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  • Question

    Can I have an IDIQ DD254 awarded to contractors allowing them access to TS//SCI if they do not have a facility to house TS//SCI? If so, can you provide any written guidance?


    Answer

    The reference for this is the National Industrial Security Program (NISPOM) Operating Manual.

    Nowhere in the NISPOM will it say that a Contractor can perform work on a Top Secret (TS) contract without having their own Sensitive Compartmented Information Facility (SCIF).  You must remember, that the Government sets the requirement.  If the Government decides that the contractor will perform the work at their own facility, then they must have a SCIF.  If the Government determines that the place of performance is at a Government facility, it will be stated as such in the Statement of Work (SOW).  In this case, the Government must give them a place to perform the work, this location will be stated in the SOW.  In order to perform on a TS contract on a Government Facility, the Contractor must have a TS Facility Clearance (FCL) and all personnel working on this contract must have SCI eligibility.

     

    Per the NISPOM Chapter 2, Section 1, An FCL is an administrative determination that a company is eligible for access to classified information or award of a classified contract and the contractor will not be afforded access to classified information until the FCL has been granted.   The Contractor will designate which employees will require access to classified information.  Per the NISPOM Chapter 2, Section 2, An employee may be processed for a Personnel Security Clearance  (PCL) when the contractor determines that access is essential in the performance of tasks or services related to the fulfillment of a classified contract.

     

    Bottom line is that the SOW determines where the work is taking place.  If the work is taking place at a Government facility, the contractor does not have to have their own SCIF.

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