Post for state agencies coming soon.
Local governments are afforded a lot of leeway when adopting TSLAC’s Local Government Schedules. It may seem daunting at first to familiarize yourself with, and meet the mandatory minimums, of 100 or even 1000 record series, but it doesn’t have to be.
Customization is still king
Before September 1, 2019, local governments had three options for their retention decision:
- Declare compliance with our schedules (passive)
- Perform a records inventory that results in a custom schedule which needs TSLAC approval (active)
- Declare everything a permanent record (very passive)
To be in compliance with the Local Government Records Act one must declare compliance with TSLAC’s schedules (option 1). Filing a custom schedule with TSLAC for our approval is no longer a possibility. However, just because you’ve declared compliance with our mandatory minimum retention periods, that doesn’t mean you have to have a passive records management program. There are still various ways you can customize TSLAC’s schedules for internal use and we have some tips for how make that effective.
Massive caveat #1: A records inventory should be conducted before implementing any of the following tips. The National Archives and Records Administration offers a several-part series on the inventory process.
Tip #1 – Use the editable version of TSLAC’s schedules
Take advantage of the MS Word versions of the schedules. We make our schedules available in three different formats: PDF, Word and HTML. The easiest one to customize is the Word format. PDF and HTML are useful in their own way, but the Word version can be downloaded and put to work at once.
Tip #2 – Do the Easy Stuff First
Using your records inventory, compare it with your adopted schedules. What records series are you using? Which ones have no relevance to your operations? Specific forms or documents that fall under an adopted record series that should be noted? By design, TSLAC’s schedules can appear a little generic. For example, GR 1000-25 – Contracts, Leases and Agreements is doing a lot of work. What functions does your government perform on a regular basis that would fall into this series? For the sake of efficient workflow, which divisions would most benefit from having their specific agreements spelled out here? Add an additional column to the end of the row that lists out the specific records you produce that are associated with a series if it’s helpful.
Combine schedules. Back when TSLAC reviewed custom schedules, a normal practice was to combine record series from different schedules. For instance, a water district might take series from GR, PW and UT and combine them into one useable document – as opposed to having three schedules to comb though. If you do this, make sure to carry over the record item numbers from TSLAC’s schedules so you have that reference to the original schedule. More information on adding original series appears later in this article.
Tip #3 – Get Out Your Clippers
Trim the schedules. You’ve declared compliance with all the of the retention periods in a given schedule, but you’ve probably noticed that even in the general schedule, there are numerous series that your local government just doesn’t use at all. The Queen of Big Buckets Susan Cisco advises that the golden number of retention series in a retention schedule is 100. This may or may not be feasible for you, but it’s a worthwhile goal to keep in mind. If you’re not using a retention series, eliminate it from the schedule you keep for internal use. There’s no reason why your government or elected office needs to flip past the five rows dealing with Construction Project Records if none of your functions entail the creation of records associated with a construction project. Take them out.
Additionally, remove erroneous information, as needed. Section 2-2: Accounting Records of Local Schedule GR makes the distinction between School Districts and “other governments” in a majority of the retention periods. There’s a 100% chance that you’re either one or the other and only need to abide by one of the mandated retention periods. Remove the irrelevant one to save space and ink (if you print these out.)
Tip #4– Flesh Out Retention Periods
TSLAC schedules publish the mandatory minimum retention periods that local governments must adhere to. If a record type serves a business use in your local government that requires you to hold onto it for longer, go ahead and note that on your internal schedules. You can accomplish this by either editing the retention period column (for instance, changing a 4 to a 5) or making a note in the Remarks Column. Or both. Change the retention period and then note the change in the Remarks Column as “_______ policy to retain longer than TSLAC minimum.”
Define AV where appropriate. AV is the retention code that defers ultimate disposition timeline control to local governments. It could be five minutes or 100 years. It’s up to you. For some record types, it may make sense to keep that flexibility. But I have consulted with some local governments that have eschewed AV retention codes for something more concrete. An example would be PW5250-01b – Residential Building Permits or Certificates of Occupancy. A municipal building permit office would probably be interested in having something more fleshed out to follow. Internal documentation of this change can include getting rid of AV in favor of, say, 18 months. Or, including in the Remarks column, “_______ policy to retain for 18 months.”
