ISP Preparation Series 1 – Chapter 7

NISPOM Chapter 7 – Subcontracting Acronyms CSCS:Contract Security Classification Specification (DD Form 254) CSA:Cognizant Security Agency (DoD, DoE, CIA & NRC) GCA:Government Contracting Activity General (7-100) Outlines responsibilities of prime contractor when disclosing classified to a subcontractor Responsibilities (7-101) Prior to disclosing classified to a sub -or- allowing sub to generate classified:  Determine the security requirements of subcontract 1) Access to classified information WILL be required Sub must possess an appropriate FCL & safeguard capability (if possession required) Pre-award phase: a) If access NOT required, subs do not have to possess an FCL to receive or bid b) If access WILL be required, subs must possess FCL & safeguard capability ©2007 SCRA®. All Rights Reserved. 2 Version May 2007

NISPOM Chapter 7 – Subcontracting ISL #6 (7-101):  Fundamental requirement for FCL Sponsorship is that contractor must require access to classified information  Cannot request to clear a company just to avoid implementing security procedures that would prevent access to classified (escort by an authorized person combined with area sanitization, etc) ©2007 SCRA®. All Rights Reserved. 3 Version May 2007

 Determine the security requirements of subcontract (continued) 2) If access to classified information will NOT be required:  If sensitive but unclassified is released/disclosed, requirements will be incorporated in solicitation of subcontract  Contractor must determine clearance status of prospective subs If prospective sub does NOT have appropriate FCL or safeguarding capability – prime must make request to CSA (FCL letter) to initiate necessary action: -Requester must include: name, address, contact info -Contact at facility must include: name, address, contact info, level of clearance and full justification for request If FCL cannot be granted in time to qualify sub for participation, CSA will continue FCL processing action for future qualification, provided: -Delay was NOT caused by lack of cooperation by sub -Future classified negotiations may occur w/in 12 months; and -Reasonable likelihood the sub may be awarded a classified contract ©2007 SCRA®. All Rights Reserved. 4 Version May 2007 NISPOM Chapter 7 – Subcontracting

Security Classification Guidance (7-102)  CSCS (DD Form 254) must be incorporated in each classified subcontract Must be certified by a designated official of prime contract Must NOT contain classified Sub must generate separate correspondence if classified supplements are required as part of 254 a) Original 254 must be included w/each RFP, RFQ, etc. (so that sub is aware of security requirements and can plan accordingly) b) Revised 254 must be issued when security requirements change c) Requests for public release by sub must be forwarded through prime to the GCA Responsibilities – Completion of Subcontract (7-103)  Sub may retain classified (received or generated under the subcontract) for 2 years  If retention needed for >2 years, sub must request authority through prime to GCA ©2007 SCRA®. All Rights Reserved. 5 Version May 2007 NISPOM Chapter 7 – Subcontracting

Notification of Unsatisfactory Conditions (7-104)  CSA will notify prime if it discovers unsatisfactory security the sub’s facility  Prime must then follow instructions by CSA for corrective action, if deemed necessary ©2007 SCRA®. All Rights Reserved. 6 Version May 2007 NISPOM Chapter 7 – Subcontracting