Northrop Grumman CTM-P-ST-004 — U.S. Government Cost Reimbursement Order (Not for Commercial Products and Services)

Its 168 clauses can ask you for 312 things.

1. A program you have to be running32e.g. Fifteen named controls running on any system of yours that holds or carries the buyer's contract information 52.204-21(b)(1)

   You are either running it or you are not, and what the prime asks for is the date it started.

   • Reasonable procedures in place and in use to prevent and detect kickbacks in your own operations and in your direct business relationships

     FAR 52.203-7(c)(1)

   • An ethics awareness and training program, and an internal control system with a reporting channel such as a hotline that an employee can use anonymously

     Owed within 90 days of award, unless you represented yourself as a small business concern for this award or the contract is for a commercial product or commercial service — (c) opens by excluding both

     FAR 52.203-13(c)

   • A screening routine that takes a written disclosure of financial interests, outside employment and gifts from each employee assigned to the covered task, and updates it when their circumstances change

     Owed for covered employees — the people performing acquisition functions closely associated with inherently governmental functions

     FAR 52.203-16(b)(1)

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   • The security program the operating manual at 32 CFR part 117 requires — a facility security officer, cleared people, storage, marking, transmission and reporting

     Owed when the same access (a) limits the clause to, and it follows any revision of the manual you are given notice of

     52.204-2(b)(1)

   • Fifteen named controls running on any system of yours that holds or carries the buyer's contract information — access limits, authentication, media sanitization, boundary protection, timely patching and malware scanning

     Owed when federal contract information — information not intended for public release, provided by or generated for the Government under the order — resides in or transits your own system

     52.204-21(b)(1)

   • Scheduling that puts the rated order ahead of unrated work, and rated orders of your own placed on the suppliers of what it needs

     FAR 52.211-15

   • A listing practice, running for the life of the contract: every employment opening listed immediately with the appropriate employment service delivery system, and at least concurrently with any other recruitment source or effort you use

     41 CFR 60-300.5(a)(2) and (a)(3), which FAR 52.222-35(b) makes a term of your contract

   • E-Verify running inside hiring — a case opened for each new hire within three business days of the date of hire, starting within 90 calendar days of enrollment

     FAR 52.222-54(b)(1)(ii)

   • Paid sick leave for everyone working on or in connection with the contract, earned at not less than one hour for every 30 hours worked, up to the 56-hour annual cap

     FAR 52.222-62(c)(1)

   • Initial and annual role-based privacy training, with a test of what was learned

     Owed when an employee will have access to a system of records, handle personally identifiable information, or design, develop, maintain or operate a system of records

     52.224-3(b)

   • A private security operation run to 32 CFR part 159 — personnel registered and managed, weapons authorized and accounted for, armored vehicles registered, incidents reported

     FAR 52.225-26(c)(1)

   • Cost accounting that follows the disclosed practices consistently, applies any change prospectively, and complies with every standard in 48 CFR 9904

     FAR 52.230-2(a)(2) and (a)(3)

   • Cost accounting consistent with 48 CFR 9904.401, 9904.402, 9904.405 and 9904.406 — estimating matched to accumulation and reporting, no cost charged twice by two routes, unallowables handled, and one consistent accounting period

     FAR 52.230-3(a)(1)

   • Work environments and procedures that safeguard the public, Government personnel and Government property exposed to the operation, avoid interrupting Government operations or delaying the project completion dates, and control the cost of performance

     FAR 52.236-13(a)

   • On construction, dismantling, demolition or removal work for a Defense agency, a site run to the Corps of Engineers manual EM 385-1-1 in effect on the date of the solicitation

     FAR 52.236-13(c)

   and 17 more, each on its clause's page

2. Something somebody else has to issue you32e.g. Mill certificates giving the country of melt for every specialty metal incorporated in the item DFARS 252.225-7009

   The same day if the issuer is one of your own suppliers, months if it is an assessor or an underwriter.

