A facility clearance (FCL) lets your company access classified information, and you cannot apply for one on your own. A government contracting activity (GCA) or a cleared contractor has to sponsor you (32 CFR 117.9(a)(10)). Most companies meet this requirement right after an award, and once DCSA starts the process the deadlines are short. This guide covers who can sponsor you, what makes a company eligible, and what to have ready before sponsorship.
Who can sponsor your FCL
Two kinds of organizations can sponsor a company:
- A government contracting activity awarding or overseeing a classified contract
- A cleared prime contractor, for a subcontract that needs classified access
Sponsorship needs a real requirement. Your company must need access to classified information for a legitimate government requirement, and interest alone does not qualify (32 CFR 117.9(c)(1)). DCSA adds that a company needs an FCL during the solicitation phase only if it needs classified access during that phase (DCSA, Facility Clearances).
FCL requirements: what makes a company eligible
Under 32 CFR 117.9(c), your company must:
- Need access to classified information for a legitimate government requirement
- Be organized under U.S. law and located in the United States
- Have a record of integrity and lawful conduct in its business dealings
- Have a senior management official (SMO), facility security officer (FSO) and insider threat program senior official (ITPSO) who are eligible for access to classified information
- Not be under foreign ownership, control or influence (FOCI) to a degree inconsistent with the national interest (see FOCI and your FCL)
- Have enough cleared employees to do the work
The FSO and the ITPSO must be U.S. citizen employees of your company (32 CFR 117.9(d)(1)). Outside help can carry the workload, but the FSO of record is yours.
Cleared leaders do not make a cleared company
Founders who already hold clearances help, because your SMO, FSO and ITPSO must be eligible for access anyway. The company itself still needs a sponsor and its own eligibility determination from DCSA.
What to have ready before you're sponsored
- A CAGE code. Register in SAM.gov or with DLA. DCSA warns that starting without one can cause significant delays or a discontinued case.
- Your business governance documents, such as articles of incorporation, bylaws or an operating agreement, board or member minutes, and a capitalization table.
- An organizational chart that matches your business structure.
- Your key management personnel (KMP) list, with proof of U.S. citizenship for each person who will be investigated.
- A physical address for the cleared work. If you have no office, a Nooks classified workspace can serve as the place of performance on your DD254 and the address for your FCL and clearance paperwork.
The sponsorship package
Your sponsor submits the request to DCSA in NISS with two things: a DD Form 254, which sets out the classification level, security requirements, scope of work and place of performance (see what a DD254 covers), and a sponsorship letter explaining the work, the clearance level needed and why access is necessary.
DCSA rejects incomplete or inaccurate sponsorship packages. Its most frequent reasons are a lack of attention to detail and no valid need for classified access.
DCSA's deadlines once you're in process
When DCSA accepts the sponsorship, it sends a Welcome Email to your point of contact. Two deadlines follow (DCSA, Facility Clearances):
- Day 20: business governance documents and the other required documents and forms are due.
- Day 45: the KMP investigation requests and electronic fingerprints are due.
The Welcome Email gives the exact dates, and the count includes weekends and holidays. Companies that gather documents before sponsorship usually meet the Day 20 date without a scramble.
How long an FCL takes
DCSA does not publish a timeline. It says the length depends on many variables, including how quickly companies send the required information and whether that information is accurate and complete. Plan for several months or longer, and longer still if FOCI mitigation is needed.
How we help
Our industrial security team prepares and submits the FCL package with you, tracks it through DCSA, and sets up the security program you need to keep the clearance. We assign an assistant FSO to your account; your FSO stays on your staff, and we carry the day-to-day work behind them.
Talk to our team about your FCL.
