30-Day Comment Adjudication

July 28, 2017

PUBLIC COMMENT on 0704-AAEZ, “Contract Security Classification Specification:

“The DD Form 254 should contain a block for the contract expiration date adjacent to the contract number or some other easily identifiable location on the front page of the form. This would better help identify a valid, current contract. In terms of the DoD, any access capable of being loaded into JPAS, or its follow on database, should be represented in Block 10. Example: NC2-ESI is not listed in Block 10 but is an often used and overlooked access that requires the DD Form 254 to be reworked after the fact losing time and money for work not being accomplished.”

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RESPONSE TO FIRST PART OF COMMENT:

Response: DoD will add text in the instructions for the DD Form 254 as a new “c” under “Description” on the first page of the instructions top left corner that reads:

c. The contract itself includes the ending period of performance, including delivery or other requirements. The DD Form 254 is an attachment to the contract and does not include the contract expiration date. Putting the schedule or period of performance in two places creates a probability that a change in one place will not be repeated in the other, and thus could create confusion about whether the security requirements for the contract are current with the current schedule or period of performance.

RESPONSE TO SECOND PART OF COMMENT: In the DD Form 254 instructions for item 10k, "Other" on page 6 of 12, revise (2) to read as follows instead of what is there now:

(2) Access requirements other than those identified at items 10a through 10j. Check item 10k, "Other" and ensure accesses (including any that will have to be included in the DoD personnel security system of record for an individual performing on the contract) are identified, as stated in the Statement of Work or Addendums, in items 13 or 14, as appropriate.