The Dec. 31 deadline to meet the M-19-21 mandate is quickly approaching and the Centers for Medicare & Medicaid Services along with the Environmental Protection Agency are turning to tracking tools to help them achieve their goal of going paperless.
“Are we going to be 100% compliant I would venture to say no but good enough and close enough absolutely,” said Susan Little, Director of Records and Information Systems at CMS during FCW's workshop on electronic records management this week. “Showing our intent as agencies and being able to document and outline that for NARA will be beneficial to all of us.”
CMS is looking to digitize permanent and long-term temporary records with regard to mission critical documents but over the last two years the agency has dealt with paper challenges as well as records information management business processes that overlap with other business programs within the federal government.
Shadow programs have been another major obstacle for CMS. Different groups inside the federal space assume their documents are not records and based on that assumption they just run them through a scanner.
“We are working on a chain of custody standard operating procedure to track a paper record to its digitized format," Little said. "The process involves business owner approvals and a higher level of team approval that verifies that the scanned document is in fact the same as the paper document before any kind of paper destruction happens.”
Many documents at CMS are tied to a litigation hold and the Swift System provides a workflow tracker that includes records management approvals for that process, which is integrated with their SharePoint environment.
The Records Management System also allows CMS to identify the physical record location.
“It keeps permanent electronic records with metadata until ERS is completely built and it allows us to proceed with disposal of the paper records that have met with retention that we’re not going to be sending to companies for audit tracking,” Little said.
The EPA has developed a paper asset tracking tool (PAT) to smooth the transition to electronic records. Andrew Yuen, Web IT Specialist at the EPA, said PATT allows users across the agency to submit and track digitization requests for paper records.
“PAT provides our records contacts with a tracking number which allows them to obtain real time information on where their records are located in the digitization process. PAT also captures and maintains metadata, assigns shelf location and tracks request priorities and it maintains that chain of custody,” Yuen said.
Another new EPA tool is the Armed Uploader, which will replace its desktop and email tool in order to improve accuracy.
“It will serve as the primary way records will be captured and submitted into our new records repository,” Yuen said. “It allows EPA staff to select files from their desktop or one drive as well as select emails from outlook.”
Little also believes CMS needs to create agency guidance on the same process. They can use NARA’s guidance and tailor it to their business model.
“We need to act on this, it’s something that we can do,” Little said. “We can’t control the external deadline, but we can internally control our mission and program to have this documentation ready.”