NAVAL COMMAND, CONTROL AND OCEAN SURVEILLANCE CENTER
Research, Development, Test, and Evaluation Division
San Diego, California 92152-5000
SDSOP NO. 31
02214/MP
29 Jun 94
From: Head, Contracts, Code 0221, Head, Security, Code 035
To: All Codes
Subj: GUIDANCE FOR CONTRACTUAL SECURITY MATTERS
Ref: (a) NOSCINST 5500.1, Security Manual
Encl:
PURPOSE: The purpose of this guideline is to assist Contracting and Technical personnel in the process of contractual security matters. For formal guidance, see NOSCINST 5500.1(series) Security Manual, or Code 0353.
REQUIREMENTS: Following are the basic requirements for specific topics:
(1) DD FORM 254:
(a) A DD Form 254 is required when a procurement package (either pre or post award) requires access to, or generation of, classified information by a contractor.
(b) A DD Form 254 is NOT required for contractors working at NRaD who do NOT have access to any classified information. Caution must be exercised in this case. If the work to be done is within a space containing openly stored classified information, and the space can't be sanitized of all classified information, then the contract will have to include a DD Form 254 because escorting contract personnel will not preclude access to classified information.
(c) A Final DD Form 254 is created by the Contracting Officers Representative or Technical Assistant (COR/TA), following receipt of a written request from a contractor to retain information created on a completed contract, and given to the Contracting Officer for approval.
(d) Approval of DD Form 254: A DD Form 254 may only be approved by the NRaD Contracting Officer for Security Matters (COSM) of Code 0353 (with the exception of the Final DD Form 254 which is currently approved by the Procuring Contracting Officer).
(a) A DD Form 254 is required for foreign travel, ONLY when access to U.S. Government classified information is required in the foreign country under the contract. A DD Form 254 is NOT required on a contract, when access will include ONLY UNCLASSIFIED information, or the locations of the travel are Puerto Rico, U.S. Possessions and Trust Territories.
(b) If there is no requirement for classified access while on travel to an overseas site, the COR/TA will complete the Request for Foreign Travel (NRaD 4650/4) to indicate either UNCLASSIFIED or NONE in the blocks 1.L and 1.M.
(3) SUBCONTRACTS:
When subcontractors will have access to classified information, a DD Form 254 is required to be completed by the Prime Contractor. The original DD Form 254 will be given to the Subcontractor, and a copy provided to the NRaD COSM, and to the Contracting Officer for placement in the official contract file.
(4) VERIFICATION OF CLEARANCE: To eliminate duplication of effort and associated costs, between the Contracting Office, Security Office, and the Defense Investigative Service/Central Verification Activity (DIS/CVA), an automated security clearance verification system is available for the Contracts Division. Instructions for this system are provided as enclosure (1) to this document. It is highly encouraged that all contracting personnel utilize the Security Control System (SCS) prior to any further action. Contracting personnel shall NOT issue letters, or telephone DIS. If there is no current record of a company in the SCS, or you are having difficulty with the system you should contact the COSM, via e-mail (userid "COSM" or "Patti") or telephone. The COSM will contact the DIS/CVA to obtain the verification, and update the SCS to include that company for future use.
This system should be used:
-When classified documentation is to be distributed with an RFP, IFB, or RFQ. The Contract Specialist is responsible for ensuring that receiving companies are cleared with the appropriate facility clearance and have proper safeguarding capability.
-To verify a company's facility clearance prior to making an award.
-In any other situation which requires a facility clearance verification.
(5) MISCELLANEOUS ITEMS:
Unclassified to Classified Contracts: Many times Broad Agency Announcements (BAA's), Small Business Innovative Research (SBIR) action's (phase I to Phase II), or other contracting actions that initially did not include requirements for classified access, develop the need to access classified information. In such instances, the following applies:
- The COR/TA shall prepare the DD Form 254.
- The COR/TA shall take the DD Form 254 and a copy of the original contract or purchase order (with all modifications) to the COSM for approval and signature.
- The COSM will then take the approved DD Form 254 to the contract specialist for distribution.
