By Michelle Johnson
Sometimes as a state agency records management officer (RMO), you may find that your certified state agency records retention schedule needs to be updated before the next recertification is due. The Texas State Library and Archives Commission (TSLAC) has a process for this called a schedule amendment. It is similar to the process for submitting a recertification, but with a few key differences. Let’s go over the why’s, when’s, and how’s of submitting an amendment.
Note: This article only applies to state agencies. Local governments can reference this article for more information about customizing your local schedule.
The function of an amendment is to add, change, or delete series; it allows agencies to make targeted changes to particular series without reviewing the entire schedule. Unlike recertifications, agencies are not required to submit amendments within a specific timeline. However, many RMOs do find it necessary to submit amendments from time to time in order to keep their schedule current and in compliance with minimum requirements under the State Records Retention Schedule (RRS), University Records Retention Schedule (URRS), and other records rules. Remember that any changes to a state agency’s schedule must be approved by TSLAC before they can be implemented – amendments give you an option to do that at any time within your recertification cycle.
When to Amend
Many RMOs choose to amend when changes are made to administrative rules. The implementation of the 5th edition of the RRS in 2020 prompted a spate of amendment submissions, and we expect to see more once the current proposed updates to the RRS and URRS are adopted. The same can be said of new state or federal laws and industry standards outside of TSLAC’s rules. If at any time you find that your agency’s schedule no longer meets minimum requirements, you can submit an amendment to bring the schedule back into compliance with state, federal, and industry laws and standards.
Changes within an agency’s internal processes may also create a need to amend. For example, newly implemented teams or service offerings might produce new types of records that are not described on the existing retention schedule. In these cases, you would need to submit an amendment to add new series to the schedule before disposition could be conducted.
There are also instances where amendments are not appropriate. You should consider a full recertification if major structural changes to the schedule are needed, for instance adding new sections or conducting a holistic overhaul. In these cases, it is beneficial for TSLAC to review the entire schedule for consistency and clarity. However, it ultimately depends on the extent of the changes; we encourage you to contact your analyst if you are unsure if an amendment or recertification is best.
How to Amend
The SLR 105C is used as a cover page anytime you send a schedule to TSLAC for review. The form is signed by either the RMO or agency head and indicates whether you are filing an initial schedule certification, a recertification, or an amendment.
The SLR 122 is an Excel template used to fill in series details. Only enter the series you want to add, change, or delete. Fields 1-12 are found on all retention schedules; enter information exactly as you want it to appear on your approved schedule. Fields 13 and 14 are unique to amendments; enter information per instructions below to assist your analyst with the review process.
- Required for every series on the amendment.
- Enter “N” for series that are new to the schedule, “C” for existing series that are being changed, and “O” for series that you want to make obsolete – that is, delete from the schedule.
- Only required for series that are being changed and have a “C” code in Field 13.
- Enter the current Agency Item Number (AIN) for the series. This helps us locate the series on the current certified schedule.
When completing your SLR 122, we suggest referencing TSLAC’s instructions for completing the SLR 122, which include directions for each individual field as well as guidance on formatting requirements.
Once complete, email the SLR 105C and SLR 122 directly to the analyst assigned to your agency. After receiving the forms, your analyst will be in touch with next steps. Amendments go through a review process that is similar to recertifications; analysts review the submitted schedule changes and communicate with the RMO to be sure updated series comply with requirements. Sometimes this is a quick and simple process; sometimes a little more back-and-forth communication is required. Your agency should continue to use the current certified schedule until amendments are officially approved.
To review, the amendment process can be described in six steps:
- Decide whether to amend or recertify
- Fill out the SLR 105C – see instructions on page 2
- Fill out the SLR 122 – see instruction sheet
- Email the SLR 105C and SLR 122 to your agency’s analyst
- Make edits based on analyst review
- Continue to use existing schedule until updates are approved
The most crucial thing to remember is to communicate with your analyst along the way. When it comes to state agency schedule amendments, teamwork really does make the dream work. If you have been thinking about amending your schedule, reach out to your analyst today!
For more information about the schedule development process, take a look at our “Getting the Most Out of Your State Agency Retention Schedule” series: Part I (Structure), Part II (AINs), Part III (RSINs).