Frequently Asked Questions (FAQs) About Records Management During the COVID-19 Pandemic

NARA RM FAQs 2020-01

Issued: April 23, 2020

Revised: June 15, 2022

This guidance pertains only to Federal agencies and applicable contractors and is binding on agency actions as required by law and similar authority. This guidance does not apply to, and is not meant to bind, the public, except as authorized by law or regulation or as incorporated into a contract.

Records Management Related to Teleworking

How should agencies capture and maintain records created while staff are teleworking during the COVID-19 pandemic?

Employees on telework should continue to manage all records in accordance with their agency policies and procedures. See our FAQ on Telework.

Some teleworking employees may find that they use personal email accounts or other electronic messaging applications, like text messages or messaging apps within social media or video conferencing tools, to communicate for work. Please note the Federal Records Act (44 U.S.C. 2911) requires Federal employees who use non-official electronic messaging accounts to copy their electronic messages to an official account or forward a copy to an official account within 20 days.  If messages have a retention of lessthan 20 days, they do not need to be copied or forwarded. 

If an agency is using Microsoft Teams, Skype for Business, Zoom, or another video conferencing platform to communicate with one another, do these tools need to be scheduled?

Many agency meetings, seminars, training sessions, and other events have moved to a virtual environment. Agencies should continue to manage the records created with these tools as they would have had the meetings been held with the same technology while in the office. Teleconferencing tools are much like social media platforms. These are software and technology solutions for communications that do not require a records schedule.  The records created by these tools need to be managed. 

If employees print at home, are those printouts Federal records?

Agencies should consider the implications of allowing printing at home, including from a records management, FOIA, and information security perspective. If printouts contain unique information, including handwritten notes, they may need to be managed separately from electronic files that lack this information. Agencies should review GRS 5.2 and provide instructions to employees on when these printouts may be transitory or intermediary records or when another records schedule may apply. 

Records Retention

Does the GRS cover employee medical records related to COVID-19?

Agencies have two options in GRS 2.7, Employee Health and Safety Records, for managing employee medical records related to COVID-19 using the GRS: 

• Option 1 is using the disposition authorities for vaccination attestations and proof of vaccination records for federal employees and contractors (item 063) and symptom screening and testing records for federal employees (item 065). 
• Option 2 is filing these records in official employee medical files (Occupational individual medical case files, items 060-062).

Are records related to agency response to COVID-19 covered by the GRS?

It is unlikely that any records related to an agency’s response to the COVID-19 pandemic are covered by the GRS. GRS 5.3, Continuity and Emergency Planning Records, covers continuity and emergency planning records, but not records related to response to an actual emergency situation, such as a pandemic.  Records related to specific incidents must be scheduled on agency-specific schedules. Agencies should look at their existing authorities related to incident response to see if they can be applied to records related to their response to COVID-19. If agencies do not have approved disposition authority for incident response records, these records would need to be scheduled.

In regard to COVID-19 internal emergency planning records, the GRS indicates that plans that are acted upon in the event of a national emergency may be of permanent value. Agencies may request to schedule these records as permanent. (See GRS 5.3, item 010, Note 1). This does not mean that all internal emergency plans related to COVID-19 are permanent, only that NARA will consider schedules from agencies that believe these plans should be permanent.

Will NARA be issuing a General Records Schedule (GRS) to cover COVID-19 records?

NARA is not planning to issue a new GRS specifically for COVID-19 records. In March 2022, we issued a revised GRS 2.7, Employee Health and Safety Records, that added disposition authorities for vaccine attestations and proof of vaccination records, as well as symptom screening and testing records. We believe these new authorities will meet the needs of most agencies. If your agency has other types of pandemic-related records that you think should be covered by the GRS, please contact [email protected] so that we can consider further expansion of the GRS. 

Can agencies apply their disposition authorities for disaster response, incident response, or pandemics to records related to responding to COVID-19? Does it require a modification to the schedule?

Yes, agencies may apply disposition authorities for records related to disaster response, incident response, or pandemics to records related to their COVID-19 response. However, if those disposition authorities apply only to records related to a specific incident, such as the Hurricane Katrina response, you cannot apply them to COVID-19 response records. If the disposition authorities are written to apply generally to such incidents, there should be no need to specify application to COVID-19. If you have questions about whether your agency’s authority may be applied to COVID-19 response records, please contact your agency’s assigned NARA appraisal archivist.

If your agency does not have a disposition authority for disaster, incident, or pandemic response, then you will need to schedule records related to response to COVID-19.

Are records related to COVID-19 permanent?

It depends. NARA expects that records documenting the significant actions of Federal officials related to the pandemic often will be captured based on existing approved schedule items. Some may be permanent; some may be temporary. However, since this emergency may create new offices or add significantly new or increased levels of responsibility specific to the pandemic, agencies should be prepared to evaluate their records for their operational or historical significance. If new records are created in response to the pandemic that are not specifically scheduled, a new schedule would need to be proposed and approved to cover such records. With the extent of the government-wide response, each agency will need to evaluate the enduring value of the records they create specific to this crisis, as has occurred in the aftermath of large-scale natural disasters in recent memory. This evaluation would highlight any need for new or updated schedules.

Please contact your NARA appraisal archivist for further assistance.

With the scale of COVID-19, will agencies need to keep employee health records and agency response and planning records longer than they are currently scheduled?

Generally, the retention schedule of any record takes into account future business needs as well as the potential for use in litigation or to seek benefits. However, after the current public health crisis subsides, agencies should work with their internal stakeholders, including their Office of General Counsel (OGC), to determine if the records warrant re-appraisal. 

Should records related to COVID-19 be kept in case of possible litigation?

Records officers should be in communication with their agency’s OGC to determine if any records are needed for current or the reasonable likelihood of litigation. Agencies should have internal policies in place regarding issuing of litigation holds, if that is necessary. NARA does not recommend retaining records “just in case” of litigation. This can result in retention of records long after the need for them has passed as well as a lack of clarity over why they were retained and who has the authority to dispose of them. Rather, litigation holds should be implemented in accordance with the Federal Rules of Civil Procedure, agency policies, and guidance from the Department of Justice. 

Who should agencies contact for additional information?

For additional assistance contact your NARA appraisal archivist. For questions specifically related to the application of the General Records Schedules (GRS), please contact [email protected].