“A-ha! You missed listing the criminal and civil penalties in your Annual Refresher which is required in the CFR, so that is a finding.”
Okay, maybe the DCSA Rep did not say “A-ha!” but the rest was true during an inspection last week and it wasn’t a great feeling.
As you may realize, FSO PRO personnel attend around 4-8 Security Reviews or Continuous Monitoring Engagements a month! Jealous? Yeah—we did’t think so.
However, they are valuable because at each review we learn:
- More of what DCSA is doing.
- More of what type of reviews (aka inspections) that FSOs can expect.
- What DSCA is expecting of FSOs.
- Then we share that knowledge with YOU and bam! You are ready!
A few years ago, the hot scoop was all about identifying the “critical assets” of your companies. Today, it is more about 1) What do your cleared employees know and 2) What new things does the CFR 117 Require?
What is the DCSA Focus During Security Reviews?
- The 32 CFR 117 (Federal Rule that replaced the NISPOM) has a more reader-friendly version online. Save this to your favorites: https://www.federalregister.gov/documents/2020/12/21/2020-27698/national-industrial-security-program-operating-manual-nispom (If you are an FSO PRO member, we also provide a PDF with quick links.)
- You need to outline the penalties for unauthorized disclosure in your annual training. (32 CFR 117.12 (e 6) (If you are an FSO PRO member, we will provide a slide to you in the December bundle.)
- You need to demonstrate greater “Senior Management Official” involvement. (32 CFR 117.7 (b) 2
- All cleared personnel must report foreign travel. (SEAD 3)
- FSOs should be utilizing the New Self- Inspection checklist and briefing the Senior Management Official on the results then uploading it to NISS. (32 CFR 117. 7 (g)
- There is a New Standard Practice and Procedures document available for FSOs with an acknowledgement sheet for employees to sign. (If you are an FSO PRO member, we will provide this in this months template bundle.)
- Upload your DD254s in NISS—watch for those NATO & COMSEC briefings!
- Ensure your profile in NISS is correct—particularly personnel numbers (located under “safeguarding” in your profile even if you don’t have safeguarding).
- Interview, Interview, Interview! Your cleared and uncleared staff need to be interviewed to ensure they are comprehending and retaining the essential elements of your security program. These are HIGHLY encouraged …just like when your dad “highly encourages” you to do something—it actually means you better do it!
- The only “sad” news is that DCSA no longer gives out numerical ratings and the “Superior” and “Commendable” ratings are much harder to get. There are four critical areas they look at now:
- NISPOM (32 CFR 117) Implementation — do that self-inspection!
- Management Support — keep your Senior Management in the loop!
- Security Awareness — Send out that awareness information!
- Security Community – Get your company to buy-in to the security program and share that with other FSOs.
DCSA looks closely at each area and defaults to your lowest rating. For instance, if in these areas you are Superior in three and Satisfactory in one, your overall rating is “Satisfactory”.
Side note— DCSA maintains that “Satisfactory” is “Success” but I have yet to meet a CEO that likes that rating. Let’s start a petition to get them to change it to “Success”, amIright?
As FSO PRO attends more and more inspections,
we will continue to share the latest updates and information with our subscribers.
We wish you a Merry DISS-mas!
We would not call ourselves experts in DISS just yet, but we do get more practice than the average FS-jOe (see what we did there? No? Too obscure? Anyway…).
If you have a question for a specific task or action in DISS, let us know and we will
work to get you the step-by-step instructions that we have created so you can
have an easier DISS-ember (see what we did there? C’mon—you get it, right?).
Need more explanation or assistance with any items mentioned this month?
Contact FSO PRO!
Looking for FSO Gifts? Check out the FSO PRO Shop!
* SVA Binders!
* Coffee Mugs!
* Membership Clubs—actively helping with the Security Awareness and Security Community portion of your inspections!
* Training Videos!
* One Hour FSO Support!
* Security Review Prep!
FSO PRO thanks all the FSOs out there for everything you do to keep the warfighter safe. Even the smallest task is designed to keep our nation’s information out of the hands of those who would do harm. We, as FSOs, are doing our part to stay vigilant and determined to protect those who protect us, even in our own small way.
That is why we say how awesome you are. And thank you.