Procurement Information Circular
May 1, 2008
CLASS DEVIATION TO NASA FAR SUPPLEMENT 1852.204-76 SECURITY REQUIREMENTS FOR UNCLASSIFIED INFORMATION TECHNOLOGY RESOURCES
PURPOSE: To provide a class deviation that temporarily removes the requirement from NASA FAR Supplement (NFS) 1852.204-76 for contractor system administrators to be certified, and specifically to be certified through the NASA System Administrator Security Certification Program.
BACKGROUND: Procurement Information Circular (PIC) 04-03 addressed the Office of the Chief Information Officer (OCIO) System Administrator Security Certification Program. The program required that potential contractor system administrators complete third-party certification testing, underwritten by NASA. PIC 04-03 was cancelled on January 22, 2008, because NASA’s current position is that the certification of contract system administrators by agencies is beyond the scope of the Computer Security Act of 1987 and OMB Circular A-130.
NFS 1852.204-76, Security Requirements for Unclassified Information Technology Resources, includes a requirement for contractor certification and for contractors to comply with NASA’s System Administrator Security Program. The requirement for compliance is being removed from the clause because the program no longer exists.
NFS clause 1852.204-76 is currently being rewritten to address numerous issues. The deletion of the certification requirement will be made a permanent change as a result of the clause rewrite. This deviation is necessary, on a temporary basis, pending formal rulemaking on the new replacement clause.
GUIDANCE: This deviation authorizes contacting officers to utilize the enclosed, deviated version of NFS 1852.204-76 which removes the requirement for compliance with NASA’s System Administrator Security Certification Program from paragraph (b)(6).
EFFECTIVE DATE: This PIC is effective as dated and shall remain in effect until implemented in the NFS or otherwise rescinded.
HEADQUARTERS CONTACT: Leigh Pomponio, Contract Management Division, (202) 358-0592, e-mail: firstname.lastname@example.org.
/s/ Deborah O’Neill for
William P. McNally
Administrator for Procurement
As prescribed in 1804.470-4(a), insert the following clause:
SECURITY REQUIREMENTS FOR UNCLASSIFIED INFORMATION TECHNOLOGY RESOURCES
(MAY 2008) (Deviation)
(a) The Contractor shall be responsible for information and information technology (IT) security when –
(1) The Contractor or its subcontractors must obtain physical or electronic (i.e., authentication level 2 and above as defined in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-63, Electronic Authentication Guideline) access to NASA's computer systems, networks, or IT infrastructure; or
(2) Information categorized as low, moderate, or high by the Federal Information Processing Standards (FIPS) 199, Standards for Security Categorization of Federal Information and Information Systems is stored, generated, processed, or exchanged by NASA or on behalf of NASA by a contractor or subcontractor, regardless of whether the information resides on a NASA or a contractor/subcontractor’s information system.
(b) IT Security Requirements.
(1) Within 30 days after contract award, a Contractor shall submit to the Contracting Officer for NASA approval an IT Security Plan, Risk Assessment, and FIPS 199, Standards for Security Categorization of Federal Information and Information Systems, Assessment. These plans and assessments, including annual updates shall be incorporated into the contract as compliance documents.
(i) The IT system security plan shall be prepared consistent, in form and content, with NIST SP 800-18, Guide for Developing Security Plans for Federal Information Systems, and any additions/augmentations described in NASA Procedural Requirements (NPR) 2810, Security of Information Technology. The security plan shall identify and document appropriate IT security controls consistent with the sensitivity of the information and the requirements of Federal Information Processing Standards (FIPS) 200, Recommended Security Controls for Federal Information Systems. The plan shall be reviewed and updated in accordance with NIST SP 800-26, Security Self-Assessment Guide for Information Technology Systems, and FIPS 200, on a yearly basis.
(ii) The risk assessment shall be prepared consistent, in form and content, with NIST SP 800-30, Risk Management Guide for Information Technology Systems, and any additions/augmentations described in NPR 2810. The risk assessment shall be updated on a yearly basis.
(iii) The FIPS 199 assessment shall identify all information types as well as the “high water mark,” as defined in FIPS 199, of the processed, stored, or transmitted information necessary to fulfill the contractual requirements.
(2) The Contractor shall produce contingency plans consistent, in form and content, with NIST SP 800-34, Contingency Planning Guide for Information Technology Systems, and any additions/augmentations described in NPR 2810. The Contractor shall perform yearly “Classroom Exercises.” “Functional Exercises,” shall be coordinated with the Center CIOs and be conducted once every three years, with the first conducted within the first two years of contract award. These exercises are defined and described in NIST SP 800-34.
The Contractor shall ensure coordination of its incident response team
with the NASA Incident Response Center (NASIRC) and the
(4) The Contractor shall ensure that its employees, in performance of the contract, receive annual IT security training in NASA IT Security policies, procedures, computer ethics, and best practices in accordance with NPR 2810 requirements. The Contractor may use web-based training available from NASA to meet this requirement.
(5) The Contractor shall provide NASA, including the NASA Office of Inspector General, access to the Contractor’s and subcontractors’ facilities, installations, operations, documentation, databases, and personnel used in performance of the contract. Access shall be provided to the extent required to carry out IT security inspection, investigation, and/or audits to safeguard against threats and hazards to the integrity, availability, and confidentiality of NASA information or to the function of computer systems operated on behalf of NASA, and to preserve evidence of computer crime. To facilitate mandatory reviews, the Contractor shall ensure appropriate compartmentalization of NASA information, stored and/or processed, either by information systems in direct support of the contract or that are incidental to the contract.