   • A declaration carrying the certification and disclosure at 52.203-11(c) and (d), obtained from each person requesting or receiving the subcontract and retained by whoever awards it

     Owed where the subcontract exceeds the threshold specified in FAR 3.808 on the date of subcontract award — the clause names no figure, and 3.808 sets it at $200,000 since 2025-10-01

     FAR 52.203-12(g)(1)

   • The agency or Homeland Security fraud hotline poster the contract names, printed by the agency that issues it and displayed in common work areas and at the work sites in the United States

     Owed unless you already run a business ethics and conduct awareness program with a reporting mechanism — (c) drops the agency poster then, and never the Homeland Security one

     FAR 52.203-14(b)(1)

   • A written disclosure from your proposed supplier saying whether it or its principals are debarred, suspended, proposed for debarment or voluntarily excluded

     Owed from each proposed supplier whose subcontract will exceed the FAR 9.405-2(b) threshold, other than one furnishing a commercially available off-the-shelf item

     FAR 52.209-6(c)

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   • A safety data sheet for each of those items in the 29 CFR 1910.1200(g) and Federal Standard 313 form — owed whether or not you are the manufacturer, so for a distributor it comes from whoever made the material

     Owed by the apparently successful offeror before award; missing it can make an offeror nonresponsible

     FAR 52.223-3(d)

   • Country-of-origin statements from the suppliers of those components, since the percentage rests on parts somebody else made — and the prime asking for them sets what is enough

     FAR 52.225-1

   • The kinds and minimum amounts of insurance the contract Schedule names, carried at your own expense for the whole performance

     FAR 52.228-5(a)

   • An endorsement on those policies holding any cancellation or adverse material change ineffective until 30 days after written notice to the contracting officer, or the longer period state law prescribes

     FAR 52.228-5(b)

   • A legible copy of the carrier's rated on-board ocean bill of lading, to the contracting officer and to the Maritime Administration

     Owed when contract cargo has moved by sea — 20 working days from the date of loading in the United States, 30 working days from a foreign port

     FAR 52.247-64(c)

   • The DoD fraud, waste and abuse hotline poster in effect at award — printed by the DoD Inspector General, displayed in the common work areas of the segments doing the work

     DFARS 252.203-7004(b)(1)(i)

   • The Homeland Security fraud hotline poster alongside it, printed by the DHS Inspector General

     Owed when the work is paid for in whole or in part with DHS disaster relief funds and performed in the United States

     DFARS 252.203-7004(b)(2)

   • Level I antiterrorism awareness training completed for each person needing routine access, within 30 days of needing it and once a year after that

     Owed for each of your people whose work needs routine physical access to a federally controlled facility or military installation

     DFARS 252.204-7004(b)

   • A DoD-approved medium assurance certificate, bought from an outside certificate authority

     Owed when an incident has to be reported — the certificate is what the reporting channel authenticates against, so it is held before the incident rather than obtained after it

     252.204-7012(c)(3)

   • A cloud service provider meeting security requirements equivalent to the FedRAMP Moderate baseline, and complying with (c) through (g) on reporting and forensics

     Owed when covered information sits on a cloud service you did not build — the paragraph reaches an external provider only

     252.204-7012(b)(2)(ii)(D)

   • The contracting officer's written consent, given before any litigation information goes to an entity outside your organization

     DFARS 252.204-7014(b)(2)

   • The same completed assessment from each of your own suppliers, before anything is awarded to them

     Owed when you place a subcontract of your own that is subject to NIST SP 800-171 under 252.204-7012

     252.204-7020(g)(2)

   and 17 more, each on its clause's page

3. A state you have to be in, in a government system15e.g. A current CMMC status at the level written into the order 252.204-7021(d)(1)(i)

   The record has to be posted before the prime can see it, and posting is not the same day as being ready.

   • A facility clearance under the National Industrial Security Program, carried by a signed DD Form 441 security agreement

     Owed when the order actually involves access to information classified Confidential, Secret or Top Secret — paragraph (a) limits the clause to that extent

     52.204-2(b)(1)

   • Enrollment as a Federal Contractor in E-Verify, within 30 calendar days of award

     FAR 52.222-54(b)(1)(i)

   • An assessment of your covered systems completed inside the last three years, with the summary level scores posted in the Supplier Performance Risk System

     Owed when the subcontract is subject to NIST SP 800-171 under 252.204-7012 — (g)(2) bars the tier above from awarding until the assessment is done, and (g)(3) is the route to get the score posted

     252.204-7020(g)(2) and (g)(3)

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   • A current CMMC status at the level written into the order, or higher, held for the life of the work

     Owed when for every information system used on the work that processes, stores or transmits the information — the level is the value the contracting officer wrote into the blank at (d)(1)(i)

     252.204-7021(d)(1)(i)

   • An affirmation of continuous compliance, completed each year in the Supplier Performance Risk System by a named affirming official

     Owed when for each CMMC identifier covering a system used on the work, and it has to be current rather than merely on file

