M-19-21 Compliance: Transition from Physical to Electronic Records

On June 28, 2019, the National Archives and Record Administration (NARA) and the Office of Management and Budget (OMB) issued M-19-21 Compliance: Transition from Physical to Electronic Records. It is a directive to modernize the way government records are managed. 

Read this article to discover insights about this government-wide policy.

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What is the M-19-21 Directive?

M-19-21 is a memorandum that was issued on June 28, 2019, by the Executive Office of the President, which consolidated and added requirements to the previous M-12-18 directive. 

The purpose of this directive is to help the government transition to electronic records with the purpose of increasing efficiency, accuracy, and economical use of space. 


When is the Deadline?

The deadline for digitally managing all permanent records has already passed – meaning many agencies have already fallen behind. 

Ultimately, this initiative is designed to transition agencies into managing government records, whether temporary or permanent, entirely within an electronic environment by 2022. 

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Who does M-19-21 Impact?

M-19-21 is a government-wide initiative that applies to all federal agencies.


What is the Problem Agencies are Facing?

Many federal and state agencies today are facing the challenge of converting years’ worth of physical paper artifacts into electronic records. 

Especially now, to comply with the M-19-21 directive from the Executive Office of the President, these agencies need a solution to convert their records efficiently and securely with appropriate Electronic Records Management (ERM) including storage, formats, and metadata. 

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Journey to Digital Conversion

Meeting the requirements of M-19-21 provides an additional challenge to agencies that are constantly grappling with tight budgets as well as adhering to other initiatives. 

Though the move to a fully electronic government is the ultimate goal, each agency will achieve this on its own unique timeline, likely employing multiple strategies.

The journey for each agency starts by understanding their own current environment and determining the appropriate options that fit their specific needs, budgets, and goals through self-assessment.

 To determine the right path towards compliance, agencies need to think strategically. This includes exploring partnerships with commercial vendors, strategic consultation, physical storage, destruction, and digitization.


Key Factors Necessary to Achieve Compliance

While the full mandate can be accessed here, some key points of M-19-21 are:

ALL Federal Records (not only Permanent Electronic Records as stated in M-12-18, but also Temporary Records) must be created, managed, and maintained in electronic format by 2022.
Agencies need to close their own facilities and transfer any paper records to a Federal Records Center or a Commercial Storage Facility by 2022.
Agencies must designate a Senior Agency Official for Records Management and Agency Records Officer.
Agencies must maintain compliance with their records management including personnel training, scheduling records, workflow scheduling, etc.
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How do Federal Agencies Develop an Effective Plan?

With the deadline for full compliance looming, getting compliant is quickly becoming a priority for many federal agencies. According to NARA’s Criteria for Successfully Managing Permanent Electronic Records, there are four primary concerns when developing an effective Electronic Records Management (ERM) strategy:

  • Relevant stakeholders should be identified and guide the policy development process.
  • Training should be implemented to standardize document handling at your agency.
  • Policies should be clear, enforceable, and aligned with long-term records management goals.
Records Access
  • Access to records improves your agency’s ability to make quick decisions.
  • Records should be protected from unauthorized access, alteration, deletion, or loss.
  • Effective electronic records access can make documents searchable, saving time and effort.
  • Implement systems that can create, capture, manage, preserve, and transfer in electronic formats.
  • Automation can be a powerful tool in ensuring records are transferred to NARA with all required metadata.
  • Systems should carefully consider the document life cycle for your agency – some records are ephemeral while others may need to be retained and referenced for decades.

As your agency transitions, the need to convert documents into acceptable formats and tag them correctly is more important than ever because:

  • By 2022, NARA will no longer accept transfers of permanent or temporary records in analog formats and will accept records only in electronic format and with appropriate metadata.
  • Beginning January I, 2023, all other legal transfers of permanent records must be in electronic format, to the fullest extent possible, regardless of whether the records were originally created in electronic formats.

How can BODEX Support Agencies to Become M-19-21 Compliant?

We at BODEX are experts in ERM and have years of experience relating to databases, asset management, and custom software development

With our expertise in scanning paper artifacts, Adobe PDF, electronic records storage (database and electronic files), and metadata management, we know that we are in a great position to provide the perfect solution.

We have come up with a secure, confidential, efficient, and cost-effective process to seamlessly convert agency records with military-grade encryption to comply with the M-19-21 Memorandum.

  • BODEX gains custody of the paper records.
  • With strict confidentiality and careful paper handling procedures, we tag the paper artifacts and create inventory.
  • The artifacts are scanned using powerful, high-capacity scanners using OCR to generate the PDFs.
  • We perform validation and enrichment of metadata on the PDFs.
  • Each PDF is then ingested in a file or asset management system.
  • Concurrently we take each PDF and run ETL (extract, transform, load) scripts to load the data into database records.
  • Then, BODEX’s quality assurance team verifies the conversion and also conducts a second validation.
  • Based on guidance from the agency, we either return custody of the paper records or properly dispose them.
  • Finally, the “Deliverable” is provided to the agency containing all of the digitized records and information in the form of either:
    • A secure, military-grade encrypted hard drive with a digital assets generator, or
    • A FedRAMP authorized cloud-based storage platform.
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Outcome After Availing Our Services

An agency that uses these services provided by BODEX sees the following benefits:

  • M-19-21 Compliance
  • Optimized spend of tax-payer dollars
  • Worry-free and secure document management
  • Optimization of physical storage
  • Virtual organization of electronic records using tagging
  • A future-oriented platform for hosting electronic records
  • Electronic archival and search abilities of records
  • A customized UI to search for and preview electronic records
  • One-Stop shop for ERM needs
  • Try before you buy

What’s Next?

We hope that you definitely got some insights about the government-wide M-19-21 compliance. 

For many, the first step is identifying any permanent records that still haven’t been digitized in accordance with M-19-21 along with all other analog records that still need to be digitized. Once you have identified those records, have your agency’s Records Officer develop a plan to be compliant by December 31, 2022. 

Thanks for reading the article.



  1. https://info.aiim.org/
  2. https://www.archives.gov/
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