments.
If you have any other questions about the Directive, I encourage you to look at the page linked above, which is where NARA provides information on the directive. They also have an email address set up for questions: PRMD@nara.gov.