     252.204-7021(d)(3)

   • The results of a current self-assessment entered in that same system

     Owed when each CMMC identifier not covered by a C3PAO assessment or a DIBCAC assessment

     252.204-7021(e)(2)

   • An account in the Government's electronic submission system, with each item's record posted through it into the item unique identification registry

     DFARS 252.211-7003(f)

   • That serial number registered against the item's unique identifier at the time of delivery, in the registry the contract routes it to

     DFARS 252.211-7008(c)

   • Every deployed person entered in the Synchronized Predeployment and Operational Tracker, with the record kept current for the whole deployment

     DFARS 252.225-7040(g)

   • Your company affiliated with the Overseas Security Advisory Council

     Owed where the contractor or subcontractor performing outside the United States is a US entity

     DFARS 252.225-7043(b)(1)

   • Each of your US nationals registered with the US embassy

     Owed for personnel who are US nationals; third country nationals comply with their own embassy's security requirements instead

     DFARS 252.225-7043(b)(2)

   • Registration with the Department of State under the ITAR, which the clause names in its own words, for a shop that manufactures or exports defense articles

     DFARS 252.225-7048(b)

   • An authorized radio frequency allocation for the device, which is what lets it be tested or operated at all

     DFARS 252.235-7003(a)

   • Ownership eligibility for communications security equipment designated as a controlled cryptographic item

     Owed when the approved equipment for the work is designated a controlled cryptographic item

     252.239-7016(d)

   • A new identifier assigned, marked and registered in the IUID Registry

     Owed when an item is found already marked but not registered, and the (d)(1) conditions are met

     DFARS 252.245-7005(d)(4)
4. Something you write141e.g. A written code of business ethics and conduct FAR 52.203-13(b)(1)

   Days to weeks, and nobody outside your company has to agree to it.

   • A written report to the agency Inspector General, or to the Attorney General where the agency has none

     Owed promptly on reasonable grounds to believe a kickback described in (b) may have occurred

     FAR 52.203-7(c)(2)

   • A written code of business ethics and conduct, made available to each employee engaged in performance, within 30 days of award

     FAR 52.203-13(b)(1)

   • A written disclosure to the agency Inspector General, copy to the contracting officer

     Owed on credible evidence that a principal, employee, agent or subcontractor committed fraud, bribery, a gratuity or conflict of interest violation, or a civil False Claims Act violation

     FAR 52.203-13(b)(3)(i)

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   • An electronic copy of the same poster on the company website, where one is already used to reach employees

     FAR 52.203-14(b)(2)

   • A posted notice of employee whistleblower rights under section 1553 of the 2009 Recovery Act

     Owed where Recovery Act money funds the work — (b) carries the clause only into subcontracts funded in whole or in part with those funds

     FAR 52.203-15(a)

   • A signed nondisclosure agreement from each covered employee, barring use of nonpublic information for personal gain

     FAR 52.203-16(b)(2)(iii)

   • A written report to the contracting officer of a personal conflict-of-interest violation, with the actions proposed and follow-up reports on the corrective action

     Owed as soon as a violation by a covered employee is identified

     FAR 52.203-16(b)(6)

   • A written notice to employees, in the predominant language of the workforce, of their whistleblower rights under 41 U.S.C. 4712

     FAR 52.203-17(b)

   • A written notice to current employees and suppliers that existing confidentiality terms blocking a report of waste, fraud or abuse are no longer in effect

     Owed where agreements or statements signed before this contract carry prohibitions inconsistent with (b)

     FAR 52.203-19(c)

   • An account of every form of Government-provided identification issued to your employees, and those credentials returned at the earliest of the end of the work, the employee's separation, or the end of the contract

     FAR 52.204-9(b)

   • A written notice from a corporate officer to the contracting officer, naming the supplier, the reasons it is listed, the compelling reason for using it anyway, and the systems protecting the Government's interest

     Owed before entering into a subcontract with a party that is debarred, suspended, proposed for debarment or voluntarily excluded, other than one furnishing a commercially available off-the-shelf item

     FAR 52.209-6(d)

   • A written proposal to the contracting officer for approval, describing the supplies in detail — and for former Government surplus property, the material, the quantity, the agency it came from and the date it was acquired

     Owed when what you offer is used, reconditioned or remanufactured supplies, or unused former Government surplus property — (e) permits their use only where it was proposed and authorized

     FAR 52.211-5(d)

   • The flow-down list your own orders have to carry — the clauses named at paragraph (e)(1), each reaching as far as that clause itself says

