NISPOM Codifying, Guidance, Cleared Defense Contractors, and all those CFRs

Send us Fan MailThe latest industry buzz is the “release of the new National Industrial Security Program Operating Manual (NISPOM)”. I’m putting air quotes in there, because an actual NISPOM has not been rewritten or re-released. There is no re-release of NISPOM, only a reorganization of the CFRs that duplicate National Industrial Security Program requirements.Conclusion:  No new NISPOM (just a few additions)·                 32 CFR part 117 and 32 CFR part 2004 are redundant requirements·                DoD will no longer publish the DoD Manual 5220.22, NISPOM as a DoD policy issuance in 32 CFR part 117.·                 32 CFR part 2004, “National Industrial Security Program” is now the standing CFR·                NISPOM Change 2 is still a requirement that Cleared Defense Contractor (CDC) must followBackgroundA quick read will review that there actually is no new NISPOM. This information just codifies (fancy legal term for: arrange (laws or rules) into a systematic code.).You might know that the Director of National Intelligence (DNI) has had a large role in developing NISPOM. Primarily DNI oversees the protection of National Intelligence Information in the hands of the cleared defense contractors. Additionally, DNI has had executive roles In relation to the 2008 publication of E.O. 13467, “Reforming Processes Related to Suitability for Government Employment, Fitness for Contractor Employees, and Eligibility for Access to Classified National Security Information.Biggest Impact: Reporting based on 13 Adjudicative Criteria, SF-86, and SEAD 3  SEAD 3 identifies required reporting of data elements that are contained in the Standard Form-86, “Questionnaire for National Security Positions” used in requesting security clearance requests. This doesn’t seem to be a new requirement, but an emphasis as many FSOs have been providing this requirement in security awareness training.For more information on SEAD 3, check this out: https://www.dni.gov/files/NCSC/documents/Regulations/SEAD-3-awareness-briefing.pdfDon’t wait for a new version of NISPOM…yet. While there is no “new NISPOM”, there are some clarifying comments. I also recommend using current NISPOM for security training and ISP® and ISOC certification. Nothing has been changed, just “codified”.Resources:How to Get U.S. Government Contracts and Classified Work.Insider's Guide to Security ClearancesSecurity Clearance and NISPOM TrainingNISPOM CentralProviding security clearance books, training, and resources for cleared defense contractors.Disclaimer: This post contains affiliate links. If you make a purchase, I may receive a commission at no extra cost to you.Support the showFSO Consulting:https://thriveanalysis.comNISPOM Compliancehttps://www.nispomcentral.comhttps://www.nispom.comThe Trusted Advisor for Technology Protection, FSO and NISPOM consulting. After dialing in my craft and many years of honing program protection experiences, I became a trusted advisor. I am currently supporting customers with technology protection and NISPOM compliance topics.INDUSTRIAL SECURITY TRUSTED ADVISORWhat Trusted Advisor Involves:I partner with executive leadership to design and operate security programs that meet and exceed NISPOM requirements. Results you can measure immediately:Prepared commercial organizations for defense contracting and NISPOM complianceDesigned ready to implement security programs before, during and after facility clearance awardRescued high risk security programs with quick turnaround; usually within 30 daysAchieved Commendable and Superior DCSA review ratingsDeveloped compliant FOCI mitigation programs