The Contractor shall ensure that system administrators who perform tasks
that have a material impact on IT security and operations demonstrate knowledge
appropriate to those tasks.
Knowledge is demonstrated
through the NASA System Administrator Security Certification Program. A system administrator is one who provides IT
services (including network services, file storage, and/or web services) to
someone other than themselves and takes or assumes the responsibility for the
security and administrative controls of that service. Within 30 days after contract
award, the Contractor shall provide to the Contracting Officer a list of all
system administrator positions and personnel filling those positions, along
with a schedule that ensures certification of all personnel within 90 days
after contract award. Additionally, the
Contractor should report all personnel changes which impact system
administrator positions within 5 days of the personnel change and ensure these
individuals obtain System Administrator certification within 90 days after the
(7) The Contractor shall ensure that
NASA’s Sensitive But Unclassified (SBU) information as defined in NPR 1600.1,
NASA Security Program Procedural Requirements, which includes privacy
information, is encrypted in storage and transmission.
(8) When the Contractor is located at a
(i) Submit requests for non-NASA provided external Internet connections to the Contracting Officer for approval by the Network Security Configuration Control Board (NSCCB);
(ii) Comply with the NASA CIO metrics including patch management, operating systems and application configuration guidelines, vulnerability scanning, incident reporting, system administrator certification, and security training; and
(iii) Utilize the NASA Public Key Infrastructure (PKI) for all encrypted communication or non-repudiation requirements within NASA when secure email capability is required.
(c) Physical and Logical Access Requirements.
(1) Contractor personnel requiring access
to IT systems operated by the Contractor for NASA or interconnected to a NASA
network shall be screened at an appropriate level in accordance with NPR 2810
and Chapter 4, NPR 1600.1, NASA Security Program Procedural Requirements. NASA shall provide screening, appropriate to
the highest risk level, of the IT systems and information accessed, using, as a
minimum, National Agency Check with Inquiries (NACI). The Contractor shall
submit the required forms to the NASA Center Chief of Security (CCS) within
fourteen (14) days after contract award or assignment of an individual to a
position requiring screening. The forms
may be obtained from the CCS. At the
option of NASA, interim access may be granted pending completion of the
required investigation and final access determination. For Contractors who will reside on a
(2) Guidance for selecting the appropriate level of screening is based on the risk of adverse impact to NASA missions. NASA defines three levels of risk for which screening is required (IT-1 has the highest level of risk).
(i) IT-1 -- Individuals having privileged access or limited privileged access to systems whose misuse can cause very serious adverse impact to NASA missions. These systems include, for example, those that can transmit commands directly modifying the behavior of spacecraft, satellites or aircraft.
(ii) IT-2 -- Individuals having privileged access or limited privileged access to systems whose misuse can cause serious adverse impact to NASA missions. These systems include, for example, those that can transmit commands directly modifying the behavior of payloads on spacecraft, satellites or aircraft; and those that contain the primary copy of “level 1” information whose cost to replace exceeds one million dollars.
(iii) IT-3 -- Individuals having privileged access or limited privileged access to systems whose misuse can cause significant adverse impact to NASA missions. These systems include, for example, those that interconnect with a NASA network in a way that exceeds access by the general public, such as bypassing firewalls; and systems operated by the Contractor for NASA whose function or information has substantial cost to replace, even if these systems are not interconnected with a NASA network.
(3) Screening for individuals shall employ forms appropriate for the level of risk as established in Chapter 4, NPR 1600.1.
(4) The Contractor may conduct its own screening of individuals requiring privileged access or limited privileged access provided the Contractor can demonstrate to the Contracting Officer that the procedures used by the Contractor are equivalent to NASA's personnel screening procedures for the risk level assigned for the IT position.
(5) Subject to approval of the Contracting Officer, the Contractor may forgo screening of Contractor personnel for those individuals who have proof of a --
(i) Current or recent national security clearances (within last three years);
(ii) Screening conducted by NASA within the last three years that meets or exceeds the screening requirements of the IT position; or
(iii) Screening conducted by the Contractor, within the last three years, that is equivalent to the NASA personnel screening procedures as approved by the Contracting Officer and concurred on by the CCS.
(d) The Contracting Officer may waive the requirements of paragraphs (b) and (c)(1) through (c)(3) upon request of the Contractor. The Contractor shall provide all relevant information requested by the Contracting Officer to support the waiver request.
(e) The Contractor shall contact the Contracting Officer for any documents, information, or forms necessary to comply with the requirements of this clause.
(f) At the completion of the contract, the contractor shall return all NASA information and IT resources provided to the contractor during the performance of the contract and certify that all NASA information has been purged from contractor-owned systems used in the performance of the contract.
(g) The Contractor shall insert this clause, including this paragraph (g), in all subcontracts
(1) Have physical or electronic access to NASA's computer systems, networks, or IT infrastructure; or
(2) Use information systems to generate, store, process, or exchange data with NASA or on behalf of NASA, regardless of whether the data resides on a NASA or a contractor’s information system.
(End of clause)