Entities (including companies and academic institutions) engaged in providing goods or services to the U.S. government involving access to or creation of classified information may be granted a Facility Clearance (FCL). Mandated by the guidelines set forth in the National Industrial Security Program (NISP), the Defense Counterintelligence and Security Agency (DCSA) processes, issues, and monitors the continued eligibility of entities for an FCL.
After a determination by DCSA that an entity has a legitimate need for access to classified information in connection with a U.S. Government or foreign government requirement, an entity may be sponsored for an FCL. All FCL sponsorship requests are submitted through the National Industrial Security System (NISS), the DCSA system of record for NISP. Submission of all FCL requests, change of conditions, clearance verifications or self-inspection certifications to NISS here.
Once a facility is cleared, DCSA has oversight authority to evaluate the security operations of the organization. The DCSA Industrial Security Representative (ISR) is the principal interface with cleared industry under the NISP. These individuals, spread across the United States in five geographic regions and 167 field locations, work in a professional partnership with the contractor's facility management staff and facility security officer to ensure the protection of classified information released under contractual obligations or research and development efforts.
To get started with the FCL process, please see the following checklist for cleared contractors, U.S. Government Contracting Activites, and U.S. Prime Contractors. Reviewing this information will help you avoid many of the common errors that delay FCL packages.
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Incomplete and inaccurate facility sponsorship packages will be rejected, which will cause delays in obtaining a FCL. For all FCL related questions or status updates on your FCL sponsorship submission, contact the DCSA Knowledge Center at 888-282-7682, Option #3.
Additionally, you will need to obtain a Commercial and Government Entity Code (CAGE Code). DCSA uses CAGE Codes to track basic facility information. If your company does not already have a CAGE Code, contractors can register with the System for Award Management (SAM) database to get a CAGE Code at https://www.sam.gov, or at DLA at cage.dla.mil. If a company does not have a CAGE code prior to initiation of the FCL process, significant delays or discontinuation of the process could occur.
Checklist for a Facility Clearance
Any facility awarded a classified contract, as the prime or subcontractor, must hold an active FCL in order to perform on the classified requirements. Also, a facility may require an FCL during the solicitation phase ONLY if access to classified information is necessary during this phase. If the facility does not hold an active FCL at the appropriate level, the facility must be sponsored for the FCL or FCL upgrade. Contractors cannot sponsor themselves for an FCL.
A contracting facility must be sponsored for an FCL by either a government contracting activity (GCA) or another cleared defense contracting company. The sponsorship is initiated in NISS through a system generated fill-in-the-blank FCL sponsorship request form. This feature includes the ability to upload the required documentation for the sponsorship request (DD254, Statement of Work/Performance Work Statement, GCA authorization, etc.).
|DCSA Begins the Process
||The sponsorship request will be reviewed by the DCSA Facility Clearance Branch and either rejected with an explanation detailing why the sponsorship request was unacceptable, or accepted and the facility placed in-process. Once the sponsorship request is accepted in NISS, the system will send a Welcome Email to the facility point of contact identified in the sponsorship request. The Welcome Email, FCL Orientation Handbook, and FCL Orientation Videos contain detailed information about the process, responsibilities, and critical deadlines. It is very important that contractors read and follow the instructions
View the FCL Orientation Videos
Contractors are encouraged to view the FCL Orientation Videos as often as necessary to gain an understanding of all requirements for both contractors and DCSA in this process. These videos were designed to provide all of the information contractors require to be successful in navigating the FCL process. After thoroughly reviewing the videos and all sections applicable to your company, there are still remaining questions or concerns, please contact the DCSA Knowledge Center (KC) at 888-282-7682, Option 3. Please note the FCB KC staff will ask if the videos were reviewed prior to calling. The FCL Orientation Videos along with the FCL Orientation Handbook are valuable resources and information for the company to utilize while going through this process and afterwards.
|Commercial and Government Entity Code (CAGE Code)
||DCSA uses CAGE Codes to track basic facility information. If your company does not already have a CAGE Code, contractors can register with the System for Award Management (SAM) database to get a CAGE Code at https://www.sam.gov/. If a company does not have a CAGE code prior to initiation of the FCL process, significant delays or discontinuation of the process could occur.
Preparation for Submitting Business Governance Documents
Contractors are encouraged to review and start gathering the legal business documentation. A list of required forms and documents is available in the FCL Orientation Handbook, Section 5.0. Please begin a preliminary identification of the Key Management Personnel (KMP) for the company. KMPs are discussed in detail in the FCL Orientation Handbook, Appendix A. Certain KMP are required to be cleared in connection with the facility clearance (FCL) which is determined by the legal structure of the company.
