Congressional Bill Proposal: AC 31.2025
The National Archives and Records Administration (NARA) has provided updated guidelines for submitting new NA-1005 forms outside the regular 4-year cycle. These forms, used for managing electronic messages under General Records Schedule (GRS) 6.1, are a crucial part of the Capstone implementation for agencies using GRS 6.1.
When to Submit Outside the 4-Year Cycle:
Agencies using GRS 6.1 must generally resubmit their email schedules every 4 years. However, if there are significant changes to the agency's email records management practices or to GRS 6.1 itself, agencies are permitted and encouraged to submit a new NA-1005 form outside of the regular 4-year cycle.
What Constitutes Significant Changes:
Examples of significant changes include alterations in email system architecture, increases in volume, agency mission changes impacting email records management, or updates to the GRS guidance that affect applicable retention periods or disposition instructions.
Submission Process:
- The agency must submit a fully completed NA-1005 form to NARA.
- The submission should clearly indicate the justification for early submission outside the regular cycle, describing what has changed and why a new schedule is needed.
- Agencies should include any documentation or new records retention requirements resulting from these changes.
Review and Approval:
NARA will review the submission on a case-by-case basis to ensure that the proposed schedule aligns with updated requirements and best practices.
Continued Use of GRS 6.1:
Agencies must continue to comply with all applicable provisions of GRS 6.1 unless NARA-approved changes are made via the new NA-1005 form.
It is important to note that the resubmission of the NA-1005 form is a requirement by NARA. Agencies currently undergoing reorganization should wait until reorganization is complete before submitting a new form.
If unsure about submitting a new NA-1005 form before the next government-wide resubmission cycle in 2027, contact the NARA GRS Team at [email protected]. A properly updated NA-1005 form can assist with implementation and reduce the possibility of unauthorized disposals.
More information on tracking position changes can be found in the FAQs for GRS 6.1, question 3. A "major agency reorganization" is one scenario requiring an agency to submit a new NA-1005 form. Agencies that have completed a major reorganization should submit a new NA-1005 form.
NARA Bulletin 2022-02 outlines when an agency should submit an updated NA-1005 form outside the regular cycle. The NA-1005 form, Verification for the Use of GRS 6.1, is a document required by NARA. The next resubmission cycle for the NA-1005 form is in early 2027. William Fischer, the Chief Records Officer for the U.S. Government (Acting), oversees these important processes.
- In light of the updated guidelines provided by NARA Bulletin 2022-02, agencies with major reorganizations should submit a new NA-1005 form as it assists with implementation and prevents unauthorized disposals.
- Similarly, if any updates to the policy-and-legislation concerning general-news affect applicable retention periods or disposition instructions, or if there are significant changes in the agency's email records management practices or architecture, politics may necessitate the submission of a new NA-1005 form outside the regular 4-year cycle.
