Electronic Documents – Processing and Requirements

Refer to: OMS/OD

Sec.

1. PURPOSE.  
   
   The purpose of this circular is to establish the Indian Health Service (IHS) electronic processing requirements for official documents consistent with the Office of Management and Budget (OMB) Memorandum M-23-07, Update to Transition to Electronic Records.
2. BACKGROUND.  
   
   The IHS has internal documents such as Federal Register (FR) Notices, agreements, memorandums, and other types of controlled correspondence that have been kept and processed in a paper format for decades. The usage of a paper records management process and the need to print paper documents for recordkeeping is outdated. All government agencies, including the IHS, must move to incorporate and transition to using electronic documents, and fulfill the Government’s mission of becoming “paperless.” Establishing policy and processes will ensure that the IHS will set the stage for documents to transition to electronic means, and will establish compliance with the OMB Memorandum M-23-07, as well as with the Presidential Directive, Managing Government Records, (76 FR 75421) across the entire agency.
   
   Given the urgency in changing reliance on paper processes, this circular establishes policy for documents that are fully electronic, replacing the old processes of printing correspondence for clearance and signature. This circular sets a process for internal electronic clearances of all documents for publication, clearance, and correspondence for the IHS. Note that this does not include instances when the agency does business outside of the government, and must use paper or “wet signatures.” The IHS must be able to continue its mission in all circumstances, and in order to be efficient, effective, and in compliance with new mandates, the electronic processing of all IHS documents and records must happen immediately.
3. AUTHORITIES.  
   1. OMB Memorandum M-23-07, Transition to Electronic Records
   2. Executive Order 13589 (76 FR 75423)
   3. 36 CFR 1236 - ELECTRONIC RECORDS MANAGEMENT
   On March 24, 2012, the National Archives and Records Administration (NARA) issued M-12-18 mandating that all Federal agencies eliminate paper records and store all Federal Government records electronically; the mandate has been revised since then, most notably in OMB Memorandum M-23-07. As required by subsequent NARA guidelines, the IHS must move to an electronic documentation and processing system by June 30, 2024. Establishing electronic processing reaffirms the NARA efforts to reform and transform the Federal record keeping system.
4. PROCESS.  
   1. Acceptable Document Formats.   All documents processed for approval and clearance must be created and managed electronically. Currently, those include the latest version of Microsoft (MS) Word (.docx) and Portable Document Format (PDF), when available, and given the future of technology, may change. These descriptions will not negate the opportunity to employ newer productivity solutions inclusive of SharePoint workflows or collaboration tools such as Microsoft Teams, but list what is currently in use to clear documents for signature.
   2. Documents requiring a signature (e.g., FR Notices, Indian Health Manual (IHM) Directives, etc.) must be signed using a valid digital signature. Digital signatures (also known as electronic signatures) that are valid and unalterable use encryption to both ensure the content integrity of the electronically transmitted file and uniquely identify the sender. Specifically, the person who signs the document uses their Personal Identity Verification (PIV) card to electronically sign the document. Digital signatures are permitted in MS Word and PDF. The Executive Secretariat Staff (ESS) will provide additional guidance on which document type(s) is preferred.
      
      How to Add Digital Signatures and Encrypt E-mails in Outlook
      
      How to Digitally Sign an Adobe Document Using a PIV Card
      
      Documents must be made 508 compliant if posted to the IHS web page, IHM, or any other public distribution web site. Section 508 of the Rehabilitation Act of 1973, as amended, requires Federal agencies to make their electronic and information technology accessible to people with disabilities.
   3. Types of Documents.   This circular applies to all IHS documents that are reviewed and processed for clearance. This circular does not apply to electronic health records (see IHM Part 3, Chapter 3, “Health Information Management,” for appropriate processing).
   4. Document Signature and Approval.   All documents for signature by the IHS Director or members of senior staff must be uploaded into the Action Tracking System (ATS).
      1. The Accountable Office creates the ATS assignment and prepares the draft document(s).
      2. The Accountable Office will send the draft document(s) for review and input to offices or programs involved via e-mail.
      3. Once the draft is in final draft format, the Accountable Office will upload the document(s) into ATS and assign the ATS assignment to ESS for review.
      4. ESS will review and provide suggested revisions for the Accountable Office’s consideration and assign the ATS assignment back to the Accountable Office.
      5. The Accountable Office adjudicates edits from ESS.
      6. The Accountable Office clears the document(s) with the appropriate office, program, and/or Office of General Council (OGC) using the Clearance Sheet.
      7. Office, program staff, and/or OGC must review the final document(s) and digitally sign the Clearance Sheet reflecting the office, program, and/or OGC concurrence. If there are suggested revisions during this phase, those edits will be incorporated into the final document(s) as necessary. If the edits are minor and do not alter the purpose or context of the document, then no new clearances are needed.
      8. The Accountable Office uploads the final document(s) to ATS and assigns to ESS for final review and clearance. Uploaded document(s) must include:
         1. A clean Microsoft Word document;
         2. Final PDF letterhead for signature; and
         3. Clearance Sheet signed by appropriate program or offices.
      9. ESS will do a final review of the document(s), sign the Clearance Sheet, and reassign the ATS assignment to the Office of the Director (OD).
      10. The OD reviews and signs the document(s), uploads the signed document(s) to ATS, and reassigns the ATS assignment to ESS.
      11. ESS will save the signed document(s) and return the assignment to the Accountable Office in ATS for distribution.
      12. The Accountable Office will transmit the signed document(s) and close the ATS assignment out.
          
          Images of an original official digital signature should not be displayed, especially on a publicly accessible web site. The proper way to indicate an official digital signature for a document on a web site (when there is a requirement that signature be displayed) is the S-signature, a signature inserted between forward slash marks.
          
          HHS Web Policies
          
          The preferred S-signature must consist only of letters, or Arabic numerals, or both, with appropriate spaces and commas, periods, apostrophes, or hyphens for punctuation. The S-signature must be inserted with a first single forward slash mark before, and a second single forward slash mark after, the S-signature (e.g., /Dr. James T. Jones, III/).
5. RECORDS MANAGEMENT.  
   
   Electronic documents should be retained in accordance with these guidelines, but may be retained for longer periods of time as required for program needs, agency policy, or project specific issues. Documents are expected to be in accordance with applicable records schedules and NARA guidelines.
   
   All paper for internal clearances, which include letters, FR Notices, and other types of correspondence are expected to be fully electronic in this transition.
6. SUPERSEDURE.  
   
   None.
7. EFFECTIVE DATE.  
   
   This IHS Circular is effective upon the date of signature.