3.6 Records Management

HHS Records Management Program

The top priority for the HHS Records Management Program still remains the acquisition of a uniform Electronic Records Management System, which correlates to priority 3(a)(6) in the Presidential Memorandum, Managing Government Records, dated November 28, 2011. The decision to pursue such a system was a significant part of the Records Management Transition Plan draft which was updated in 2013. In preparation for acquiring that system, the HHS Records Management personnel conducted an inventory of the Department’s records schedules, updated file plans and created records schedules for the agency’s automated information systems according to OMB Memorandum M-12-18 section 2.2 dated August 24, 2012. An Executive Committee, consisting of representatives from the Department and all of its Operating Divisions, was established to justify the need for an Electronic Records Management System, and to define its required functionality and oversee its analysis and implementation.

HHS personnel analyzed the records management capabilities in both manual processes and the multiple automated information systems employed throughout HHS and concluded a uniform solution for electronic records management was needed for several reasons. Some of the electronic records management solutions in use throughout HHS were not satisfying the minimum requirements for such systems. Since the number of records managed by those automated information systems was growing exponentially, the HHS personnel determined better solutions for electronic records management, verified as meeting NARA expectations, were needed and a uniform solution would be more cost-effective than evaluating each independent automated information system in use and correcting them all separately. Additionally, the volume of records not yet managed electronically was also growing exponentially and the cost and logistics of managing the records was becoming unmanageable.

The HHS personnel that developed the Records Management Transition Plan realized compiling an inventory of the Department’s records schedule and file plans was prerequisite to acquiring an automated information system that could manage all records for the Department. The Department has met the prerequisite.

The Department is actively attending conferences and hosting Records Management vendors for solutions that will address the M-12-18 Managing Government Records Directive to manage all permanent records in an electronic format by December 2019. In addition to attending conferences and hosting vendors, the Department is also communicating with its Information Technology Infrastructure and Operations (ITIO) team to leverage the current SharePoint software as a possible solution.

The department will meet the two short-term priorities that are due by the end of 2016:

1. Department’s Records Management Program is the acquisition of an enterprise Email Record Keeping System. The Department began a phased rollout of its Email as a Service initiative, which has since been renamed “My Work Place” to most of its OPDIVs and STAFFDIVs. The inclusion of Microsoft 360 Email as a part of “My Work Place” allows the department to meet the M-12-18 mandate which states by December 31, 2016 all Federal agencies must manage all email records in an electronic format and that Email records must be retained in an appropriate electronic system that supports records management and litigation requirements including capability to identify, retrieve and retain records for as long as needed. Those HHS OPDIVs not implementing “My Work Place” are required to ensure their platforms meet the minimum requirements outlined for “My Work Place.” To further enhance management of emails, the Department Record Officer is working with the Department’s Information Technology office to explore/create additional RM automation tools and functionality to assist users with management of Email.
2. The Department will meet the directive for all paper and non-electronic records to be identified, and to create and submit record schedules to the National Archives by December 31, 2016. The Department’s OPDIVs began inventory of records in 2013 and all have either submitted schedules for records they identified or they are in the process of submitting the remaining schedules to the National Archives.

Data Standardization

At OMB’s request, HHS is leading a research project on the standardization of data elements and data element definitions for the Federal grants lifecycle. HHS initiated the project by examining over 1,100 individual data elements and their associated definitions using a set of 17 individual data sources. Key leaders in the grants community who worked on the development of information collections through the framework of the Grants Policy Council (GPC) and Grants Executive Board (GEB) were interviewed, and GPC documentation reviewed and analyzed line-by-line.

Though data standards exist throughout the financial assistance community, they are not always consistently defined or used across Federal agencies. This lack of consistent implementation of standards results in duplicative infrastructure within and among both Federal agencies and recipients, and creates challenges to the assurance of high quality publicly shared financial data. The goal of the financial assistance administrative data standardization initiative is that every set of approved data elements will have the same meaning across the grants administration lifecycle – from pre-award activities through to post award reporting, for the whole Federal government.  As grants data standards are developed, data quality gaps may be identified in systems like the CFDA and USA Spending.gov.  Establishment of these standards and ultimately remediation of gaps in systems will foster improved data quality for all federal financial data associated with financial assistance awards.  Implementation of these standards will also result in reduced administrative burden on recipients, who will be able to collect, store, and report consistently defined data more efficiently throughout the lifecycle of an award. The intended result of this effort is a set of approved data elements that will have the same meaning across the grants administration lifecycle – from pre-award activities through to post award reporting, for use by all federal grant making agencies.  The goal of this initiative is that every set of approved data elements will have the same meaning across the grants administration lifecycle – from pre-award activities through to post award reporting, for the whole Federal government.

