DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

ROADMAP TO GETTING A 

FACILITY CLEARANCE/FCL 

Sponsorship

May 2023

DCSA FCB Staff Specialist Shelton R. Mallow
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

A general understanding of how the facility clearance process works, to prepare 

your business for the facility clearance process and considerations to be mindful of 

as your company looks to enter the cleared industrial base. 

Topics include:

• Basic Principles Surrounding Facility Clearances

• NISS Sponsorship Discussion

• Facility Clearance Process Roadmap and Timeliness

• Top 5 Reasons for Rejection 

• Required Roles and Responsibilities 

• Initial vs. Upgrade sponsorship

• Questions and Considerations to Keep in Mind 

• DCSA Resources and Training 

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WHAT YOU WILL WALK AWAY WITH TODAY
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY 3

WHAT IS A FACILITY CLEARANCE?

A Facility Clearance (FCL) is an administrative determination 

that a company is eligible for access to classified 

information

• Reference: DoDM 5220.32 Vol 1, Section 4 and 32 CFR 117.9(c) 

The FCL Process requires Key Management Personnel (KMP) 

to get Personnel Clearances in connection to the FCL

• Reference: DoDM 5220.32 Vol 1, Section 4.7 and 4.8 and 32 CFR 

117.7(b) and 32 CFR 117.7(c)

NOTE: A Facility Clearance is not a clearance for a specific location, site or 

building, but is granted based on the ownership, authority and control of 

the KMPs of that company verified in the company’s legal business 

documents. 

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DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY 4

FCL SPONSORSHIP IN THE SYSTEM OF RECORD

DoD TWO STEP AUTHENTICATION – NCAISS AND NISS

https://www.dcsa.mil/is/nisp_ncaiss/

The DCSA NCAISS Portal is a web-based application 

that provides Public Key Infrastructure (PKI)-based 

authentication services to DCSA applications and 

information systems for authorized users. Through 

the NCAISS Portal, an authorized user can access 

their DCSA NCAISS Portal account via a single signon (SSO) capability using PKI certificates (either a 

Common Access Card (CAC) or DoD-approved 

External Certification Authority (ECA) certificate).

DCSA System of Record for industrial security 

oversight accessible by Industry, Government, and 

DCSA personnel. FCL Sponsorship Requests will be 

made in this system. Once submitted, the FCL 

Request will be tasked to DCSA Facility Clearance 

Branch for review. During the review, DCSA FCB will 

validate the bona fide need to access classified 

information in the performance of a classified 

contract and ensure that the request meets policy 

requirements. 

National Industrial Security Program 

Contracts Classification System (NCAISS)

https://www.dcsa.mil/is/niss/

National Industrial Security System (NISS)
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY 5

FACILITY CLEARANCE ROADMAP

SPONSORSHIP 

SUBMISSION 

AND REVIEW

SPONSOSHIP 

PACKAGE 

ACCEPTED

FCL Process 

Video Review*

FCL PACKAGE 

UPLOAD

INITIAL FCL 

PACKAGE 

DEADLINE

DAY 45: 

KMP PCL 

DEADLINE TO 

SUBMIT

Once the company has met the requirements and deadlines noted above, that does not mean the FCL 

process is finished. The following tasks will need to be completed before an FCL is issued.

KMP PCLs in 

connection with the 

FCL are adjudicated 

at the appropriate 

level and reflect in 

DISS

DCSA has completed 

an internal vetting 

assessment and 

FOCI has been 

mitigated, as 

needed

An Orientation 

Meeting has been 

completed with 

DCSA Industrial 

Security Rep in the 

field

DAY ONE

CLOCK STARTS! 

The FCL 

Orientation 

Handbook 

provides 

valuable 

information on 

the FCL process

DAY 10-20 

FSOs upload all

required 

documents & 

forms based on 

company’s

Business 

structure into

NISS. 

DAY 5-10

FSOs review 

the FCL 

process 

videos/Handb

ook at 

www.dcsa.mil

to prepare 

compiling the 

FCL package

DAY 20

DCSA reviews 

companies

FCL package to 

validate it 

meets 

requirements 

and for 

accuracy. 