PROCEDURES: Following are the basic procedures for specific topics involved with contractual security matters:
(1) DD FORM 254:
(a) When a DD Form 254 is required for a contractual action, the COR/TA shall prepare the DD Fddorm 254. Guidance is available from the COSM. Additional assistance is provided in the NOSC Securityd Manual, 5500.1(series). On pre-award DD Form 254's for Large Purchases, the Contracting Receptionist area shall be included on page 2, Block 13, and shall read: All requests for information should be directed to the Contract Office, Code 0221, Telephone 619-553-4462; for Small Purchase requirements, the technical point of contact may be included on page 2 of the form. The process for a DD Form 254 is:
(1) The COR/TA will prepare two DD Form 254's at the beginning of the procurement cycle. One DD Form 254 would be for the pre-award action. The second DD Form 254 would be for the award action. This second DD Form 254 would be completed by the contract specialist, after source selection determination, with the contract number, contractor name, CAGE Code, and follow-on information (if applicable). It will then be approved and signed by the COSM. This process is provided to eliminate delays at the time of award due to the COR/TA being on travel or leave.
(2) The COR/TA shall provide the DD Form 254's with the procurement package to the Technical Assistance Office (TAO), Code 02219.
(3) The TAO will forward the procurement package, inclusive of DD Form 254's, to the COSM, Code 0353, for review, correction, and approval.
(4) The COSM, after approval, will then return the package to the TAO.
(5) The TAO, upon completion of the overall review process, will forward the completed procurement package to the cognizant contract specialist.
(b) All revisions and changes to the DD Form 254 must be reviewed and approved by the COSM. No changes should be made to the DD Form 254 by other than the COSM, other than to type in the Contract Number. Unauthorized changes to a DD Form 254 may be considered a security discrepancy.
RESPONSIBILITY: The responsibility for the DD Form 254 is shared by many people. The Contracting Officer, Contract Specialist, Contracting Officer's Representative (COR) and the Contracting Officer for Security Matters (COSM) all share the responsibility for the completion, preparation and use of this form. Following are the basic responsibilities for specific security matters:
Contracting Officer's Representative/Technical Assistant (COR/TA): The COR/TA is responsible for:
-determining classified access and the necessity for a DD Form 254.
-when necessary, preparing a DD Form 254 for all actions.
-As required by DoD 5220.22-M, Industrial Security Manual for Safeguarding Classified Information, reviewing the DD Form 254 every two years and preparing a revised DD Form 254 for the COSM's approval and signature.
-providing the classification guidance listed on the DD Form 254 to the prime contractor.
-ensuring that the DD Form 254 reflects applicable access to classified information overseas.
Contracting Officer for Security Matters (COSM): The COSM is responsible for:
-correcting, approving, and signing the DD Form 254 (with
exception of the Final DD Form 254).
-verifying the facility clearance of the company being awarded the contract at the time the award DD Form 254 is being processed.
-providing assistance to the COR/TA, Contracting Officer, Ordering Officer, and Contractor in matters pertaining to security.
-ensuring that the DD Form 254 grants access, as needed, for contractors on foreign travel for NRaD.
Contracting Officer/Contract Specialist: The Contracting Officer and Contract Specialist are responsible for ensuring that:
-the DD Form 254 is part of the pre-award action, as required.
-an approved award DD Form 254 is included in contract awards.
-the FINAL DD Form 254 is prepared (this responsibility will shift o the COSM upon issuance of the next change to the OPNAVINST 5510.1H in the near future).
-distribution of the following is made to the COSM:
-Contracts with an award DD Form 254
-Modifications to a Contract containing a DD 254
-Delivery Orders containing a DD Form 254
-Contracts with ANY foreign OWNED firm.
Ordering Officer: The Ordering Officer is responsible for ensuring that:
-the DD Form 254 is part of the DO, when required, OR the work required in the DO is covered by the basic contract DD Form 254.
-IF foreign travel is required by the DO, the Ordering Officer is required to review the DD Form 254 in the basic contract. If the DD Form 254 does not cite the foreign destination, obtain a D.O. DD Form 254 from the COR, or Technical requestor.
GUIDELINE PREPARATION: This booklet was prepared in cooperation by the Contracting Officer for Security Matters, Code 0353, and the Supply Department Policy Support Office, Code 02214. For questions and/or revisions to this document in the area of security matters, e-mail "patti" or "COSM" or call Patti Talley at X3/3195. For questions and/or revisions to this document in the area of contractual matters, e-mail "melody" or call Melody Petersen at X3/4531.
D. M. Smith
R. A. Fletcher
To use the SCS you will need to log onto the VAX using the DRACO cluster (DRACO, HYDRA, etc.). For Contracting personnel, you may do this by choosing the "Communication Programs" from the LAN Main Menu. Select TERMINAL or KERMIT to come up with the # sign. Select one of the following (location 10, call 800; location 13, call d50; or location 14, call f80) and type in the location #, and return, then type the call # and return. Now type in your userid, then your password. At the $ type menu, then select SCS.
