I’ve been a cleared 1099 sub-contractor since 2015. One of the concerns I had when I first started was how to keep my security clearance “active,” meaning I wanted to be able to take on projects that require a security clearance without having to start from scratch on the process.
This was important because there is a higher demand and smaller supply of folks with clearances, making me more competitive as a 1099 subcontractor.
Over the last five years, I’ve made a few mistakes and have been subject to the mistakes of others to the tune of $200,000 in lost revenue over that time period due to security clearance issues.
5 Lessons on Managing a Security Clearance as a 1099 Subcontractor
Here are five lessons I learned the hard way that can help you avoid losing time and money as a 1099:
1. Make sure at least one prime contractor “owns” your clearance
An organization that hires you can either have an “owning” or “servicing” relationship with you in the Defense Information Security System (DISS), the system of record for government contractor security clearance.. Owning implies that the organization would take a broader responsibility for your clearance and do things like submit your re-investigation paperwork.
A “servicing” relationship by contrast simply allows you to perform cleared work with that particular company or organization, but they won’t handle much beyond that in a practical sense.
When you take on your first 1099 project, make sure that the company you are working for takes an “owning” relationship with you as a consultant. This is important because your previous employer may not have changed your status in DISS and the path of least resistance is for your new prime FSO is to bring you on with a “servicing” relationship. You can begin work, but if you need to resolve issues with your clearance, the Facility Security Officer (FSO) won’t be able to help you.
This might not be a problem initially but if you need help resolving any issues with your clearance (like submitting a re-investigation request), this could lead to costly delays.
As you switch projects, just ensure at least one company owns your clearance and that you maintain a good relationship with them, lest you get stuck in administrative limbo in DISS.
2. Be proactive about validating your security clearance information
FSOs, particularly at large companies, are busy. More importantly, they will prioritize their own employees’ security clearance administration over any 1099s.
What this means is you need to be extra diligent about knowing the status of your clearance. By keeping tracking of key pieces of information, you’ll know when your need to submit a re-investigation request, what potential obstacles there will be to switching projects, and how to help the FSO troubleshoot issues with your clearance.
Here are a pieces of information you can validate with your current FSO.
- If your investigation is open or closed
- The date of the last closed investigation
- If you are in the continuous evaluation program
- If your investigation has been fully adjudicated
- Date of your most recent adjudication
- Level of security clearance adjudication (Secret, Top Secret, Top Secret/SCI, etc.)
- If your FSO has contacted DCSA in case your investigation has been closed but not adjudicated
- If your FSO has contacted CAF if your adjudication is taking a particularly long time
- If the customer agency has received your clearance information or has been notified of any updates about a recently completed investigation or adjudication
Knowledge is money as a 1099.
3. Don’t assume your clearance will “crossover” in a timely manner
I have been burned a few times by assuming my clearance was in tip top shape and that I would be able to start a on a new project relatively quickly.
The first time was when I was starting on a new project at NGA. I was already badged, still active on a contract there, and had a desk and access to my accounts. So…no brainer right?
Wrong!
Apparently, because I still had an active re-investigation going on, the security office wanted to re-adjudicate me before approving me to start work on the new contract.
That took three months and some prodding by the program manager to the head of the personnel security office there. I could have made around $50,000 in that time frame.
The second time was when I secured a new project at the Department of Homeland Security (DHS) in June of 2020. My TS/SCI clearance was adjudicated in March of 2020 by another agency and based on the very recent adjudication, I once again thought the process should only take a few weeks. The program manager had some recent data points suggesting that would be the case.
Well, I didn’t get approved and adjudicated by DHS until November of 2020! I learned that under current reciprocity guidelines, if you have a close relationship with a foreign national (my mother in this case), agencies can conduct further investigation and not apply reciprocity off the bat.
I never did start on that DHS project because a few other projects were “faster” in terms of getting me on-boarded.
Five months of delays was around $80,000 – $100,000 in income I didn’t earn.
So even if you think your clearance is good to go, you should mitigate the risk by either staying on your current project until you get an actual indoc/start date or come up with alternative plans in case there are multi-month delays with your crossover.
4. Never assume anything will every go “quickly”
This is a broader application of lesson number three.
This is the government. Things generally do not move at a reasonable pace. As a 1099, this is incredibly frustrating because time is money.
While you can be proactive and diligent about doing your part, I guarantee there will be delays.
So plan around it, assume things will take five times as long as it should. This will make for a less stressful 1099 career.
5. Don’t leave your current project until you have an indoc date on your new contract
Let’s say you secured a new project for yourself and you are excited to start. You decide you want to take a few weeks off so you de-brief from your current project and expect to start on your new project after your time off. They just need to sort out some clearance crossover paperwork.
You know what Murphy’s law says? Something weird will happen and the security officer that is handling your new contract will need to review something and they can’t give you an estimated start date.
Meanwhile, you are sitting there not billing hours and losing money.
Don’t do this. Stay on your current project until you have a confirmed start date. Then plan any vacations and time off.
Bonus Round – Look For Upgrades
I had a Secret clearance when I entered the Navy. Before I left, I asked the FSO to bump me up to a Top Secret.
He asked why, and I said I might need it when I got out for future jobs
He submitted the paperwork, and I received a Top Secret clearance which set me up for TS and TS/SCI projects as a W2 employee and as a 1099 sub-contractor years later.
If you currently have a lower level clearance, there is no harm in asking your prime FSO to upgrade you so you can support one of their projects at a higher clearance level – if you’re not worried about skeletons in your closet.
As a solo 1099, you will have to be extra diligent about maintaining your clearance. But by taking the appropriate precautions and proactive measures, you can manage the risks of being stuck on the bench and out of work.
