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AIMD-95-26R 1 (1994-11-10)

handle is hein.gao/gaocrptaanq0001 and id is 1 raw text is: United States General Accounting Office Washington, D.C. 20548 Accounting and Information Management Division B-259207 November 10, 1994 Mr. Edwin L. Manky, Jr. Director, Support Services Defense Finance and Accounting Service DFAS-DE/W Denver, CO 80279-8000 Dear Mr. Manky: This letter responds to your request for our views on whether the electronic images produced by the Distribution and Retrieval Image-based Value Enhancer System constitute records. It is our understanding that this system is designed to convert finanical records, such as payment vouchers and supporting documentation, into electronic records. After the conversion, the paper documents would be destroyed and the electronic records would become the agency's official records. Traditionally, agencies maintain, on paper or similar physical mediums, many of their financial records that are subject to records retention requirements. We have not previously addressed the use of imaging in creating and maintaining records; however, we believe electronic technology, generally, can be used to process, store, and retrieve data that are currently contained on paper documents when adequate controls have been implemented to ensure data integrity. GAO has long recognized that agency records are not required to be maintained in their original paper-based form. For example, we have found microfilm and similar technologies to be acceptable methods for storing the data on paper documents. In a 1991 Comptroller General decision, 71 Comp. Gen. 109 (1991), which addressed whether government contracts stored electronically rather than on paper satisfied a statutory requirement that a contract be in writing, we stated that electronic technology that allows the data to be examined in human readable form, as on a monitor, stored on electronic media, recalled from storage and reviewed in human readable form, can provide data integrity that is equal to that of a paper document. We also noted that although electronic documents are stored in a different manner than paper documents, they ultimately take the form of visual symbols. As stated in that decision, we believe that it is sensible to interpret federal law in a manner to accommodate technological advancements unless the law by its own terms expressly precludes such an interpretation, or sound public policy reasons exist to do otherwise. We are not aware of any law or public GAO/AIMD-95-26R Electronic Imaging Page 1

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