March 29, 2023

DCSA Updates Facility Security Clearance Package Submission Procedures

Holland & Knight Alert
Andrew K. McAllister | Antonia I. Tzinova | Robert A. Friedman | Mackenzie A. Zales


  • The Defense Counterintelligence and Security Agency (DCSA), which processes facility security clearances (FCLs) for most government contractors, released updated guidance for the sponsorship and FCL package review process.
  • With the process changes, DCSA hopes to reduce the number of cycles per FCL package and lower the rejection rate for both sponsorship and initial/upgrade FCL packages.
  • At the same time, contractors will have fewer attempts to submit a complete package submission to DCSA without being completely removed from DCSA's queue.

Facility security clearance (FCL) sponsorship packages for U.S. government contractors currently have a rejection rate of more than 50 percent. For initial and upgrade FCL packages, there is a 70 percent rejection rate. These are the recent statistics released by the Defense Counterintelligence and Security Agency (DCSA), and the agency is seeking to reduce delays.

The Problem

The average FCL sponsorship package nearly always requires rework after DCSA review due to missing, incorrect or incomplete information or forms. According to DCSA, the average cycle for sponsorship packages is 1.93 times, and the average cycle for initial and upgrade FCL packages is 2.5 times. Understandably, these statistics manifest in delays in the FCL processing timeline, which impedes U.S. government contracting activities (GCAs) from receiving vital goods and services, financially harms U.S. government contractors and puts U.S. national security at risk.

The Solution

To address these issues, effective March 1, 2023, DCSA implemented more stringent rework and rejection procedures (Submission Procedures) intended to shorten the review timeline. Importantly, if a GCA or contractor does not address inaccurate or missing information that DCSA flags on a first review, DCSA will reject the package and completely remove it from the queue, requiring resubmission. The Submission Procedures indicate that DCSA will provide details concerning the missing information or items to be corrected and available resources (policy, forms, templates, etc.) that can be used to address the reasons for the return. For example, if a required exclusionary resolution from the contractor's board of directors is missing, DCSA may provide a template for the resolution. Further, DCSA commits to notifying the affected parties when returning, rejecting or discontinuing a package.


DCSA appears to be responding to certain criticisms from industry – namely that the sponsorship/FCL package process takes too long and there is a lack of transparency regarding submission deficiencies. The DCSA policy underscores the importance of bringing in experienced industrial security counsel early in the sponsorship and FCL package process to ensure any submissions are accurate and complete. If you have any questions about the sponsorship process or how to prepare a complete FCL package or need assistance addressing a package returned by DCSA, please reach out to the authors of this alert or another member of Holland & Knight's Facility Security Clearance Team.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.

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