Tip #5 – Start Bucketing
Use the bucketing technique. You may have noticed when browsing the schedules that there are several rows in a row for records series that serve similar functions and have similar retention periods. Take the Ledgers section in Local Schedule GR for example:
|GR1025-30a||LEDGERS, JOURNALS, AND ENTRY DOCUMENTATION||General ledger showing receipts and expenditures from all accounts and funds of a local government. (1) For fiscal years for which an annual financial audit report (see item number GR1025-01) exists. (2) For fiscal years for which an annual financial audit report (see item number GR1025-01) does not exist.|| FE + 5 years. |
|Retention Note: Review before disposal; some ledgers may merit PERMANENT retention for historical reasons.|
|GR1025-30b||LEDGERS, JOURNALS, AND ENTRY DOCUMENTATION||Subsidiary ledgers.||FE + 5 years.||Retention Note: Review before disposal; some ledgers may merit PERMANENT retention for historical reasons.|
|GR1025-30c||LEDGERS, JOURNALS, AND ENTRY DOCUMENTATION||Receipt, disbursement, general, or subsidiary journals.||FE + 5 years.||Retention Note: Review before disposal; some journals may merit PERMANENT retention for historical reasons.|
|GR1025-30d||LEDGERS, JOURNALS, AND ENTRY DOCUMENTATION||Journal vouchers and entries or similar posting control forms (including supporting documentation such as correspondence and auditor adjustments that evidence journal entries and amendments).||FE + 5 years.||Retention Note: If bill stubs (see item number GR1025-27a) are used as entry documentation for account journals, they must be retained by all local governments for FE + 5 years rather than the FE + 3 year retention period for accounts receivable records.|
|GR1025-30e||LEDGERS, JOURNALS, AND ENTRY DOCUMENTATION||Perpetual care fund registers of government-owned cemeteries.||PERMANENT.||By law – Health and Safety Code, Section 713.005(a).|
If you do regular annual audits and don’t own a cemetery, you’re looking at several rows of series that have similar functions and an identical retention period. Instead of determining the applicable series when the date of disposition is the same, you can just combine them into one row that encompasses them all. See below:
|GR1025-30||LEDGERS, JOURNALS, AND ENTRY DOCUMENTATION||Series includes general and subsidiary ledgers as well as journals and their entry documentation.||FE + 5 Years||Retention Note: Review before disposal; some ledgers and journals may merit PERMANENT retention for historical reasons.||Series includes the following item numbers from Local Schedule GR: GR1025-30a, GR1025-30b, GR1025-30c, GR1025-30d|
- For the first column, I just reused the generic record item number from GR.
- Second column, I reused the generic record title from GR.
- For the third column, I included the basic descriptions of the four series that were to be bucketed.
- Fourth column is the uniform retention period that applies to all four series.
- In the fifth column, the retention note is virtually identical.
- I added this sixth column as a quality control measure. Because this bucketed series cannot be found on GR, a cross walk is helpful to explain its bits and pieces. The information in this cell can also be added to remarks or description – or not used at all.
The ledgers series is low hanging fruit. These series have the same name and retention period. More advanced bucketing could entail sticking those four series into a series with similar functions but a different retention period.
Massive Caveat #2: When you bucket series with different retention periods, you must use the longest retention period of the bucketed series.
For instance, you might just add journals and ledgers to the appropriate Accounts Receivable and Accounts Payable Series. Accounts Receivable example below:
|GR1025-27a||ACCOUNTS RECEIVABLE RECORDS||Bill copies or stubs, statements, billing registers, account cards, deposit warrants, cash receipts, credit card receipts, receipt books, cash transfers, daily cash reports, cash drawer reconciliations, ledgers, journals, entry documentation and similar records (such as returned checks and associated fees) that serve to document money owed to or received by a local government and its collection or receipt.||FE + 5||Retention Note: Review before disposal; some ledgers and journals may merit PERMANENT retention for historical reasons. Series includes the following item numbers from Local Schedule GR: GR1025-30a, GR1025-30b, GR1025-30c, GR1025-30d|
- Record item number is identical to what it is in GR
- Record series title is identical to what it is in GR
- The description was changed to include the four ledgers, journals and their entry documentation series.
