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Change comes to the Defense Security Service: The Transition from e-FCL and ISFD to NISS on October 30, 2017

On October 30, 2017, the U.S. Department of Defense (DoD) Defense Security Service (DSS) will complete its transition to the National Industrial Security System (NISS). The NISS will replace two predecessor systems: the Industrial Security Facilities Database (ISFD), and the Electronic Facility Clearance System (e-FCL). This Alert describes some aspects of the change that are important for cleared contractors.

Background
The transition to NISS has been in the works for quite some time. The present IFSD system contains information on contractor facilities cleared by the DoD. The e-FCL system allows contractors to submit facility clearance applications to DSS in an electronic format. It was designed around the SF-328 form, and provides users an electronic interface to upload and submit required information into the system. The new platform will provide DSS with “next generation enterprise capability” and a “comprehensive enhanced capability to manage its entire mission portfolio.”

Among the benefits that DSS is expecting government and industry stakeholders to gain from the new system are technical and operational efficiencies through the consolidation of multiple legacy systems into one newer system. DSS also expects improvements in information transparency relating to the status of requests, better processes and processing capability including streamlined facility clearance processing, improved Foreign Ownership, Control, or Influence (FOCI) processing, automated alerts and notices, and improved features to track a company’s current and historical facility security information. Additionally, NISS allows multiple user roles for external users, including Facility Clearance Verifier, Facility Clearance Sponsor, and Industry Security Staff roles.

Transition to NISS

Both e-FCL and ISFD systems will be taken offline on October 14, 2017 and the last available access to these systems will be on October 13, 2017. This will allow the DSS to migrate data from the legacy systems to NISS between October 14th and the full deployment of NISS on October 30, 2017. Contractors should plan accordingly for this gap in system availability. According the DSS, contractors that wish to make changes during this period should work with their Industrial Security Representative (ISR) for specific instruction.

NISS is expected to incorporate data that is presently in both e-FCL and ISFD systems, with one notable exception. According to DSS, “any Initial or Change Condition packages in the Pending Submission status in e-FCL as of October 14 will not be migrated to NISS.” Consequently, users must plan to resubmit these packages into NISS after the full deployment of the system on October 30, 2017.

All organizational information in e-FCL and ISFD will also be migrated to NISS. Users with existing accounts in e-FCL and ISFD must register for accounts on the NISS system. This is done through the National Industrial Security Program (NISP) Central Access Information Security System (NCAISS).

Finally, as mentioned previously, NISS will allow multiple roles, and will allow a user to switch between roles. Clients should familiarize themselves with this process and, as necessary, revise internal guidance so that users are clear on how to change roles and the implications of doing so.

For More Information

Hogan Lovells is always available to help you navigate this transition to NISS. If you have questions on the transition of your data from e-FCL and ISFD to the NISS system, please contact the authors of this post.