Monday, May 24, 2010

Government Issued Identification for Contractor Employees

The CAC (Common Access Card) is the DoD term for a Personal Identity Verification (PIV) card. CACs are issued to Government and contractor personnel in order to gain access to Federal facilities, including Military Bases. In October 2008, the DoD-IG issued an audit report finding that Government controls over contractor CACs were very weak. The most prevalent finding was that CACs were not adequately accounted for after contract performance - there are thousands of unaccounted-for CACs floating around.

As part of the corrective actions, the FAR Councils proposed a new regulation designed to reinforce the requirement of collecting from contractors all forms of Government provided identification once they are no longer needed to support a contract. Specifically, Government contractors (and their subcontractors) must establish policies and procedures to account for all forms of Government-provided identification issued to Government contractors under a contract, and return such identification to the issuing agency at the earliest of any of the following,
  • when no longer needed for contract performance;
  • upon completion of a contractor employee's employment;
  • upon contract completion or termination.
This new requirement does not seem too onerous. Government contractors should be doing this anyway and most Government contractors probably have some form of procedure for collecting and returning unused CACs already. However, under the new regulation, the contracting officer now has the authority to delay final payment under a contract if the contractor fails to comply with these new requirements. Although not stated, the "delay period" probably extends until contractors are able to account for all CACs that have been issued to the company.

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