What are the steps to apply records cutoff and trigger disposition under a federal retention schedule?

In federal recordkeeping, a retention schedule controls how long records are kept and what happens to them afterward. Two linked concepts make a schedule operate: the cutoff, which closes a file so its retention clock can start, and the disposition, which is the final action—destruction or transfer to the National Archives—once retention is met. The schedule itself must be approved by the National Archives (NARA) before any disposition occurs.

Steps to Apply Cutoff and Trigger Disposition

1. Identify the records and the schedule. Determine which approved schedule item—often a General Records Schedule (GRS) item or an agency-specific schedule—applies to the record series. The item defines the retention period and the eventual disposition action.

2. Apply the cutoff. Close the file at the end of a defined period (commonly the end of a fiscal or calendar year, or when a case or transaction completes). Cutoff separates active records from those whose retention period can begin counting.

3. Start the retention clock. After cutoff, calculate the retention period stated in the schedule. The period generally runs from the cutoff date, not from each record’s creation date.

4. Hold records during retention. Maintain the records in a secure, accessible system until retention is satisfied. Do not dispose of anything while it is needed for ongoing business.

5. Check for holds and restrictions. Before any disposition, confirm there is no litigation hold, freeze, audit, investigation, or open FOIA/Privacy Act request that requires continued preservation. A legal hold always overrides a schedule.

6. Execute the disposition. When retention is met and no hold applies, carry out the scheduled action—authorized destruction for temporary records, or transfer of permanent records to NARA in the required format.

7. Document the action. Record what was disposed of, when, under which schedule authority, and by whom. This audit trail demonstrates that disposition was authorized and properly performed.

Key Principles

• Never destroy federal records without an approved schedule authorizing it.
• Legal holds suspend disposition for affected records until released.
• Apply the process consistently and document it so actions are defensible.

For broader context on agency schedules, authorities, and related guidance, see the federal records topic hub.