Security Program (NISP) Reporting
Requirements
Why do contractors need to be concerned with reporting? - To protect our national
security, to protect our service members, to protect our economic stability, and to
protect your company's own competitive advantage in the marketplace.
National Industrial Security Program Operating Manual (NISPOM) Reporting
Requirements - • The National Industrial Security Program Operating Manual
(NISPOM) establishes the baseline security requirements to ensure that safeguards
employed by contractors are adequate for the protection of classified information.
• One such requirement, defined in the NISPOM, states that contractors must
report certain events to the appropriate government agencies, that may have an
effect on the status of the entity's or an employee's eligibility for access to
classified information. This requirement includes both your own observations and
those of your cleared employees.
• This requirement to report applies to certain events that may have an effect on
the status of the contractor's favorable entity eligibility determination, also
referred to as a Facility Security Clearance (FCL) or affect the status of an
employee's favorable national security eligibility determination, also referred to as
a Personnel Security Clearance (PCL); may indicate an insider threat to classified
information or to employees with access to classified information; affect the
proper safeguarding of classified information, and indicate that classified
information has been, or is suspected to be, lost or compromised.
What must be reported? - • The National Industrial Security Program Operating
Manual (NISPOM) lists the various events that must be reported.
• The easiest way to understand these reports is to group them by where most
reports will be submitted.
, • According to the NISPOM, most reports are submitted to the Federal Bureau of
Investigation (FBI), or the Cognizant Security Agency (CSA).
• The CSA reports are submitted to the Defense Counterintelligence and Security
Agency (DCSA) via the DOD personnel security system of record, with certain
reports going to your DCSA Industrial Security Representative (IS Rep).
Facility Security Officer (FSO) Reporting Requirements (1) - • On the industry side,
each cleared contractor facility must appoint an Facility Security Officer (FSO), who
supervises and directs security measures for implementing applicable National
Industrial Security Program Operating Manual (NISPOM) and related government
security requirements to ensure the protection of classified information.
• The FSO is the link between government and industry.
• One of the FSO's responsibilities is to ensure that appropriate reports are made
in a timely manner.
Facility Security Officer (FSO) Reporting Requirements (2) - • The Facility Security
Officer (FSO) is responsible for reporting events they have directly witnessed, and
ensuring their cleared employees are making the appropriate required reports.
• Not only is the FSO responsible for ensuring that their cleared employees are
aware of the National Industrial Security Program Operating Manual (NISPOM)
reporting requirements, they must also ensure their employees know what
information should be reported and how to make reports.
• Once a report is received by the FSO, it is then up to the FSO to submit the
reports accordingly.
Defense Counterintelligence and Security Agency (DCSA) - • The majority of
National Industrial Security Program Operating Manual (NISPOM) reports will be
submitted to the DCSA, acting as the Cognizant Security Office (CSO) on behalf of
your Cognizant Security Agency (CSA).