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By Jeffrey W. Bennett, ISOC, ISP, SAPPC, SFPC
To be eligible for a defense contract an organization registers with SAM.gov, to obtain their CAGE code. There are a lot of steps to becoming a defense contractor.
However, the documents uploaded into SAM.gov are the same that DCSA needs during the sponsorship process. Articles of incorporation, board resolutions, meeting minutes, line charts, line and block charts, org charts, business licenses, all that.
The difficulty I see is that while the work has been done for SAM.gov, the person appointed as FSO for the security clearance sponsorship may not have access to those documents. This causes a significant amount of stress as the already tight time crunch is hindered by company bureaucracy.
Of course there are other forms required such as the NDA between the entity and the government, and then a form that shows whether or not and to what extent an entity might be under foreign ownership, control, and influence. And then the entity will identify key management personnel. By day twenty of the DCSA countdown, the FSO has to upload everything that the DCSA requested into the National Industrial Security System (NISS).
Hold on, not so fast, we can't even get to NISS until we get the appropriate certs to log in; that's going to eat some time up as well. this may require certs in a CAC or PIV. If these certs are not already available, they could take up to three weeks to acquire (I've seen two months).
You will also want to do some pre-work, and that is to get our key management persons ready for their security clearances. This KMP information is submitted by day twenty, and then by day forty-five, they must complete their SF-86.
Failure to meet the timeline could result in delay or denial of the FCL. However, once submitted on time, there is a time of negotiation as DCSA analysists request clarification or additional supporting documents. This may require board resolutions or additional administrative tasks.
Keep in mind, depending on the complexity of the situation, the above described tasks could cost upward of 60 or more hours of an appointed FSO's time. For small companies, the appointed FSO could very well be a executive who is not a security professional, but rather responsible for the growth and health of the organization
What this means for you is that somebody at the leadership level is going to have to handle these tasks and twenty to sixty hours in a 20 day period is a lot if you are not able to focus on your organization's health and prosperity.
So the best news is that once you go through the experience and receive your FCL, the FSO and other KMP now shift priorities to building a security program as described in last month's article You have your FCL, Now What
I hope this article has helped you identify actions necessary once an organization is sponsored for an FCL. Instead of going it alone, why not get assistance from someone who has done this many times. What if this would save an organization valuable time, reduce stress and improve their conditions?
You might consider a guide such as a consultant who has repeatedly navigated other companies successfully through the process. Contact me to help with navigating the process, strategize for new contracts, recommend security structure. I already have the credentials needed to log on to the DCSA databases.
Consultants can meet your timeline requirements and absorb the hours that executives might put into the work and allow them to focus on the prosperity and health of the business.