DAY 45

Once FCL 

Package is 

approved, 

FSOs will 

submit KMP 

e-QIPs and 

fingerprints
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY 6

UNCLASSIFIED

National Industrial Security Program (NISP) Facility Clearance (FCL) Lifecycle

Continuous Monitoring 

• Contractor submitted changes or information

• Review news and reporting

• Automated data feeds

• QA performed

Analysis 

• Assess risk indicators for business 

vulnerabilities & contractor conduct

• Assess risk indicators for threat

Determine Mitigation 

• Review relevant assessments

• Develop Risk Mitigation Strategy

Oversight 

• Conduct field/HQ oversight 

& security reviews 

• Provide continuous engagement, 

support & outreach

Stages

Review & Triage

Analysis

Determine Mitigation

Implement Mitigation

Oversight

CM

Review & Triage 

• Review sponsorship for bono fide need to access classified

• Review contractor submitted package for completeness

• Initial identification of risk indicators w/referrals

• Initiate key management clearances necessary

Entity Eligibility 

Determination 

(Adjudicate)

Implement Mitigation 

• Execute interim measures, if necessary

• Negotiate terms with contractor, as required

• Execute governance and operational mitigations

• Ensure entity eligibility requirements are met 

Government Contracting Activity or 

Cleared Contractor Sponsors

May 2023
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY May 2023 7

UNCLASSIFIED

National Industrial Security Program Requirements

• Eligibility Requirements 32 CFR §117.9(c)

1. Legitimate need to access classified

2. Access consistent with U.S. national security interests

3. Organized & existing in the United States

4. Located in the United States

5. Record of integrity & lawful conduct

6. Eligible Key Management Personnel (KMP)

7. Maintain sufficient KMP for security requirements

8. KMP/business not excluded from federal contracts

9. Not under FOCI to a degree inconsistent with national interest

10. Not pose an unacceptable risk to national security interests

11. Meet any other requirements governing access

• Reviewed by FCB during Sponsorship Process

• Reviewed During Triage Process

1. Record of espionage against U.S. targets

2. Record of enforcement actions against the entity for 

unauthorized tech transfer

3. Record of compliance with pertinent U.S. laws, regulations, 

and contracts

4. Type and sensitivity of classified information

5. Source, nature, and extent of FOCI

6. Nature of relevant bilateral or multilateral security and 

information agreements

7. Foreign government ownership or control

8. Any other factor that indicates/demonstrates capability of a 

foreign interest to control or influence operations or 

management

• FOCI Factors 32 CFR §117.11(b)
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY 8

THINGS THAT COULD AFFECT THE TIMELINESS OF THE FCL

PCLs

•Will the KMPs need to be initiated for a PCL OR are KMPs already cleared 

with PCL eligibility reflected in DISS

•The PCL backlog is no longer an issue, as we are now at a steady state and 

have much stronger numbers on timeliness for T3 and T5 investigations

FOCI

•Is there significant foreign ownership, control or Influence

•If so, there may need to be FOCI mitigation instruments put in place which 

could affect the timeliness

Legal Docs

•Are there discrepancies in your company’s legal docs, website, address

•Is your company in good standing with the registered Secretary of State

•Reviewing this information and being prepared ahead of time can help the 

FCL process
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY 9

PRE-AWARD AND POST-AWARD SPONSORSHIPS

PRE-AWARD SPONSORHIP

Must have bona fide need to access classified 

during performance of the contract during the bid 

process. 

Reference DoDM 5220.32 Vol 1, Section 6 and 6.c 

and CFR 32 117.17 1(a and b)

Sponsorship must include, but may not be limited to:

• Solicitation number, release date and close date

• Written GCA Authorization verifying access to 

classified information in the pre-award stage 

• Level of classification and copy of pre-award 

DD254

POST-AWARD SPONSORHIP

Must have bona fide need to access classified 

during performance of the contract. 

Reference: DoDM 5220.32 Vol 1, Volume 2, 

Sections 4.3 and 4.4 and 32 CFR 117.9(c) 

Sponsorship must include, but may not be limited to:

• DD254

• SOW/PWS

• Written GCA Authorization on security 

requirements above those listed in NISPOM
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY May 2023 10

TOP REJECTION REASONS FOR FCL REQUESTS

Missing Government Contracting Activity 

Authorization on those security requirements 

above those noted in NISPOM

Incorrect or incomplete information on the 

DD254

Lack of Justification/No access to classified 

required/No obvious bona fide need to access 

classified 

Solicitation with no required access to 

classified information in the pre-award stage

Incorrect sponsorship request/conflicting 

information on sponsorship and DD254
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY May 2023 11

BUSINESS STRUCTURE REQUIREMENTS

•Business Structures in the NISP Business Structures in the NISP

Corporation

Limited 

Liability 

Company

Partnerships Joint 

Ventures

Colleges & 

Universities

Valuable resources include: the FCL Orientation Handbook and DoDM 5220.32 Vol 1, Section 

4. 

