Deployment processing for contractor personnel

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1. Theater admission

Under 32 CFR 158.5, special area, country and theater personnel clearance documents must be current under the Defense Foreign Clearance Guide (32 CFR 158.5(i)). They must be coordinated with affected agencies so that entry requirements do not harm the mission. Contractors authorized to accompany the force (CAAF) who support Defense missions are treated as Defense-sponsored personnel for Foreign Clearance Guide purposes (32 CFR 158.5(i)(1)).

Contracting officers must make sure contracts require contractor personnel to meet theater personnel clearance requirements before entering a designated theater (32 CFR 158.5(i)(2)). The contract must also require personnel to obtain those clearances through the Aircraft and Personnel Automated Clearance System. Contracts must also require personnel to obtain passports, visas and other documents needed to enter and leave the area (32 CFR 158.5(i)(3)). Personnel must have a Geneva Conventions identification card or other appropriate Defense credential from the deploying center.

2. Deployment centers

Contracts must detail the need for contractors to follow these credentialing requirements, as 48 CFR subpart 225.3, DFARS 252.225-7040 and the Foreign Clearance Guide require (32 CFR 158.5(j)). At a minimum, contracting officers must make sure contracts address requirements specific to the operational area. They must also say how the Department will inform contractor personnel of the requirements and procedures for their deployment.

A formally designated group, joint or Military Department deployment center conducts deployment and redeployment processing for CAAF (32 CFR 158.5(j)(1)). The exception is where the combatant commander or designee authorizes or waives contractor-performed theater admission preparation. If the contract specifies another government-authorized process that includes all the functions of a deployment center, the contractor may also use that process.

3. Medical preparation

Contracts must require contractors to provide medically and physically qualified personnel, in line with the medical rules in 32 CFR 158.6 (32 CFR 158.5(j)(2)(i)). Any CAAF found unsuitable to deploy for medical or dental reasons during the deployment process will not be authorized to deploy (32 CFR 158.5(j)(2)(i)(A)). The Secretary of Defense may direct immunizations as mandatory for CAAF performing essential contractor services (32 CFR 158.5(j)(2)(i)(B)). For American citizen CAAF, contracts must require contractors to make available the medical and dental records of deploying employees who authorize release (32 CFR 158.5(j)(2)(i)(C)).

Government personnel may not involuntarily immunize contractor personnel or require them to disclose their medical records involuntarily (32 CFR 158.5(j)(2)(ii)). The contracting officer therefore gives contractors time to notify or hire employees who voluntarily accept government medical requirements, including required immunizations and disclosure of medical information. All CAAF receive medical threat briefings at the deployment center on health risks and countermeasures in the operational area (32 CFR 158.5(j)(2)(iii)). Contracts must specify health readiness and force health protection capability, as a duty of either the contractor or the Defense components, and health surveillance must include plans for CAAF (32 CFR 158.5(j)(2)(iii)(A) and 32 CFR 158.5(j)(2)(iii)(B)).

4. Training

Joint training policy and guidance apply to both members of the military services and contractor personnel (32 CFR 158.5(j)(3)). Combatant commanders place standing training requirements on the command’s operational contract support web page for contractors to consult. Training requirements specific to an operation go on the page shortly after they are identified, so contracting officers can add them to contracts as soon as possible. Training requirements must be included, or incorporated by reference, in contracts employing contractor personnel who support applicable operations (32 CFR 158.5(j)(3)(i)). They include requirements set by the combatant commander and training required by part 158 and by 32 CFR part 159 (32 CFR 158.5(j)(3)(ii)).

5. At the deployment center

Affected contracts must require all CAAF deploying from outside the operational area to process through a designated deployment center, or a government-authorized contractor-performed facility, and to redeploy the same way (32 CFR 158.5(j)(4)). On receiving the company’s certification that employees meet deployability requirements, the contracting officer or representative digitally signs the letter of authorization. The employee then presents it to officials at the deployment center.

The process includes verifying registration in the Synchronized Predeployment and Operational Tracker-Enterprise Suite (SPOT-ES), issuing government-furnished equipment and verifying medical and dental screening (32 CFR 158.5(j)(4)). It also includes administering theater-specific immunizations and medications not available from public healthcare providers. The center verifies, and where necessary provides, required training and country and cultural awareness briefings (32 CFR 158.5(j)(4)(v)). The rule gives thirteen examples of required training. They are law of war, detainee and interrogation law where appropriate, general orders, standards of conduct, force protection, personnel recovery and first aid. The others are combating trafficking in persons, operational security, anti-terrorism, counterintelligence reporting, use of chemical, biological, radiological and nuclear protective ensembles, and a deployment health threats briefing.

6. Certification, legal affairs and waivers

Contracts must require contractors to certify to the authorized government representative, before deployment, that each individual has completed all required deployment processing (32 CFR 158.5(j)(5)). Contractor personnel are not entitled to military legal assistance in theater or at the deployment center (32 CFR 158.5(j)(6)). They must have their personal legal affairs in order, such as powers of attorney, wills, trusts and estate plans, before reporting.

For required contracted support of 17 days or less in an operational area, the combatant commander or designee may waive part of the formal procedural requirements (32 CFR 158.5(j)(7)). That may include waiving in writing the requirement to process through a deployment center. The waiver cannot cover the requirements to hold proper identification cards and to maintain accountability for all contractor personnel. Nor can it cover any medical requirement without prior approval of the cognizant medical authority. If a contract authorizes contractor personnel to be armed, the requirements on private security authorization and on reception and integration in theater may not be waived. The medical standards themselves are covered in medical and dental fitness for deploying contractors.

Key terms

Foreign Clearance Guide	The Defense guide governing area, country and theater clearance documents.
Deployment center	A designated group, joint or Military Department center that processes CAAF in and out.
Deployability certification	The contractor’s certification that each individual completed deployment processing.
Digitally signed letter	The letter of authorization the contracting officer or representative signs after that certification.
Short-duration waiver	A partial waiver of procedures for support of 17 days or less.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

Deployment processing is the first step in moving people safely into theater. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.