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  • Question

    Is Clinger Cohen Act compliance required for purchasing or paying for cellular services?


    The Clinger – Cohen Act applies to the purchase of cellular service.  See FAR 39.002 Definitions, specifically the following language.

    “National security system” means any telecommunications or information system operated by the United States Government, the function, operation, or use of which --

    (1) Involves intelligence activities;
    (2) Involves cryptologic activities related to national security;
    (3) Involves command and control of military forces;
    (4) Involves equipment that is an integral part of a weapon or weapons system; or
    (5) Is critical to the direct fulfillment of military or intelligence missions. This does not include a system that is to be used for routine administrative and business applications, such as payroll, finance, logistics, and personnel management applications.

    Cellular service would fit under that definition.  Specific language and policies contained in the FAR that derived from the Clinger-Cohen Act can be viewed at this link. Fields/Clinger-Cohen Act.html

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