Acting Director

1 Attachment

Policy Guidance

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(St NATIONAL RECONNAISSANCE OFFICE

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WASHINGTON. D.C.

OFFICE OF THE DIRECTOR 3 shine 1977

MEMORANDUM FOR DIRECTOR, PROGRAM A

DIRECTOR, PROGRAM B

DIRECTOR, PROGRAM C

SUBJECT: NRO Policy on Consultants

For your information and appropriate action, the attached

policy guidance for the employment of consultants on NRO programs is established. Included within the scope of this policy

are all personal services consultant contracts issued by NRO

Program Offices. Although these provisions do not necessarily

apply to consultants serving as members of panels or other

ad-hoc groups providing services to NRO programs, it is recommended that the guidelines of this policy be considered in

such cases. While it is recognized that Program B will obtain

consultant services approval and D&F from the DCI, periodic

reporting on the activities of. Program B consultants will still

be made to the DNRO. Review of consultant activities for

Programs A and C consultants will be included in the packages

sent to the DNRO to support D&F renewals.

A very significant aspect in the relationship with NRO

consultants is the avoidance of any impropriety of conflict of

interest between the consultant's activities with the gov

governs

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nent and with governs tractors. The absence of external rn

oversight afforded b security and NRO streamlined

management requires us extra-careful so that there not

even be the appearance of any conflict of interest. This is

not meant to preclude any consultant contracts but only to

urge extreme care in the employment of use of consultants

within the NRO.

Your assistance in assuring adherende to this policy

would be greatly appreciated.
NRO POLICY ON EMPLOYMENT OF CONSULTANTS

Purpose 

The purpose of this paper is to outline procedures and

establish policy guidelines for the use of consultants to the

NRO. The term consultant used in this paper will apply to a

single individual entering into a personal service contract

for the purpose of consultation to any element of the NRO.

Background 

Over the past few years relatively few persons have been

employed as consultants to the NRO. Program A has entered

into contracts with three individuals for various efforts.

Program B has employed three or four people as consultants,

some on a "without compensation" basis. Program Chas not

employed consultants and at this time does not contemplate

using persons in a consultant role.

Three consultants which Program A has used in the past

have assisted the various project offices.in evaluating proposals, concepts, and new techniques for optical, camera, and

SIGINT systems. They have also recommended advanced technology and exploratory research projects for study. They have

participated in various boards and committees both internal

and external to the NRO structure. Their outside contacts

have sometimes benefited the NRO by identifying applicable

R&D activities being conducted outside the NRO. The NRO Staff

has occasionally used Program A consultants to review the NRP

R&D program. Also in some cases consultants under contract to

Program A have been used under separate contracting

arrangements by Program B.

Program B consultants are employed in accordance with

internal CIA regulations regarding the employment of consultants. CIA policy is not to employ consultants unless the

following provisions can be met: specialized services cannot

be provided by any other agency resource; the consultant service is beneficial to the CIA;'the consultant services are

not obtainable under other employment procedures, and the

consultants' services will not violate conflict of inteiest

statutes. DCI approval is required prior to entering into

any contractual arrangement with a consultant. Program B has

only used about three or four people on a consultant basis.

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They are used on specific jobs requiring only a few days

per year of their time. They are not used'in an advisory

capacity on any Source Selection Boards.

Financial Aspects 

Costs to the NRO for consultant services have been low.

for consultant services vary between

or • ogram B costs for

consultants are ut er year.

Discussion

There are situations where it would be desirable to have

a consultant providing a program office with particular

expertise in an area in which a program office or the Staff

knowledge is lacking. In this situation the consultant would

evaluate concepts and proposals and even advise a Source

Selection Board on matters involving his area of expertise.

For the situation where the program office does not have

expertise available, the use of consultant services should

not be discouraged. Care should be exercised, however, to

preclude the consultant being put into a poteritial conflict

of interest situation particularly if the consultant also has

a contractual relationship or a financial interest with other.

contractors involved in the satellite reconnaissance field.

Prior to signing a contract with a consultant, a list of his

financial interests and other contracts must be obtained and

reviewed for potential conflicts of interest. The NRO program office involved would decide whether a conflict of

interest exists and whether a contract could be consummated

with the consultant.

Another service which has been provided by consultants

has been to provide the NRO with information on technical

innovations and status of other Intelligence Community

studies and efforts which are of interest to the NRO. Also

consultants have, at the request of the NRO, interfaced with

other Intelligence Community activities on matters which

affect the NRO. This type of service benefits the NRO by

providing information and insight on these activities which

the Staff does not have the manpower to cover. This service

is of value to the NRO by bringing in an outside viewpoint

on Community activities and their impact on NRO R&D projects

and other studies during internal NRO program review. Again,

there must be a close examination of the consultant's other

contracts and financial interests to avoid conflict of interest.

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Regardless of the type of activity engaged upon by the

consultant, there should be adequate reports written to

document the consultant's efforts. Reports could be either

task-oriented or cover more general activities over a period

of time. In any case, there should be at least quarterly

reports written by the consultant on his activities under

the contract. At the end of each year, an evaluation of the

consultant's contributions should be made to assist in the

determination of whether to continue the contract. This

evaluation should be made by the project officer. Final

decision regarding continuation of the consultant's contract

should be made by the NRO Program Director or the NRO Staff

Director (for consultants contracts supporting the NRO Staff).

NRO Policy on Consultants 

The NRO Staff and program offices are allowed to use

consultants who either have expertise in special technical

areas which are not covered by in-house experience or have

wide ranging experience and contacts throughout the

Intelligence Community in areas of technology similar to NRO

areas of technology.

Expert or consultant services will be contracted for in

accordance with applicable portions of ASPA Section 22, Part 2

and the Federal Personnel Manual, Section 304.

Care must be exercised to preclude involving consultants

in situations which might lead to conflict of interest problems.

Consultants will execute the confidential statement of employment and financial interest form and keep it current. The

program office has responsibility to adjudicate any conflict

of interest situations.

for 

or, any other documents generated by the

cons for non-NRO offi ces which contain information

derived from100 sources will be submitted to the program

office for security and policy review prior to further

dissemination.

Consultants will not serve on Source Selection Boards and

any participation of consultants in Source Selection Board

activities will be extremely limited and only with the expressed

approval of the NRO Program Director.

Consultants will not have access to budget planning data

on NRP systems or technology except in situations specifically

approved by the appropriate NRO Program or Staff Director.
TV-SECRETWhen working space is furnished to experts or consultants,

it shall be segregated from the space occupied by government

personnel to the maximum extent possible, in a manner consistent

with the amount of secure space available and consistent with

relevant security requirements and considerations.

Consultants will submit written reports on each task or

at least quarterly to the NRO project officer having cognizance over the consultant's activities. Yearly evaluation

reports will be written by the NRO project officer. These

reports will be used to evaluate the consultant's contributions

and to determine whether the consultant's contract should be

renewed for another year.

Determination and Findings documents will be prepared by

the organization having the contract with the consultant.

The IMF package will be sent thro hannels to the

NRO Staff for staffing to obtain th ry secretarial

approvals.

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