On May 9, 2014, President Obama signed the Digital Accountability and Transparency Act of 2014 (DATA Act) into law. The purpose of the DATA Act is to expand the current reporting requirements of the Federal Funding Accountability and Transparency Act (FFATA) by establishing government-wide financial data standards and increasing the availability, accuracy, and usefulness of federal spending information. In order to meet this goal, the DATA Act requires agencies to report additional information on federal spending. Once available, this detailed data could serve as a tool for better oversight, management decision-making, and innovation inside and outside of the federal government. When implemented, the DATA Act will provide the opportunity to better understand how federal programs and investments can improve the lives of the American public and make program delivery more effective.

Subsequent to the passing of the DATA Act, the United States Department of Health and Human Services (HHS) was designated by the Office of Management and Budget (OMB) as the executing agent of the Grants portion of the pilot required under Section 5 of the DATA Act. In this role, HHS is tasked with establishing and reporting the results of a pilot program that targets the reduction of burden in federal grant recipient reporting.

While HHS demonstrated its commitment to reporting transparency since the inception of FFATA, we recognize the significance and complexity of implementing the DATA Act requirements and our role serving as OMB’s executing agent for the grants Section 5 Pilot. In October 2014, HHS established a DATA Act Program Management Office (DAP) to ensure successful implementation of the requirements contained within the statute and to lead all efforts in the execution of the grants Section 5 Pilot.

For the purposes of HHS implementation, DAP serves to provide as a cohesive agent between the four business communities within HHS that are critical to implementation, those being; budget, finance, financial assistance, and procurement.  In accordance with OMB/Treasury guidance and to better enable the efforts of the DAP, HHS designated a Senior Accountable Official (SAO) with the ability to coordinate activities across these communities. The actions taken provide the organizational groundwork necessary to fully engage HHS stakeholders through regular working group sessions and strategy meetings. To date this approach has performed department-wide inventories of cross-community systems, facilitated a common understanding of the data standards, and communicated reporting requirements germane to the DATA Act.

With transparency in mind DAP shares government–wide standards and their perceived impacts on HHS during weekly meetings with critical stakeholders that have institutional knowledge and influence across the four business lines.  These meetings provide a forum to discuss an implementation strategy and allow stakeholders to provide input into the ongoing data standardization process. In turn, these critical leads have mobilized stakeholders within their communities to establish working groups to analyze specific impacts and issues that affect their functional areas. HHS also collaborated extensively as an active member of the Interagency Advisory Committee (IAC) to provide substantive community-specific and cross-cutting feedback to OMB and Treasury in support of government-wide standardization and related policy considerations. Examples of HHS’s existing IAC leadership roles include the Council on Financial Assistance Reform (COFAR), Budget Officers Advisory Council (BOAC), and Award Committee on eGov (ACE) / Financial Assistance Committee on e-Gov (FACE). HHS will maintain its commitment to data transparency within the Department, and share knowledge to ensure effective implementation goals as well as actively promoting the Grants Section 5 Pilot.

HHS designed 6 testing models for the Grants Section 5 Pilot that were approved by OMB.  Under this partnership HHS is developing a technical proof of concept to build a data standards repository.  The Common Data Elements Repository (CDER) Library provides direct benefit to the federal community and the public to facilitate the implementation of the DATA Act. The CDER Library is designed to house standard data elements and associated data element definitions, and makes the common standards available for government-wide use in information collection activities, and visually accessible to the public to increase their own understanding of the information being displayed and collected in support of federal programs.

Additional information on HHS’s DATA Act implementation and Section 5 Grants Pilot activities can be found here: http://www.hhs.gov/about/agencies/asfr/data-act-program-management-office/