Federal Contract Information

What Is Federal Contract Information (FCI)?

As defined in Federal Acquisition Regulations (FAR) , federal contract information (FCI) is “information, not intended for public release, that is provided by or generated for the Government under a contract to develop or deliver a product or service to the Government, but not including information provided by the Government to the public (such as on public websites) or simple transactional information, such as necessary to process payments.â€Ìý

Documents that include FCI may include:
  • Documents handled by OCG and PIs (awards, reports, subcontract agreements, emails and communications).Ìý
  • Information handled only by the PI (project data received from the federal government or produced by ¶¶ÒõÂÃÐÐÉä, project notes, basic technical data, timelines, schedules and milestones, logistical information).Ìý
  • Information handled by other departments (financial reporting if not transactional).Ìý
What is NOT considered FCI:
  • Public Information: Data that the government has already released to the public is not FCI.ÌýÌý
  • Proposals unless a proposal, in very rare cases, is submitted under a contract.Ìý
  • Fundamental Research ResultsÌý
  • Information Related to a Project not Under the Contract: Information related to a project that has been provided by the government or generated by the University prior to a contract being signed.Ìý
  • Simple Transactional Data: Information necessary solely for processing payments, such as invoice details, is generally excluded.Ìý

¶¶ÒõÂÃÐÐÉä Boulder’s Support for Principal Investigators with FCI Requirements Ìý

Because, unlike Controlled Unclassified Information (¶¶ÒõÂÃÐÐÉäI), FCI is not marked and is in some cases difficult to determine as a contractor, OCG’s approach is as follows:Ìý

If a proposal or contract indicates a project will include handling FCI, OCG will work with the PI to clarify with the sponsor 1) if the project will include handling FCI and 2) if applicable, what is considered FCI.

Indications that a project includes handling FCI are references to:

  • Federal contract information (FCI)
  • Covered Contractor Information System
  • FAR clause 52.204-21 – Basic Safeguarding of Covered Contractor Information Systems
  • 48 CFR 52.204-21 – Basic Safeguarding of Covered Contractor Information Systems
  • CMMC Level 1

If the sponsor clarifies that the project will not include handling FCI:

  • At the proposal stage, the Proposal Team will move forward following normal processes.
  • At the award stage, OCG will request that the sponsor remove references to FCI from the contract, namely FAR 52.204-21, because they are not applicable.

If the sponsor confirms a project will include handling FCI, OCG will refer the PI to ¶¶ÒõÂÃÐÐÉä Boulder’s Information Technology Security Office (ITSO) to ensure the systems used meet the compliance requirements of FAR 52.204-21 for handling FCI.Ìý

  • Unless the sponsor confirms that the proposal itself is FCI, the proposal will move forward for submission following normal processes. Costs for handling FCI are an allowable cost and should be budgeted for in proposals.
  • OCG cannot finalize awards until the ITSO review with PIs is complete.Ìý

PIs are responsible for ensuring that all project personnel comply with the requirements discussed with ITSO.Ìý