- A flat retention period of FE + 5 years for all of these records. Formerly, there was a distinction drawn between school districts and other governments that is no longer applicable here. School districts keep the FE + 5 retention period while all other governments increase their retention from FE + 3 to FE + 5. As the caveat above mentions, you need to use the longest retention period of any series you are combing, so FE + 5 here.
- The previously non-existent (in the original series) retention note is carried over from the ledger series and included here.
Another example of local government bucketing options can be found in this article on the personnel file.
Bonus bucketing – TSLAC examples from Local Schedule PS.
For the 4th edition of Local Schedule PS, where we saw duplicates and redundancies, we did our best to combine and eliminate series.
- Aircraft maintenance (4025-01b) and inspections (4025-01c) were combined into a single series (4025-01b)
- Several vehicle records (4050-04b, c, d, and e) were combined into a single series (4050-04b)
- We also broadened the incidents reports series (4150-07) to include child abuse reports (4150-02), family violence reports (4150-04), and gunshot wound reports (4150-06)
There was also a suggestion made to bucket the video and recordings subseries into one:
|*PS4125-04a||VIDEO AND AUDIO RECORDINGS||Video or audio recordings from police vehicles of persons on whom charges are not filed.||90 days after the date of the stop.|
|*PS4125-04e||VIDEO AND AUDIO RECORDINGS||Officer-worn camera videos that do not capture a violation, use of deadly force by an officer, or are otherwise unrelated to an administrative or criminal investigation of an officer.||90 days.||By law – Occupations Code §1701.655(b)(2).|
TSLAC declined to combine these because of the specific statutes attached to dashboard cams versus body cams, but there is no reason why a local government can’t combine them for internal use. Both series have identical retention periods and Record Series Titles.
Before combining series ask yourself the following questions:
- Is the function of the records similar/same?
- Are existing retention periods the same or similar? That is, if one series has a 90-day retention period and the other one is a Permanent record – best not to bucket them.
- Are series maintained by different agencies/departments/offices or listed in different sections/categories of existing retention schedules?
- Is any series governed by law or statute?
- Are the historical value considerations the same?
Additional considerations on when or how to bucket can be found in this article.
Tip #6 – Add your own unique series
Though TSLAC doesn’t have the formal ability to approve original series amendments, they are still a useful tool for customizing your retention schedule. We know that our schedules are not all-encompassing and that some functions are not reflected therein. Heck, for each local schedule we have an ongoing “schedule suggestions” spreadsheet with recommended additions and edits – most of which we get from you all.
Adding a unique series is as easy as adding a new row to your schedule. You can add that row to the appropriate section (i.e. SECTION 1-2: General Records in Local Schedule GR.) You can add it the end. Or you can even start a separate document with all of your unique series. We have a template for that. Remember, in order to dispose of a local government record, it must appear on a retention schedule.
What you should include in your amendment:
- Record Item Number – Make it unique, to distinguish it from TSLAC’s local schedules. For instance, “Alamo1, Alamo2, Alamo3” work.
- Record Series Title – Make sure it accurately represents the content of the series and is distinguishable from other like series.
- Description – Summarize the business purpose, scope and content of the series.
- Retention Period – Sometimes unique series amendments are spurred by sections of the administrative code that TSLAC is not aware of. There might already be a retention period assigned. If that isn’t the case, and you’re unsure of what a suitable retention period would be, contact your analyst. We have access to researchers and a vast database.
- Remarks – This is your opportunity to say your piece on a record series. Where is it stored? What format? Is there a legal citation? Does this record type contain confidential information? Should the RMO review before disposition? Anything else the user of this record series should know about the record type?
If you’re a local government and you’re using our schedules in interesting ways, please let us know! Whether you’re trimming, amending, bucketing, combining or in any way editing our schedules to fit the needs of your local government, give your analyst a shout (or leave a comment.) I may be alone in this, but I miss the days of reviewing Records Control Schedules. I recall fondly the days where I would run up to the RMA Manager with a stack of papers and say, “what ________ is doing with Local Schedule LC is brilliant.” Ah, those were the days.
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Post for state agencies coming soon can’t come soon enough. I am hoping it will streamline processes that compliments compliance not at the expense of either.