Is the DD-254 on the follow-on contract enough to close this closeout checklist item (disposition of classified)?
The short answer is that you will need to follow the procedures outlined in FAR Part 4.804 (Closeout by the office administering the contract), DD Form 1594 (Contract Completion Statement) and DD Form 1597 (Contract Close-out Checklist), comply with your agency's procedures as listed in the DCMA Contract Closeout Guidebook (guidebook.dcma.mil/17/ContractCloseoutGuidebook.htm), and finally check with your contracting officer and security manager to see if the DD-254 on the follow-on contract is enough to close this closeout checklist item.
Open full Question Details
In reference to the DD 254 and Disposition of Classified Material, the DCMA Contract Closeout Guidebook clearly states that, "all classified documents must be dispositioned IAW government security regulations and accounted for by the contractor. This can be accomplished when a final DD Form 254, DoD Contract Security Classification Specification, is issued, indicating disposition, or the contractor provides written certification that all data has been properly processed. (See DODD 5220.22-M, National Industrial Security Program Operating Manual about disposition and retention). Be sure the prime contractor has cleared all subcontracting DD 254s. Upon physical completion of a contract, a copy of the DD Form 1593, marked "Information Copy" is sent to cognizant Industrial Security Office. The cognizant Industrial Security Office can be found on the contract DD 254. The ACO does not need confirmation or certification of completed actions from the security office to proceed with closeout."
So based on the above, it does not appear that the DD-254 on the follow-on contract alone would be sufficient enough to meet your agency's own DD 254 and Disposition of Classified Material closeout requirements. Since we do not have all of the facts particular to your contract, program, and situation, we highly recommend that you consult with your contracting officer, security manager, and Legal Office for further guidance.