Due to the number of independent occupational licensing boards in the state, the regulation, creation, issuance, and maintenance of professional licenses is a function that is performed by one of the highest percentages of State-level entities, second to functions that currently exist on the General Schedule for State Agency Records. As records analysts help agencies crosswalk their existing program schedules to the new functional schedules, it is critical to migrate these records correctly and understand how the Functional Analysis Initiative will affect the retention of these records. This series of blog posts will walk you through the process of matching program schedule items to the new functional schedules.
For Part 1, let’s focus on the process of getting a license from a functional perspective. All licenses start with an application process: applicants submit an application, any supporting documentation, and any fees required. Frequently, if an applicant does not have all the supporting documentation at the time of application, there’s a window of time to complete it without having to resubmit an application fee. If an application is still incomplete after the window has passed, the applicant must restart the process from scratch.
After an application has been completed, it undergoes a reviewing process that may include the applicant taking a professional exam. The Board then approves or denies the application based on its rules for licensure or certification.
Focusing just on the application as it turns into a license, this entire process is supporting the authorization of a person to practice a given profession. Consequently, it is scheduled in the Monitoring and Compliance Functional Schedule, specifically sub-function 2: Authorizing and Licensing.
The excerpt above covers every stage of the application process, from submission to approval. Applications that are fully approved become the core of a license, and are scheduled under RC No. 1324. Applications that do not reach that point are scheduled separately, depending on whether they were withdrawn, left incomplete, or denied by the Board.
TIP: Pay attention to the trigger period!
The functional schedules include far more trigger periods (that is, the time that you should start counting the retention period) than previous schedules. This allows us to provide greater guidance to agencies, and establish consistent retention periods while taking individual agency needs into account. For example, some boards’ application periods expire based on a time frame set up in their statutes. By setting the trigger period for incomplete and denied applications after the point of expiration, agencies with different application windows don’t need separate records series on the schedule.
Now that we’ve reviewed the processes behind applications and licensure, let’s look at a current Program schedule and see how it fits.
As you can see from the excerpted items on the schedule, there are currently records series for both denied applications (Licensure Denial File) and incomplete ones (Incomplete Application File). However, there are also four other items relating to licenses: approved applications for two different types of licenses, a database listing the same information, and an additional master file. Where should these different items go?
The answer to that question lies in the way that the functional schedule works: licenses and permits are scheduled by whether they are subject to renewal, rather than what type of license they are. Agencies with detailed schedules will frequently find multiple items on their program schedule matching with one item on the functional schedule, and this is no exception. Since nursing licenses are subject to renewal, all of these items will fall under RC No. 1324.3. We can now match this schedule excerpt to the functional schedule in this way:
You may have noticed that some of the license files have very different retention periods on the new functional schedule, particularly the ones that are scheduled for storage at the State Records Center. This is a signal to contact your records analyst, so we can ensure that these records are accounted for during the transition. We’ll discuss this in greater detail in Part 2 of this series of posts.