     Owed when you place a subcontract of your own for commercial products or commercial services

     52.212-5(e)(1)

   • Either the substance of this clause or the substance of FAR 52.215-13, written into your own subcontracts

     Owed on each subcontract that, when entered into, exceeds the certified cost or pricing data threshold at FAR 15.403-4(a)(1) — $2.5 million

     FAR 52.215-12(c)

   • The substance of this clause, including paragraph (d) itself, written into your own subcontracts

     Owed on each subcontract that exceeds the certified cost or pricing data threshold on the date of agreement on price or the date of award, whichever is later

     FAR 52.215-13(d)

   and 126 more, each on its clause's page

5. Something you fill in and send back40e.g. A cyber incident report filed at dibnet.dod.mil within 72 hours of discovering the incident 252.204-7012(c)(1)(ii)

   Hours, once you know which one is missing.

   • Standard Form LLL naming the lobbying registrants, including the individuals performing the services

     Owed when no form went in with the offer and a registrant has since made a lobbying contact for you on this contract

     FAR 52.203-12(d)(1)

   • An updated Standard Form LLL to the contracting officer, within 30 days of the end of the calendar quarter the change fell in

     Owed where a form was already filed under 52.203-11(d) and a change affects Block 10 of it — the name and address of the registrant, or the individuals performing the services

     FAR 52.203-12(d)(2)

   • Your identity and award data for the prime's first-tier report — unique entity identifier, company name, physical address and the primary place of performance

     FAR 52.204-10(d)(2)

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   • The names and total compensation of your five most highly compensated executives for your preceding completed fiscal year

     Owed only where all of (d)(3) holds: in your preceding fiscal year 80 percent or more of your annual gross revenues came from federal contracts, subcontracts, loans, grants and other federal financial assistance; $25,000,000 or more of your annual gross revenues came from those same sources; and the public cannot already reach executive compensation figures through filings under section 13(a) or 15(d) of the Securities Exchange Act of 1934 or section 6104 of the Internal Revenue Code

     FAR 52.204-10(d)(3)

   • A report — contract number, supplier, brand, model number and item description — with mitigation detail and the prevention steps taken and planned within 10 business days after it

     Owed when you identify a Kaspersky Lab covered article in what you supply or use — the first report is due within three business days of that

     FAR 52.204-23(c)

   • A report — contract number, supplier, brand, model number, item description and any mitigation already under way — with further detail and prevention steps within 10 business days after it

     Owed when you identify covered telecommunications equipment or services in what you supply or use — the first report is due within one business day of that

     FAR 52.204-25(d)

   • A report — contract number, product or service name, the covered article or the source, the vendor, brand, model number and item description — with mitigation detail and prevention steps within 10 business days after it

     Owed when you identify a covered article or a prohibited source in what you furnish or will furnish — the first report is due within three business days of that

     FAR 52.204-30(c)(3)

   • A written acceptance or rejection of the rated order, back to the customer inside the window the priorities regulation sets and on the grounds it allows

     FAR 52.211-15

   • A signed Certificate of Current Cost or Pricing Data in the form at FAR 15.406-2, before award

     FAR 52.215-20(b)(2)

   • Interim vouchers billed against incurred cost

     FAR 52.216-7(a)

   • The Individual Subcontract Report and the Summary Subcontract Report, filed through the electronic subcontracting reporting system

     FAR 52.219-9(d)(10)

   • The VETS-4212 report to the Department of Labor each year by September 30 — protected veterans by category and location, total new hires, and how many of those were protected veterans

     FAR 52.222-37(b)

   • Standard Form 1444, Request for Authorization of Additional Classification and Rate, submitted to the buyer

     Owed when a class of employee that the wage determination does not list performs work on the contract — the form is due no later than 30 days after that work begins

     FAR 52.222-41(c)(2)(ii)

   • A certification to the buyer, at award and once a year after that, that the plan is implemented and that after due diligence nothing prohibited was found — or that remedial and referral action was taken

     Owed when the same $700,000 outside-the-United-States portion that brings the plan with it

     FAR 52.222-50(h)(5)

   • An immediate report to the buyer and to the agency inspector general, naming the action taken against whoever was responsible

     Owed when you receive credible information that an employee, agent or subcontractor has engaged in the prohibited conduct

     FAR 52.222-50(d)(1)

   and 25 more, each on its clause's page

6. Nothing to send now52They are terms that decide what money moves later or rules you follow while you work.