Behind closed doors at the National Archives, an acrimonious debate has unfolded over whether and how to dispose of records generated by Chief Financial Officers (CFOs) at executive branch agencies.
What is at stake is the proper identification and preservation of historically significant government financial records, some of which have already been lost.
A proposed “General Records Schedule” (GRS) that would authorize the disposal and destruction of various CFO records is “fundamentally flawed,” wrote one Archives analyst last year.
“I really cannot say anything positive about this proposed GRS,” wrote another analyst, in internal comments. “It is flawed, troubling, and misleading.” It is “unimplementable” and “will lead to the destruction of permanent records.”
“This proposal is ill-considered, ill-conceived, and should be terminated with extreme prejudice,” said a third.
But another Archives official said the “extremely aggressive tone to the argument” shows that those critics’ judgment has been “clouded” because they were not consulted in advance.
As a general matter, no one doubts that the overwhelming majority of government records lack permanent historical value and are properly destroyed. What is at issue in this dispute is whether the proposed schedule for destruction of financial records properly recognizes the enduring value of some CFO records.
The functions of agency Chief Financial Officers “are not routine, administrative, housekeeping operations traditionally covered by a [General Records Schedule],” one internal NARA critic insisted. “Prima facie, it is doubtful that there should be a GRS for the office of Chief Financial Officer.”
But the proposal is nevertheless moving forward.
In a February 22 Federal Register notice, NARA announced the availability for public comment of a disposition schedule for CFO records. A copy is here (pdf).
As a result of the debate of the past several months, the revised proposal adds several new caveats. It acknowledges that some CFO records are permanent, not temporary, and that they must be preserved; it specifies that the proposed schedule would apply to certain types of CFO components and not to others; and it notes that some CFO records are already subject to existing schedules that take precedence over the new proposal.
Under the circumstances, then, the remaining question is whether the proposed schedule will provide increased clarity and flexibility, as intended, or whether it will generate new confusion and inadvertent loss of historically valuable records.
A cross-section of internal NARA comments on the proposed schedule as of September 2006, only some of which were resolved by the latest draft, is posted here (pdf).
Some basic financial records of the United States Government have already been lost to history.
“We are unable to locate a document containing, or a series of documents from which we may deduce, the aggregate U.S. intelligence budget figure for Fiscal Year 1947 [or Fiscal Year 1948],” wrote the CIA’s Kathryn I. Dyer in 2003 in response to a Federation of American Scientists lawsuit.