By Musa Khan, Senior Manager
Records management regulation goes way back. So if your Federal Health agency isn’t clear where current policy came from, where it is now, and what you need to do going forward, there’s probably good reason. Let’s start with a quick trip through history.
Back in the 1950s, Congress deemed federal records worthy of preservation for their informational value. The reason? Federal records document the transaction of public business, including functions, policies, decisions, procedures, operations, and other government activities. Enter the Federal Records Act of 1950 (referred to as “the Act”). The Act established a records life cycle framework for records management programs in federal agencies, from creation to disposition. The Act requires all federal agencies to create and maintain a records management program in collaboration with the National Archives and Records Administration (NARA).
Over the years, numerous regulations have been appended to the Act, including those guiding agencies on how to use innovative technologies and best practices.
Records management in a modern digital landscape
The government recently issued the Office of Management and Budget Directive (OMB) M-19-21, Transition to Electronic Records, requiring all federal agencies to provide permanent and temporary records in electronic format to NARA by the end of 2022. But managing and adapting to the ever-changing landscape of records management in the federal arena requires flexibility, transparency, and consistency. While some agencies have already begun to transition to electronic records, others have found themselves needing support to accomplish this heavy lift. These agencies have reached out to companies like Octo for help.
Any company providing records management support must implement tools, processes, and infrastructure to comply with OMB M-19-21 and NARA’s Federal Electronic Records Modernization Initiative (FERMI). This can make navigating the variety of regulations daunting for both Health agencies and the government contractors that support them, especially while trying to maintain operations from day to day. That’s why Octo created a streamlined, four-phase approach that helps customers move to a comprehensive and sustainable records management strategy that meets the requirements of NARA, as well as other regulations and requirements.
Phase 1: Project Initiation and Needs Assessment
Education is key. We work with our clients to help them understand federal requirements, including the key records management components, to develop roadmap and implement a long-term, sustainable strategy. To identify where an agency needs to be, it must first understand where it is and what federal laws and regulations regarding records management apply in general and electronic records management (ERM) specifically. While the two are entwined, ERM has special requirements that include capture, maintenance and use, disposal, transfer, metadata, and reporting that must be addressed.
With an understanding of the governing laws and regulations, the agency – or Octo on its behalf – assesses what types of records it has and performs a “current state” analysis for records management. The agency also develops “target state” objectives that describe a future approach to records management, identifying gaps and developing a roadmap detailing the path forward for compliant records management.
Phase 2: Technology Assessment
Phase 2 involves a technology assessment, which consists of three key steps:
- An evaluation of the technical requirements needed to implement and manage a fully mature records management strategy,
- Market research and an analysis of alternatives with respect to the detail identified in Phase 1, and
- Selection of the tools that would best suit the records management objective.
To assist customers in selecting the most effective tools for their needs, Octo conducts Records Management Technology Market Research that evaluates and scores vendors on a variety of criteria. Working with our customers, we tailor the evaluation to more heavily weigh the criteria that are the highest priority to the agency. Example criteria evaluated include:
- Email Management: Evaluates a solution’s capability to manage all email electronically or integrate with the preferred email system used by the agency, such as Microsoft Office 365.
- All Records: Assesses a solution’s capability to manage all records electronically. In most instances, where a solution can manage e-mail records, it can also manage all records. However, in many instances, solutions that can manage all records may not also be able to manage e-mail records.
- Gartner and Forrester Scores: Applies this industry analysis as a useful tool to help examine the current market for an agency’s requirements. Both Gartner and Forrester perform analyses of enterprise content management and enterprise information archiving software solutions. We apply a score for each vendor based on its placement in each publication.
- Agency Owned: Assigns a score to vendors based on whether their solution currently resides within an agency’s technology stack, recognizing that total cost of ownership is important to agencies and existing tools streamline implementation.
Octo then assigns a total score across all categories and makes recommendations for which tools would best meet our client’s needs. Using this scoring system, we create a “Top Ten” list that takes the guesswork out of our client’s hands and arms them with information to make decisions on how to proceed.
Phase 3: Develop Records Management Strategy
During Phase 3, the agency uses the information gathered in the first two phases to make decisions regarding retention and disposition schedules, records management custodian training, handling and/or transition of legacy records, and governance policies. Once these decisions are made, we recommend the agency creates an Organizational Change Management Plan (OCM) to manage the evolving processes, functions, and the resources impacted within the organization by the transition. Additionally, the OMP captures new processes for use in training current and future employees.
Phase 4: Implement Records Management Strategy
The implementation phase involves standing up the technical architecture required to support is records management processes. This process includes testing and deploying the new system(s) for both new records and transitioning legacy records, employee training, and making any corrective actions necessary.
ERM in Federal Health
As a leading provider of health solutions for federal customers, Octo has a wealth of experience in health digital modernization and implementing electronic records systems, cybersecurity, and other health services. Our team secure solutions to improve public health include the following:
Covid Digital Pathology Repository (COVID-DPR) – Octo partnered with Indica Labs, a leading provider of computational pathology software, to deploy a repository solution that collects resolution microscopic COVID-related human tissue images hosted at the National Institutes of Health. Scientists and medical practitioners will use the slide images, annotations, and metadata in the repository as a reference dataset for education, research, and future clinical trials aimed at further understanding patterns of infection, disease, and death.
Light Application for Veteran’s Administration Augmented Reality (LAVAAR) – Octo deployed LAVAAR, which leverages Application Programming Interfaces (APIs) to retrieve patient images from digital medical record systems and use them as visual aids for medical educators.
Caregiver Records Management Application CARMA – Octo partnered with Acumen and the Department of Veterans Affairs (VA) to develop the (CARMA) which serves veterans and their families. The CARMA application provides the ability to create an electronic health record with the click of a button so that Caregiver Support Coordinators can document their clinical interactions more easily and efficiently.
How to Learn More about ERM Compliance
Electronic records management does not have to be overwhelming. Let us help you navigate the ERM compliance maze. Reach out to one of our specialists to talk about your specific needs and goals.