THE HOUSE SUBCOMMITTEE ON TECHNOLOGY, INFORMATION
POLICY, INTERGOVERNMENTAL RELATIONS, AND THE CENSUS
ON THE SUBJECT OF ELECTRONIC RECORDS MANAGEMENT
JULY 8, 2003
My name is J. Timothy Sprehe and I am president of
Sprehe Information Management Associates, a consulting firm based in
Washington, DC, and in recent years specializing in electronic records
management.
It is a pleasure to appear before the Subcommittee on Technology, Information Policy, Intergovernmental Relations, and the Census to discuss the subject of electronic records management or ERM. In the words of the National Archives’ 2001 report on current recordkeeping practices, “The chief paradox of today’s Federal RM is the disconnect between paper and electronic recordkeeping.” Government employees do not know how to solve the problem of electronic records – whether the electronic information they create constitutes records and, if so, what to do with the records. Many agencies do competent paper records management; only a handful does competent electronic records management.
Part of the reason for this disparity lies in the
organizational culture chasm between the records management community and the
information technology community. Generally, records managers do not understand
IT and IT managers do not understand records management. IT personnel do not
comprehend that a “record” under the Federal Records Act is not just something
saved by a computer; rather, it is maintained as evidence in pursuance of legal
obligations or in the transaction of business. A federal record is something
you can take into court, where you must be able to prove that the record has
authenticity, reliability, integrity, and usability.
Another reason that ERM is sadly wanting in
federal agencies is because the National Archives and Records Administration
has been painfully slow to address ERM, let alone get out in front of it. In my
view, with a handful of outstanding exceptions, NARA is far below the norm in
technological sophistication. Bold, out-in-front policy guidance on ERM comes
very slowly in NARA’s culture of archivists and historians, compounded by the
agency’s extreme – and perhaps well justified -- fear of adverse litigation.
Let it be said in fairness that, when NARA does try to take the initiative on
ERM matters, the Office of Management and Budget, an agency that enjoys only a
superficial understanding of ERM, frequently applies the brakes.
In sum, as the volume of electronic records
multiplies exponentially in the agencies, progress in ERM creeps along inch by
inch. Records management disasters such as happened at the Bureau of Indian
Affairs and the Federal Bureau of Investigation are the tip of a large iceberg;
many more records management disasters are out there waiting to happen.
Turning to the brighter side, many agencies are
now actively planning for ERM. The principal obstacles these agencies face are
lack of funding for ERM and indifference on the part of senior management.
Investment in ERM brings long-term institutional improvement that does not
happen overnight. Too many agency heads and Chief Information Officers consider
ERM a back-burner low priority. They believe their top priorities are more
immediate and include such items as security and risk management, failing to
appreciate that ERM improves security and lowers risks.
A few agencies have broken through the clouds and
achieved significant achievement in making ERM an integral operating component
in their information architectures. The most notable examples are the Nuclear
Regulatory Commission, the Office of Civilian Radioactive Waste Management –
also known as the Yucca Mountain Project – in the Department of Energy, and the
Office of the Comptroller of the Currency in the Treasury Department. These are
agencies that take records very seriously by the nature of their missions,
agencies where top management has issued a mandate that ERM shall occur
enterprise-wide. Before long, the FBI can be added to this list. Also, the
Defense Advanced Research Project Agency has a limited, well running
application of ERM.
Agencies that have reached the stage of full
implementation of an ERM system are discovering that an electronic records
repository is a valuable asset that has many beneficial applications beyond records management. NARA’s motto
is “ready access to essential evidence.” Agencies with functioning ERM are
finding they have “instant access to institutional memory starting yesterday.”
They have begun to leverage this asset to provide economies and efficiencies to
other business functions.
To give an example, the Nuclear Regulatory
Commission’s ADAMS, which stands for Agency-wide Document Access and Management
System, is a combined electronic document and records management systems. ADAMS
contains only materials that are unclassified and nonproprietary. NRC has made
ADAMS a core component of the agency’s public website. ADAMS is not only
performing records management functions; it is also providing important public
information functions.
More than this, NRC has coupled ADAMS with
electronic signature capability. As a result, ADAMS can receive electronic
submissions from nuclear reactor licensees. Once those submissions are stripped
of classified and proprietary information, they are made available to the
public. Hence, NRC also has leveraged its investment in ERM to carry out the
Government Paperwork Elimination Act and improve its performance under the
Paperwork Reduction Act.
If I were to make a single recommendation regarding ERM, it would be this. Let the Office of Management and Budget change Exhibit 300 on Capital Planning and Budgeting in its annual budget directive, Circular No. A-11. The section of Exhibit 300 that deals with IT systems should state that no new IT system will receive funding for development and acquisition unless the justification for the new system adequately explains how the system will take care of records created by or passing through the system. NRC and the Yucca Mountain Project are already implementing such a policy.
In sum, we can only hope that, as more agencies
implement ERM, they will recognize what a valuable information asset they have
created. From my research and consulting, I have come to believe that ERM is
the bedrock of what is known as Enterprise Content Management. Without ERM,
Enterprise Content Management, formerly known just as Information Management,
is incomplete and hollow at its core.
Thank you for inviting me to testify. I am now
ready to answer any questions you may have.