Subject: Supplement to Class Deviation dated February 26, 2026, entitled “VA Acquisition Regulation (VAAR) Class Deviation to VAAR Part 804, Administrative and Information Matters and Part 852, Solicitation Provisions and Contract Clauses, to Strengthen Compliance with Contractor Personnel Vetting.”

Purpose: Issue a supplement to a class deviation that was issued in accordance with Federal Acquisition Regulation (FAR) 1.404, and VAAR 801.404, Class deviations, to clarify the requirement for personnel vetting and credentialing for contractor employees that have access to Department of Veterans Affairs (VA) facilities, VA information, and VA information systems.

VAA Parts Referenced: VAAR parts 804 and 852.

Effective Date: Immediately.

Expiration Date:  NA

Background: VA is required to comply with executive orders, Federal regulations, and VA requirements for vetting contractor employees. Every contractor employee must be vetted before beginning work at VA. The vetting requirement was established to ensure all contractor employees who perform work for or on behalf of the Government are and continue to be reliable, trustworthy, and of good conduct and character.

Applicability: This supplement to a class deviation applies to all VA contracting activities and contracting officers.

Action Required: Contracting officers must comply with this supplement to class deviation by inserting deviated VAAR clause at 852.204-70, Personal Identity Verification of Contractor Personnel, and new VAAR clause at 852.204-72, Personnel Vetting and Credentialing, in solicitations and contracts that require contractors or contractor employees to have un-escorted, physical access to a VA facility or logical access to VA information, or to VA information systems. Contracting officers must incorporate the clause at 852.204-72 in any existing contract, not otherwise physically complete (see FAR 4.804-4) or have more than 6 months remaining. Contracting officers are expected to add the clause to their contracts as soon as practically possible, so enforcement of the clause may begin at option exercise. Contracting officers have discretion regarding the need to enforce or amend the contract when contracts have no option periods left to exercise. Note that without inclusion of the new clause, the contracting officer may be required to separately address any access issues that arise during performance of the contract.

Contracting officers should be aware that non-Personal Identity Verification (PIV) cards are now PIV-1 cards and there are no longer any exceptions. Contracting officers should also be aware any position that does not go longer than 180 calendar days per year does not require a background investigation for suitability or fitness but at a minimum, a Fingerprint Special Agreement Check must be completed, and PIV-1 card must be issued.

Additional Information: Direct questions or concerns regarding this deviation to the Office of Acquisition and Logistics (003A), Procurement Policy and Warrant Management Service (003A2A), at va.procurement.policy@va.gov.