NISPOM Compliance Checklist for Cleared Contractors

Every cleared contractor has different operational realities, but the basic elements of a healthy security program are consistent. Documentation must be current, training must be completed, reviews must be performed, and leadership must understand how the program is being maintained. The checklist below is not a substitute for company-specific analysis, but it is a practical starting point for strengthening compliance and inspection readiness.

1. Program Management and Oversight

• Confirm the Facility Security Officer role is clearly assigned and understood.
• Ensure key leadership understands the company’s security obligations and current program status.
• Verify security responsibilities are not being handled only on an ad hoc basis.
• Review whether recurring tasks have an established cadence and ownership.
• Confirm the program can be sustained operationally, not just documented on paper.

2. Core Documentation

• Review security policies and procedures for accuracy and current applicability.
• Ensure required forms, internal records, and supporting documentation are organized and accessible.
• Check that employee briefings, debriefings, and acknowledgments are documented where required.
• Confirm records reflect current staffing, roles, and operational practices.
• Remove outdated or conflicting versions of program documents that could create confusion.

3. Training and Security Awareness

• Verify required security training is completed and documented.
• Ensure initial and recurring security briefings are being conducted appropriately.
• Review insider threat awareness training status and supporting records.
• Confirm training content aligns with actual responsibilities and work environments.
• Check that training is more than a one-time event and is reinforced as needed.

4. Self-Inspections and Corrective Action

• Confirm annual self-inspections are being completed on schedule.
• Document findings clearly and track corrective actions to closure.
• Look for repeat issues that suggest weak follow-through or incomplete process improvement.
• Verify leadership is aware of meaningful program gaps and remediation priorities.
• Use self-inspections as a management tool, not just a compliance exercise.

5. Personnel Security Practices

• Review whether access is aligned with eligibility, need-to-know, and role requirements.
• Confirm personnel security actions and records are maintained accurately.
• Ensure changes in employment status, role, or access needs are reflected promptly.
• Check whether onboarding and offboarding practices include required security actions.
• Look for gaps in follow-up where employees, managers, or program owners may assume others handled the task.

6. Physical and Information Security Controls

• Verify classified information handling practices are clear and consistently followed.
• Review storage, transmission, reproduction, and destruction procedures for compliance.
• Confirm physical access controls support the sensitivity of the information and spaces involved.
• Ensure safeguarding practices are documented and understood by personnel with access.
• Look for informal workarounds that may indicate process breakdowns or weak controls.

7. Insider Threat Program Requirements

• Confirm the insider threat program structure is defined and supported appropriately.
• Ensure required training and awareness elements are being executed.
• Verify records are maintained to demonstrate the program is functioning as intended.
• Assess whether the program is integrated into broader security management, not isolated from it.
• Check whether reporting expectations and escalation paths are understood.

8. DCSA Review Readiness

• Make sure key records can be produced quickly and confidently.
• Review whether documentation reflects actual practice, not just intended policy.
• Identify any weak areas that may draw questions during an external review.
• Ensure leadership understands where the program is strong and where risk remains.
• Address known gaps before they become inspection findings or customer concerns.

Final Checklist Review

The strongest NISPOM compliance programs are not the ones with the most paperwork. They are the ones where responsibilities are clear, execution is consistent, and documentation reflects reality. Cleared contractors should use a checklist like this to test whether the program is operating in a controlled, repeatable way rather than relying on memory or last-minute preparation.

If a review of these areas reveals uncertainty, inconsistency, or weak follow-through, that is usually a sign the program needs additional structure, support, or oversight.