•

--TOP-SECRETNAN V A

--(S)-NATIONALRECONNAISSANCEOFFICE

WASHINGTON. D.C.

THE NNO STAFF 28 March 1977

MEMORANDUM FOR DIRECTOR, PROGRAM A

DIRECTOR, PROGRAM B

DIRECTOR, PROGRAM C

SUBJECT: NRO Policy on Consultants

Attached is a proposed policy for the employment of

consultants on NRO programs. It is becoming apparent that

we need such a policy to assure that the NRO remains

sensitive to and is in compliance with the various conflict

of interest statutes. Also we must assure that consultants

are being used in the most effective manner. I would appreciate your reviewing this policy and providing comments

back to the Staf 1 April. Please have your reply

directed to Ma .

who is the Project officer on this

effort.

JR.

Brigadier General, USAF

Director

1 Attachment

taped Policy

714-77)

ei ASWAN Ow

*tea (VIM OM IMO IL IN WNW CAN 1 11

• NU SECIAININ, Na• Oa 1

WA 47"" TOP1EGRET-
COATIS 7"

OPIES

PAGES

CON RCA Sv 1111111111111P

4. aatOule &OW

MG& IWO IN

emlitoM11 MONO *OW

m. isellataillbile Oft wee

--TIFSECREf-

•

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 C has 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 interest

statutes. DCI approval is lequired prior to entering into

any contractual arrangement with a consultant. Program B has

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

•
CONE NO

ES

PAGES

7

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.

P for consultant services vary between

rogram B costs for

consu n are about 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 potential 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.

le 61•0010 MAEIMO

eseavly ON II WO

•WIM... OMR • MANI ellestow. gimp

ION COI IIIN 1n41Ma • qmovas •
IV-SECRET

Regardless of the type of activity engaged upon by the

consultant, there should be adequate report* 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 consultant 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.

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.

ocuments or any other documents generated by the

consuLw t for non-NRO offices which contain information

derived from NRO sources will be submitted to the program

office for security and policy review prior to further

dissemination.

Consultants will not support source selection activities.

Consultants willmot have access to budget planning data

on NRP systems or technology except in situations specifically

approved by the appropriate NRO Program or Staff Director.

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.

taally001111 Ufa/ ••nn•

&M... OM

•••••••••n 111•1111• .ftwrOssernse.esse

see. elm ellasser • maw on
11W-SKIIETYearly Determination and Findings documents will be pre- •

pared by the organization having the contract onsultant. The DO. package will be sent through

channels to the NRO Staff for staffing to obta

necessary secretarial approvals.

4.•