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    Does the Contracting Officer who signs DD Form 254 would need to hold a clearance level equivalent to the clearance shown on the DD Form 254?


    Applicable references: FAR 4.403 (c)(1) "...The contracting officer, or authorized agency representative, is the approving official for the DD Form 254 associated with the prime contract and shall ensure the DD Form 254 is properly prepared, distributed by and coordinated with requirements and security personnel in accordance with agency procedures, see 4.402(d)(1)."

    DFARS PGI 204.403 Responsibilities of contracting officers.

    (1) Consistent with the requirements at FAR Subpart 4.403, contracting officers shall ensure that solicitations, to include any Broad Agency Announcement (BAA) or notice to industry, that requires industry access to classified information and/or controlled unclassified information (see policy memos), shall contain one or more of the following:

    (i) Draft DoD Form DD 254, DoD Contract Security Classification Specification.

    See Defense Security Service (DSS) guide for the preparation of the DD Form 254 at and select “A Guide for the Preparation of a DD Form 254”.

    Bottom line: Based on my research, nothing in the FAR or DFARS requires the contracting officer to have a clearance at the same level that's shown in the DD Form 254.  For additional information about completing the DD Form 254, you can review the Guide for Preparation of a DD Form 254 or call the DCSA Knowledge Center at 888-282-7682.


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