4.703: Only Shrewd Contractors Survive Going Paperless.
No Mercy for the Unprepared
Let me guess, you’re a contractor or a subcontractor with the U.S. Government and you just read Subpart 4.703, the one that pertains to what records you need to hold onto during and after a contract. Yes, the subpart that says you can have a paperless office. If you think the process of going paperless is going to be easy, you haven’t done your homework. 4.703 states that all contractors must store and be able to quickly supply all records about a contract 3 years after its final payment. This includes: books, documents, accounting procedures and practices, regardless if such items are in written form, computer data, etc. Fortunately, original documents only need to be kept for one year. (I say ‘fortunately’ but I have heard horror stories of companies switching to paperless, shredding everything, and then realizing they were missing invoices for the entire current year… so don’t forget this. You must keep all original documents for one year.)
After the year is up, original paper documents do not need to be maintained or produced if:
- Your process creates and preserves accurate images of the documents
- You have an established procedure for getting your documents into your paperless system and reliably restricting access to them.
- You can find the documents easily.
- There’s an audit trail for your electronic documents: who first saved it into the system and when, any changes made, when they were made and by whom, and whether it was deleted.
So, after reading this, I bet you’re thinking… “Easy! Let’s scan these records onto a SharePoint shared drive and be done with it.” That would be a huge mistake. You can satisfy #1 and maybe #3 if you have your SharePoint search set up right. #2 is not insurmountable if you’re really careful and have a good SharePoint person on staff. But #4 is a real problem.
While you can store images of original documents on SharePoint via PDF thinking no one will change them, you aren’t thinking smart. How many people in your office have Adobe Editor? With just a few clicks, anyone can change an invoice’s amount, change a document’s metadata, or even create an entire new invoice. Do you know how to set up a SharePoint library to keep a permanent audit trail? Who has access to empty the site’s recycle bin? There is no accountability and no way an auditor could know for sure what they are viewing is reliable.
4.703 is not the government’s version of a Catch 22. There is an simple solution to going paperless and being compliant and it’s called an Enterprise Information Management (EIM) system. For small businesses looking for their first EIM system, we often recommend M-Files. It’s easy to use, flexible, intuitive, affordable way for smaller government contractors to comply with contract record retention requirements.
Preserves Accurate Images
Software is one part of a compliant document management system; the more important part is your processes and procedures. We can help you design compliant processes for the way you work, and bake them into the M-Files configuration and workflows. This might include a “hot folder” to pick up documents from your scanner, or an email account that goes directly into M-Files. Granular permissions can be set so that each person has access only to the documents they need for their job, and no others.
Indexing and Access
M-Files’ unique metadata-driven system allows a company to not only go paperless but also folderless. When information is fragmented into different systems it’s difficult to access and combine data. Tell M-Files what you’re saving, and you’ll be able to find it easily.
M-Files maintains a complete, permanent audit trail of every action taken against a document. For each change to a document’s contents, permissions or metadata, M-Files records who made the change, what the change was, and when it was made, and allows a rollback to previous versions. Without administrative privileges, no one can change or delete a document without leaving a trail.
Don’t let extra compliance requirements scare you away from going paperless. Tagence’s team of software engineers, business process improvement specialists and system architects have domain expertise in multiple business areas including finance, logistics, acquisitions and records management. Our consultants and technical staff will work with you to configure M-Files so it is specific to the way your organization works, with your unique document types and workflows in mind, and provide the support and training to ensure a successful implementation and widespread adoption. Please email us at email@example.com any questions you may have about going paperless.