-Select 14 - Company/Activity.
-The cursor will go to the right side of the screen. Type in your secondary password of CONTRACT (upper or lower case).
-The following screen will appear:
CA1000 10:39:10 COMPANY/ACTIVITY 01/28/94 ---------------------------------------------------------------------- Company Name (1) Comp Name Cont: (2) Status: AC Abbreviation: Foreign Owner (4) DBA/AKA Name (3) ---------------------------------------------------------------------- Company Address Classified Mailing Address Street Street (5) City City State: Zip: - Country US State Zip: - Country: US ---------------------------------------------------------------------- Clearance Security Officer Fac Clearance: UN (6) Last Name: Date Granted: / / / First Name: Date Verified: / / /(7) Phone Number: ( ) - Ext: ---------------------------------------------------------------------- Cage Code/UIC (8) FAX Number: ( ) - Ext: Safeguard Cap: (9) Confirmation ( ) ---------------------------------------------------------------------- Remarks: (10) ---------------------------------------------------------------------- Command:(Add,Chg,Del,AddR, SecOff,ClEar,Class,CAGE,FaX,Spcl, Query, ReMarks) Esc-chr: help: ? port:1 speed: 9600 parity:none echo:rem VT102 ...
To Print the data on the Screen hit the Shift and Print Screen keys on your keyboard.It is critical when you finish using this system that you logout. TOO MANY users on the system at one time slow it down and prevents access by any other users.To escape or quit at any time use the F1 (gold) key and M. This will return you to the SCS menu. Type 99 to exit the SCS. Another approach that may be available to some individuals is to use the F1 key and type E to exit the SCS. This will return you to your menu. From the $, type lo (for logout). Then, from the # use the F10 key.
Note that the commands provided at the end of the screen can not be used by other than security personnel. These commands are for write privileges only.
(1) Company Name. Self Explanatory. If the company exceeds the length of the line, it is continued on the Comp Name Cont line (2). Both lines are required for the complete company name.
When looking for a company, you may use a wild card. Type at least three characters of the name, followed immediately by *. This will search for all companies in this string (example: HORIOKA*).
(3) If the name you are searching for happens to be the company's official DBA (Doing Business AS), type the name you are looking for on line (1), the SCS will scan all records for this entry on lines (1) and (3), and the official name will appear on line (1) with the DBA you are searching for showing on line (3) (i.e., HORIOKA ENTERPRISES INC on line (1) and CLEANSERV EXECUTIVE SERVICES on line (3)).
The screen should show your company (if it does not find your company, contact Code 0353, extensions 33195 or 35841). If the record that is displayed is not the record you thought you were looking for, please remember to double check line (3) for the company name you were searching for.
(4) Foreign Owner: If this block is filled in, then you need to contact Code 0353, extensions 33195 or 35841, for special instruction.
(5) Classified Mailing Address: This is the only official address to be used for mailing classified information.
(6) Fac Clearance: This is the current clearance level for the company. You must ensure that this level is at or above the level of your specific action.
(7) Date Verified: This is the latest verification date of the company's clearance. This should be within the last 12 months prior to providing any classified documentation or completing an award action. If this date is not within the last 12 months, you should contact code 0353, extensions 33195 or 35841 for an updated clearance verification.
(8) CAGE Code/UIC: Self explanatory. It is helpful to use the CAGE code whenever possible. This will provide the unique record for the company you are interested in (i.e., there are several HORIOKA ENTERPRISES INC., the use of the CAGE code will identify your specific location). To enter the CAGE code from the beginning (in lieu of a company name), simply TAB down twice, and enter the alpha numeric code.
(9) Safeguard Cap: This is the company's approved level of safeguarding capability. You must ensure that this level is equivalent to the classification level of the material you wish to furnish to them.
(10) Remarks: In this block, you may find information such as:
-2nd line add
-this means that the following typed line (shown on the screen) is the second line of the company's address. Generally it is only the physical address of the company. If the company's physical address is the same as the mailing address, then the line will read 2nd line addresses (plural).
In the future the SCS screens will be changing to accommodate additional fields and the expansion of existing fields. When this occurs all information pertaining to companies, including their complete addresses, will be found in the main body of the screen and will not be continued in the remarks block.