These will help your company prepare to go through the FCL process and understand what will be required for 

submission in the FCL package. Ensure that all company documentation is accurate and up to date. 

NOTE: This includes Multiple facility organizations (MFOs)/Branch Offices and Parent/Subsidiary business 

structure relationships as well. 
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY May 2023 12

KEY MANAGEMENT PERSONNEL REQUIREMENTS

Senior Management Official (SMO)

Facility Security Officer (FSO)

Insider Threat Program Senior Official (ITPSO)

Key Management Personnel (KMP) that are required to be cleared in 

connection with the FCL will be determined and verified through the 

company’s legal documents. At a minimum, the SMO, FSO and ITPSO will 

be cleared. Additional KMPs may need to be on the KMP list depending on 

the information within the company’s governance documents. 

NOTE: DoDM 5220.32 Vol 1, Section 4.7 and 4.8 and 32 CFR 117.7(b and c)

Joint Venture Administrative employees 13 CFR 121.103 (h)
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

HOW CAN A COMPANY GET AN FCL?

• A contractor or prospective contractor cannot apply for its own FCL

• Contractors must be sponsored by Government Contracting Activity (GCA) or cleared contractor AND have a 

legitimate or bona fide need to have access to classified materials. 

WHAT ARE THE FCL REQUIREMENTS?

• Must have a bona fide need to access classified in connection with a legitimate requirement (prime or 

subcontract)

• Must be legally organized and registered to do business in the US

• Must have a reputation for integrity and lawful business dealings

• Must not be under Foreign Ownership or Controlling Interest (FOCI) - Be mindful of FOCI considerations with 

investors

• DODM 5220.32 Vol 1, SECTION 4 and 32 CFR 117.9(c)

WHO PAYS FOR THE FACILITY CLEARANCE? 

• The government funds the processing of PCLs and FCLs for access to classified information. The only cost to you 

to go through the process is to ensure the business is in compliance with the 32 CFR 117 National Industrial 

Security Program Operating Manual (NISPOM)

DOES AN FCL EXPIRE?

• An FCL remains active until the company no longer has a need to access classified information 32 CFR 117.9(c)

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FACILITY CLEARANCE FAQs
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

DoDM 5220.32 Vol 1, Volume 2, dated August 1, 2018, Section 6.2.a (2.a)

•(DCSA) does not fund investigations for non-NISP contracts (i.e., those that do not require access to classified information under 

DSS (DCSA) security cognizance). GCAs are responsible for funding any and all background investigation requirements established in 

non-NISP contracts (e.g., network or system administrators, access to government installations or facilities or issuance of the 

common access card (CAC)). See paragraph 52.204-09 of the FAR and applicable DoD or Component policies for specific guidance.

DoDM 5200.02, April 3, 2017, Section 8.1a 

•Access to Classified Information states “Granting national security eligibility is a function distinct from granting access to classified 

national security information. National security eligibility determinations are made on the merits of the individual case and involve 

examining a sufficient period of a person’s life and background to determine that the person is an acceptable national security risk.

Access determinations are made solely on the basis of the eligible individual’s need for access to classified information to perform 

official duties

Executive Order #12968: Part I, Definition, Access to Classified Information, Financial Disclosure and Other 

Items, Sec 1.1 (g)

•‘‘Need for access’’ means a determination that an employee requires access to a particular level of classified information in order 

to perform or assist in a lawful and authorized governmental function.” AND Sec 1.1 (h) “(h) ‘‘Need-to-know’’ means a 

determination made by an authorized holder of classified information that a prospective recipient requires access to specific

classified information in order to perform or assist in a lawful and authorized governmental function.

Executive Order #12968: Part II Access Eligibility Policy and Procedure, Sec 2.1 (b) 

•Eligibility Requirements states: (1) Eligibility for access to classified information shall not be requested or granted solely to permit 

entry to, or ease of movement within, controlled areas when the employee has no need for access and access to classified 

information may reasonably be prevented.

