Records Management - cross

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OMB-M-19-21 required all federal agencies to manage their records electronically by 31 December 2022. Prior to that, USMC’s Records Management (RM) policy and business practices were based almost exclusively on paper (textual) RM processes. There was no standardized methodology for maintaining an RM program at the command level—Command Designated Records Managers (CDRMs) typically created and controlled the organization’s file plan via three-ring binders and excel spreadsheets. Furthermore, Headquarters Marine Corps (HQMC), specifically, the Records, Reports, Directives, and Forms Management Section (ARDB), had no way of verifying command’s RM compliance, outside of biannual IG inspections.

CHALLENGE: Hartwood Consulting Group realized early on that, at both the command and enterprise level, the USMC had no way of identifying 1) records locations 2) their format (i.e., electronic or paper), or 3) the policy conflicts and/or logistical limitations that could prevent those records from being managed in an electronic environment. Hartwood also realized that in order to fully migrate to electronic RM (ERM), the USMC had to first take inventory of its current readiness posture, determine any training and policy gaps, and decentralize its cultural RM processes.

SOLUTION:  Recognizing the need for a standardized system, Hartwood developed CROSS—the Command Records Operational Support Site—to meet all programmatic RM needs. A sharepoint configuration, CROSS provides both CDRMs and ARDB an “at-a-glance” snapshot of a command’s RM readiness posture. It also standardizes the programmatic construct of RM programs across the enterprise and enables CDRMs to manage their unit hierarchy, Staff Section RM assignment, file plan, and IG checklist in one, central location.

RESULT:  Representing Phase I (of III) of the USMC’s ERM migration plan, CROSS has successfully taken the guesswork out of RM while allowing commands to tailor their programs to suit their individual business needs. It has also provided a level of transparency and analysis to ARDB and IG staff previously denied. As a direct result of CROSS implementation, CDRMs have not only received noteworthy inspection recognition for their RM programs, but they have also—some, for the first time—come to appreciate how a decentralized management model can improve collaboration and compliance.  

The National Archives and Records Administration (NARA) required that all government organizations be compliant with the capture, storage, and management of email records by 31 December 2016. The United States Marine Corps (USMC) was aligned to utilize another organizations compliant system but when that option fell through at the last moment, another option was needed within 3 months.  

CHALLENGE:  The USMC was able to get a 3 month storage arrangement that technically met the capture and storage requirements of Capstone but did not allow for the proper conversion into records or the efficient management of the records. Hartwood was asked to explore options for a low cost solution that would bring the USMC into compliance with the ability to provide coverage for a minimum of 6 months and a maximum of 24 months. Of course the solution would need to be able to be implemented within 3 months. 

SOLUTION:  Hartwood Consulting Group reached out to other organizations across the USMC to determine if there were any existing architectures that could be leveraged to provide a short term compliant records management repository. Via this communication, it was discovered that there was an existing prototype architecture already on a USMC network that would be viable for the Capstone RM needs. Hartwood proposed 3 technical options that included different capabilities such as Deduplication, automated metadata assignment to assist with retrieval requirements, and of course licenses and support for the RM of the emails. We covered Information assurance requirements, storage requirements, and complete technical integration between software products.

RESULT:  After presenting the technical options, Hartwood was able to coordinate with the appropriate best in industry solution providers to align resource requirements, communicate across the USMC organizations, and provide full documentation of the extent of the work required to allow the USMC to acquire the funding, coordinate the contracting, and the management of the work. This included the complete lifecycle of the email from determination of Capstone officials to ensuring the ability to retrieve the records as needed to support the transparency requirements of the US government.

As a Department of the Navy, the Marine Corps is required to utilize the Navy’s retention policies for Records Management. In 2018, the Department of the Navy consolidated approximately 6,000 Standard Subject Identification Code (SSIC) retentions into approximately 712 Record Schedules. These schedules determine when and how records are destroyed or transferred to the National Archives and Records Administration (NARA). 

CHALLENGE:  Marine Corps personnel have historically used four-digit SSICs to categorize and dispose of their records. With the advent of the new Record Schedule dispositions, they are now required to manage two population sets: one to categorize/label their records according to subject (SSIC), and the other to label that same record’s retention policy (Record Schedule). Both data elements are required for each individual record and require records managers to manually “crosswalk” SSICs to their corresponding record schedule disposition. To further complicate matters, current USMC business practices require only the first four digits of an SSIC (ex., 1650) to be identified on a record itself—in actuality, SSICs can drill down five to seven digits (ex. 1650.1b), with each sub paragraph aligning to a different retention (ex. SSIC 1650.1b belongs to RS 1000-5 while SSIC 16501.c belongs to RS 1000-7). This has led to an enormous amount of confusion, compounded by a lack of available training.  

SOLUTION:  Recognizing the information disparity across the enterprise, Hartwood immediately went to work, hiring subject matter experts who performed a comprehensive analysis of every Record Schedule data point. We quickly realized that over 100 schedules are Navy specific, meaning that they have little to no bearing on any USMC mission/records at all. We also identified that of the 712 schedules, only 40% have “hard” retention policies—meaning that they have an event-based or manual “trigger” for disposition. This renders the remaining 60% nearly impossible to program into electronic workflows or retention policies, which is the endstate of DoD Office 365. Finally, we recognized that many of the record schedule descriptions (such as RS 1000-1) are vague and nearly impossible to interpret/categorize correctly. While COVID-19 interrupted our progress, Hartwood plans to reschedule an RM Workshop in which leaders of all ranks and Mission Occupational Specialties can convene to hammer out and “augment” more articulate record descriptions. Hartwood also designed a USMC-specific training, utilizing Articulate software, in order to provide self-guided training on the proper crosswalk of SSICs to Record Schedules. This resource, now posted as an E-Learning tool in CROSS, has enabled RMs all over the USMC to learn the proper application of an extremely antiquated and convoluted process.