Subject: 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 Executive Orders

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

Effective Date: February 27, 2026

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 performing work for or on behalf of the Government are and continue to be reliable, trustworthy, and of good conduct and character. In a recent audit of VA’s compliance of this framework, it was determined that VA needed to strengthen contractor vetting requirements. In order to achieve this effort, VA must take three key steps to properly vet contractor employees: (1) VA officials must use the OPM, Position Designation Tool (PDT) to determine the position’s risk and sensitivity levels; (2) contracting officers ensure appropriate personnel security clauses are included in contracts, indicating the results from the PDT; and (3) Security Specialists ensure fingerprint checks and background investigations are conducted, and results are evaluated and adjudicated..

Applicability: This class deviation applies to all VA contracting activities.

Action Required: Contracting officers must comply with this 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 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, requiring contractor employees to have access to VA facilities, VA information, or to VA information systems.

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.