Please note that DCSA will make the final determination of which KMPs are required to be cleared in connection with the FCL based upon roles, responsibilities and authorities of key positions outlined in the governance documents. To streamline the process, any KMP believed to require the PCL in connect with the FCL may begin collecting information pertaining to their background investigation paperwork. The "SF 86, Questionnaire for National Security Positions" form is available for review and download on the OPM.gov website. Please be aware, DCSA requires proof of US citizenship for any KMP in process for a background investigation. Business governance documents along with other required documents and forms are due by Day 20 of this process, (See Section 5.0 in the FCL Orientation Handbook). This date is provided in the Welcome Email and does not exclude weekends or holidays.
Please begin researching the best method for the KMPs to obtain electronic fingerprints. There are many ways to submit the electronic fingerprints and details are provided in the e-QIP and Electronic Fingerprint Guide for In-Process Facilities. The KMP investigation request submission and electronic fingerprints are due by Day 45 of this process. This date is provided in the Welcome Email and does not exclude weekends or holidays.
Prepare for a DCSA visit
Download the National Industrial Security Program Operating Manual (NISPOM), which is available on the DCSA website. Becoming familiar with the NISPOM takes a great deal of time and determined effort. There are many resources available to assist with this effort. The Security Toolkits are located here, and provide information on a variety of topics including the required training for the FSO and the ITPSO. The FSO and ITPSO are encouraged to begin taking these courses.
DCSA Facility Process Forms
Certain forms are required as part of the facility clearance process. The DD Form 441 and the SF 328 are two of these forms. Please visit the Facility Clearance Toolkit for links to these forms. If you are a branch or division office, please complete the addendum to the DD 441, called the DD Form 441-1. To exclude parent companies or certain KMPs, please complete exclusion resolutions. Examples of these are in the FCL Orientation Handbook. When completing the DD Form 441, please do not enter the date at the top of page 1. DCSA will enter the date once the FCL is issued. Please also enter the company name on page 2 of the DD Form 441 on the line 'Typed Name of Contactor Entering Agreement.' In addition, a FSO Appointment letter as well as an ITPSO Appointment letter is also required. Also, please include whether the individual in the position is a US citizen and employee of the company; and indicate the FSO Appointment date within the KMP entry for the FSO.
Frequently Asked Questions:
- How long does the FCL process take?
Answer: DCSA is unable to provide a timeline due to many variables, including but not limited to responsiveness of facilities in providing the required information by the deadline dates. In addition, it also depends upon receipt of accurate and complete information.
- What are the reasons for my FCL sponsorship being rejected?
Answer: The most frequent reasons for rejecting a sponsorship are due to lack of attention to detail and/or no valid need to access classified information. Ensuring the sponsorship is accurate and complete, with no discrepant information and the DD254 is complete with a clear justification for access to classified information will help move the process along. Please review the DD-254 Instruction Guide for assistance in completing the form. In addition, there are cases where processing is discontinued as it is identified that the contract performance does not require access to classified information. These are cases where investigations are required for IT Level access, suitability, or base access where a sponsorship is submitted. In those cases an FCL is not required and the investigations are the responsibility for submission and management by the government activity.
- Can we get a FCL during the solicitation phase?
Answer: DCSA will process a request for a FCL if access to classified information is required at the pre-award stage. This requirement must be validated by the Government Contracting Activity (GCA) and all the required information is provided, as detailed in DoD Manual 5220.22, Volume 2 National Industrial Security Program: Industrial Security Procedures For Government Activities (Section 6.2.C.3)
- How much does a FCL cost?
Answer: The government funds the processing of personnel clearances (PCL) and facility clearances (FCL) for access to classified information.
- Does a facility clearance expire?
Answer: Facility clearances are valid as long as there is an active classified contract and there is a need to access classified information in performance on the classified contract.
Common Sponsorship Errors:
- There is no clear justification or need for access to classified information in the sponsorship documents. Please ensure your sponsor clearly articulates in the DD254 and sponsorship information what activities or support you will be providing that requires access to classified information.
- Missing Government Contract Activity (GCA) authorization. Certain accesses will require GCA authorization to include intelligence information, etc. In addition, the issuance of a subcontract should have GCA approval.
- Incomplete or discrepant information on the DD254. There is a DD254 instruction guide that should be followed. Ensure the DD254 is complete, accurate and is signed with the appropriate signatures. The link is provided here.
- Discrepant information between the sponsorship and DD254. Please ensure the information on the sponsorship and DD254 aligns. The sponsorship should not request a Top Secret facility clearance while the DD254 indicates a Secret requirement as an example.