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PERSONNEL SECURITY PROGRAM REFERENCES

IN REFERENCE TO SERVICE CONTRACTS, IT LEVEL POSITIONS, HSPD-12 & NEED TO KNOW
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

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WHAT CAN YOU DO TO PREPARE

ENGAGE OTHERS INVOLVED IN NISP AND ASK QUESTIONS

REACH OUT TO DCSA FCB KNOWLEDGE CENTER FOR ANY QUESTIONS ABOUT THE PROCESS OR WHAT THE 

REQUIREMENTS FOR AN FCL ARE

GET YOUR COMPANY’S LEGAL DOCUMENTS IN ORDER

RESOLVE ISSUES WITH SECRETARY OF STATE SITE, SAM.GOV, ADDRESS AND WEBSITE INFORMATION TO ENSURE 

ALL IS ACCURATE AND UP TO DATE

THROUGHLY REVIEW THE FCL ORIENTATION HANDBOOK

THE HANDBOOK HAS MANY ATTACHMENTS (PAGE 10) THAT WILL ASSIST YOU IN 

SUBMITING AN ACCURATE FCL PACKAGE

GET SMART ON DoDM 5220.32 Vol 1 & 32 CFR 117

RESEARCH SECURITY REQUIREMENTS OR TAKE A DCSA CDSE COURSE
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

Initial Sponsorship

• Facility must obtain PKI and request 

NISS Access

• FCB will serve as the facilities Field 

office/ISR until the facility has 

completed FOCI review.

• Facility will submit initial FCL package 

containing all documents for the 

company

• Facility will require a full FOCI review

• FCB Will initiate e-QIPs for KMPs who 

need to be cleared.

• Orientation meeting will need to be 

conducted.

Upgrade Sponsorship

• Facility should already have PKI, NISS 

account and DISS account

• Facility will remain assigned to their 

currently assigned field office/ISR

• Facility will submit an FCL package 

verifying all company information is 

correct, and supporting 

documentation for any new changes.

• Facility will not require a new FOCI 

review if an assessment has been 

conducted within the last 12 months.

• FSO will initiate e-QIPs for KMPs who 

need to have PCL upgrades 

completed.

• ISR will conduct orientation/outreach 

to facility.

INITIAL SPONSORSHIP VS UPGRADE? 

Overall the fundamentals of the process is the same for an 

initial FCL and upgrade
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

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RESOURCES

• FCL Process Orientation Video –

https://www.dcsa.mil/mc/ctp/fc/

• FCL Orientation Handbook 

VISIT WWW.DCSA.MIL

• DoDM 5220.32 Vol 1

• NISPOM

• Other references depending on the contract or security 

requirements

POLICY

• EMAIL: DCSA.FCB@MAIL.MIL

• DCSA FCB Knowledge Center at 

888-282-7682, Option 3

CONTACT DCSA FCB

• www.CDSE.edu

• FREE training and resources

• Facility Security Officer toolkit

DCSA Center for 

Development of 

Security Excellence 

(CDSE) 
DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

There are 35 NISP signatories: 

National Aeronautics and Space Administration

Department of Commerce

General Services Administration

Department of State

Small Business Administration

National Science Foundation

Department of the Treasury

Department of Transportation

Department of the Interior

Department of Agriculture

Department of Labor

Environmental Protection Agency

Department of Justice

Federal Reserve System

Government Accountability Office

United States Trade Representative

United States International Trade Commission

United States Agency for International Development

Nuclear Regulatory Commission

Department of Education

Department of Health and Human Services

Department of Homeland Security

Federal Communications Commission

Office of Personnel Management

National Archives and Records Administration

Overseas Private Investment Corporation

Department of Housing and Urban Development

Millennium Challenge Corporation

Executive Office of the President

Social Security Administration

United States Postal Service

Privacy and Civil Liberties Oversight Board (PCLOB)

Department of Veteran Affairs

National Credit Union Administration

U.S. Trade and Development Agency (USTDA)

This information can be found on dcsa.mil > NISP 

signatories

October 2019 DCSA took over the PCL mission. This newly 

formed organization is intended to give a more timely, 

seamless approach to the whole FCL and PCL process. 

Better communication, collection of required information 

on the front end. We are already seeing a very positive 

benefit within our agency which ultimately helps us 

better support you in Industry. 

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DEFENSE COUNTERINTELLIGENCE 

AND SECURITY AGENCY

QUESTIONS?

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