An overview of when FCLs and PCLs need to be upgraded, and how the process works
For both Personnel Clearances (PCLs) and Facility Clearances (FCLs), there are times where a clearance needs to be upgraded to respond to changing needs of a contract or mission. When you need a clearance upgrade, you don’t want to risk extending that process any longer than it needs to be. Understanding the process can help you stay prepared should you need to upgrade.
Upgrading an FCL
The decision to upgrade your FCL will come from your sponsor. This will either be the prime contractor if you’re a subcontractor or the Government Contracting Activity (GCA) directly if you are the prime contractor. When their DD254 changes to a higher level than your current clearance, such as from secret to top secret, you will need to be upgraded.
The process begins when your sponsor sends a new sponsorship request in NISS. From there, DCSA will email you alerting you of the sponsorship. You will need to submit an FCL package within 20 days of receiving this email, the same time frame as when you first got a clearance, in order to secure your upgrade. The main difference between this process and the process for an initial clearance is that you are able to clear your Key Management Personnel (KMPs) yourself rather than having DCSA do it for you.
Since you’ve already gone through this process once, it shouldn’t be overly difficult. As a reminder, your documentation will include materials including company articles of incorporation, a KMP list, a DD 441 and an SF 328. It’s helpful to keep your FCL package paperwork handy in case you’re sponsored for an upgrade again in the future.
Upgrading From Non-Possessing to Possessing
The process for upgrading to a facility cleared to possess classified information is different than upgrading your clearance level. This will occur when you either have a new contract that necessitates possession or if your current sponsor finds a need for you to possess. You will upload a new DD 254 showing you are required to possess to begin this process.
In order to make this change, you will work with your Industrial Security (IS) representative. They will give you a list of actions that you need to take to be cleared. These actions will vary based on the unique risks your facility faces based on your location, likelihood of an incident, and more. Recommendations can vary from IS rep to IS rep as well. Some actions that won’t vary include getting a GSA-approved safe and developing a Standard Practice Procedure (SSP) for how you will protect your information.
Once you’ve taken the actions required by your IS rep, you will be cleared to safeguard information and can move forward as a possessing facility.
Upgrading a PCL
Like an FCL, upgrading a PCL involves going through the original process again. Unfortunately, when getting a higher-level clearance, you can’t do it through a reinvestigation, but instead have to submit a whole new SF 86.
This time, the investigation will be more thorough. If you originally were cleared at a classified level and are moving to a secret or top-secret level, it’s more likely that investigators will contact you and your references. You will also need to submit your fingerprints again alongside the form.
The SF 86 can be a pain to complete, but you can make it easier on yourself. Once you’ve filled it out the first time, you know the questions it asks, like your places of residence and people who can confirm that, so you can keep track of that information during your time as a cleared employee. If you maintain all this information somewhere for yourself, filling this form out in the future will be a breeze.
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Don’t worry if you’re cleared at a higher level and end up moving to a lower-level contract. You will still maintain your clearance at the level you were cleared rather than the level of the contract. For FSOs, make sure you’re initiating any reinvestigations at the level of the employee’s clearance rather than the contract level.
If you’re an FSO navigating upgrading clearances, you don’t have to do it alone. Adamo’s FSO support services can make this process smooth sailing or help you with any other aspects of your responsibilities that keep you from focusing on the most important parts of your work. Don’t face bumps in the road alone. Contact us today to learn how Adamo can help.
