NARA's request for comments on the ERM Federal Integrated Business Framework closes August 15, 2025. If you've never participated in a federal standards review, you might assume your input won't matter or that the process is too complex. That's not the case.
Federal agencies rely on this framework to build their electronic records management systems. When NARA updates terminology or redefines standard data elements, those changes affect procurement specifications, system requirements, and compliance audits across the federal sector. Private-sector organizations that work with federal agencies often align their practices to these standards for easier interoperability.
This guide walks you through submitting feedback that NARA's Requirements Working Group will consider.
What You Need Before Starting
Familiarity with the current framework. Download the ERM Federal Integrated Business Framework from NARA's website. Focus on sections relevant to your work: standard data elements if you design systems, terminology if you write policies, and functional requirements if you manage implementations.
Specific examples from your environment. NARA has removed terms that only it uses and don't need agency tracking. Your feedback is more valuable when you can point to a specific scenario where the current framework causes issues. Instead of saying "the terminology is confusing," specify "our procurement team can't map 'digital records' to our existing Records Control Schedule categories because the framework doesn't clarify whether scanned paper falls under digital or physical."
A regulations.gov account. Submit your feedback through the federal rulemaking portal. Create your account now at regulations.gov. Use your work email if commenting on behalf of your organization, or your personal email if submitting as an individual.
Organizational clearance if required. If you work for a federal agency or a contractor with communication policies, check if you need approval before submitting public comments. Some organizations require legal review for any official feedback on proposed standards.
Step-by-Step Implementation
Step 1: Identify your highest-impact issue. NARA's review focuses on terminology updates and standard data elements for shared services. Choose one specific problem you've encountered in either category. It's more effective to address one issue thoroughly than to scatter comments across multiple topics.
For terminology: Look for terms that create ambiguity in your Records and Information Management program. NARA clarified language around digital records, but does that resolve your classification questions?
For standard data elements: NARA narrowed the list to what shared services actually need. If you operate or use a shared records management service, which elements are missing? Which included elements don't align with how your systems track records?
Step 2: Draft your comment in a text editor. Don't compose directly in the regulations.gov form. Write in a document where you can edit, get feedback from colleagues, and save a copy for your records.
Structure your comment:
- Opening statement: Identify yourself (role, organization type, years of experience) and state your specific concern.
- Evidence: Describe the operational problem. Include system names if relevant, but focus on the requirement gap, not vendor complaints.
- Proposed solution: Tell NARA exactly what change would resolve the issue. If you want a term added, provide a definition. If you want a data element modified, specify the new scope.
- Impact assessment: Explain who else this affects. If you're a contractor, note how the change would improve federal agency compliance. If you're an agency records officer, explain how the change would reduce audit findings.
Keep it under 500 words. NARA's Requirements Working Group reviews every submission. Concise, specific comments get more attention than sprawling critiques.
Step 3: Submit through regulations.gov. Navigate to regulations.gov and search for the ERM Federal Integrated Business Framework docket. You'll find it under NARA's agency listings. The docket number should reference the 2025 review cycle.
Click "Comment" and paste your draft into the comment field. You can attach supporting documents (screenshots, policy excerpts, data models), but the comment field itself must contain your core argument. Reviewers read the comment first and only open attachments if the comment warrants deeper investigation.
Before you submit, confirm your contact information is correct. NARA occasionally follows up with commenters to clarify technical points.
Step 4: Share the docket with your professional network. NARA explicitly asked stakeholders to share widely. Post the regulations.gov link in your ARMA chapter, your legal operations Slack, your industry association forum. The more practitioners submit feedback, the more NARA understands which issues affect the broader community versus isolated edge cases.
Don't coordinate identical comments. NARA counts unique perspectives, not petition signatures. If five people from different organizations independently raise the same terminology gap, that signals a systemic problem.
Validation: How to Verify It Works
Immediate confirmation: After you submit, regulations.gov displays a tracking number. Save it. You'll receive an email confirmation at the address you provided. If you don't get that email within 24 hours, check your spam folder and resubmit if necessary.
Public record check: Wait 48 hours, then search the docket again. Your comment should appear in the public record. If it doesn't, contact regulations.gov support with your tracking number.
NARA's response timeline: NARA will publish a summary of comments received and their disposition after the August 15 deadline. This typically happens 60-90 days post-closure. Watch NARA's records management blog and the FERMI updates page for the analysis.
Framework updates: If NARA incorporates your feedback, you'll see the change in the next published version of the ERM Federal Integrated Business Framework. NARA usually credits comment themes in their revision notes, though they don't attribute specific commenters by name.
Maintenance and Ongoing Tasks
Monitor the Business Standards Council calendar. NARA conducts this review annually as required by the Council. Mark your calendar for next year's cycle. If your first comment doesn't result in changes, you can refine and resubmit.
Track how the framework affects your procurement. When you write RFPs for records management systems, reference the ERM Federal Integrated Business Framework explicitly. Require vendors to map their data models to the standard elements. This creates a feedback loop: you'll quickly discover which parts of the framework work in practice and which create vendor confusion.
Join the Requirements Working Group if eligible. NARA consults an interagency working group for these reviews. If you work for a federal agency, ask your CIO or records officer how to participate. Working group members shape the framework before it goes to public comment.
Document your implementation gaps. Keep a running log of moments when the framework doesn't match your operational reality. When next year's comment period opens, you'll have a year's worth of evidence ready to submit.
The August 15 deadline is firm. If you've been waiting for someone else to raise your issue, they're waiting for you.
