EMBASSY
OF
THE
UN
ITED STATES
OF
AME
RI
CA
UN
I
TED
STATES
SEN
DI
NG STATE
OFF
I
CE
FO
R IT
ALY
UN
IT 9500 BOX 65
DPO, AE 09624-0065
USSSOINST 2010.01
25 Jan 2024
U.S. SENDING STATE OFFICE FOR ITALY INSTRUCTION 2010.01
SUBJ: CIVILIAN COMPO
NENT
AND TECHNICAL REPRESENTATI
VE
STATUS AND
ACCREDITATION PROCEDURES
Ref: (a)
NATO
SOFA: Agreement Between the Parties to the North A
tl
antic Treaty
Regarding the Status
of
Their Forces signed on 19 June 1951 ratified in Italy as
Law No. 1335 on 30 November 1955.
(b) Shell Agreement: Memorandum
of
Understanding Between the Ministry
of
Defense
of
the Repub
li
c
of
Italy and the Department
of
Defense
of
the United States
of
America Concerning Use oflnstallations/lnfrastructure by the U.S. Forces
in
Italy, 2
February 1995 ( commonly referred to as the "She
ll
").
(c) Tri-Service Directive on Personal Property, Rationed Goods, Motor Vehicles and
Drivers' Licenses, Civilian Component a
nd
Technical Representative Status
(COMUSNA VEUR INST. No. 5840.2E; USAREUR REGULATION No. 550-32;
USAFE INSTRUCTION No. 36-101), 20 February 2004.
(d) USEUCOM Policy Memorandum 04-04 (Civilian Personnel Accreditation in the
Republic
of
Italy)
1.
Purpose.
a. This instruction provides overa
ll
guidance on accreditation
of
Civilian Personnel under the
Shell who are not employed directly by the US Government in Italy.
b.
This instruction provides specific guidance
on
seeking accreditati
on
of
DoD
contractor employees as Technical
Re
pr
esentatives (TRs) in Italy.
c. This instruction establishes procedures for defining contract positions that may qualify as
TR
positions, and for accrediting individual contractor employees
as
TR
s.
2.
Authority:
a.
Reference (d) confers executive agent authority
on
the United States Sending State Office
(USSSO) to accredit civilian personnel.
b.
This authority exten
ds
throughout Italy for a
ll
service components.
3.
Background.
USSSOINST 2010.01
25
Jan 2024
a.
The Shell Agreement provides that persons closely affiliated with the U.S. Forces and
under their authority, but not employed by them, may be designated as Civilian Personnel.
A Civilian Personnel employee is exempt from the payment ofltalian income tax, is eligible
for individual logistical support (ILS), and is required to be
in
possession
of
a mission visa,
placed in a regular (tourist) passport prior
to
entry into Italy. Italian citizens, dual citizens
of
Schengen countries, and persons ordinarily resident in Italy cannot be accredited as Civilian
Personnel.
4. Responsibilities.
a.
United States Sending State Office for Italy (USSSO): The U.S. European Command
(EU COM) office, at the American Embassy, Rome, is responsible for implementing the
accreditation
of
Civilian Personnel in accordance with references (a) through (c).
b.
DoD Contrnctor Personnel Office (DOCPER): The office designated
by
EUCOM
to
process on behalf
of
the
USS
SO applications for accreditation as Civilian Personnel.
c.
Servicing Staff Judge Advocate: The Staff Judge Advocate (SJA) office designated
to carry out necessary legal functions in connection with the process
of
accreditation
of
Civilian Personnel. Each military component command may designate one or more such
offices.
5.
Definitions.
a.
Civilian Component is defined in Article I
(l.b)
ofreference (a) (NATO SOFA), as
civilian personnel accompanying a force
of
a Contracting Party (the United States in this
case), who are in the employ
of
an armed service
of
that Contracting Party, and who are not
stateless persons, nor nationals
of
any State which is not a NATO Contracting Party, nor
nationals of, nor ordinarily resident in the State in which the force is located.
b. Civilian Personnel is defined in reference (b) as persons who are closely affiliated with
U.S. Forces and under their authority, but are not employed directly by them, on the condition
that the presence
of
such persons in Italy is recognized by both governments as necessary in
connection with the functioning
of
the installations. Personnel eligible for Civilian Personnel
status are not stateless persons, nor nationals
of
any State which is not a NA TO Contracting
Party, nor nationals
of:
nor ordinarily resident in the State in which the force is located. Such
persons include:
(1) Employees
of
other U.S. Government Departments;
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USSSOINST 2010.01
25
Jan 2024
(2) Essential personnel
of
the USO, credit unions, schools/universities (other than
Department
of
Defense Education Activity (DoDEA) schools) and the Red Cross.
(3) Technical representatives
of
organizations, companies, or private enterprises, having
special relations with U.S. Forces when such persons come to Italy for other than temporary
visits.
c.
Technical Representatives (TRs) are persons who have a high degree
of
skill, or
knowledge, in the systematic procedures
by
which a complex or scientific task is accomplished,
as distinguished from routine mental or physical processes. The skills and knowledge must have
been acquired through higher education or through a long period
of
specialized training and
experience. Specific minimum qualifications for education are as follows:
(])
Bachelor's degree in a related field;
or
(2) Associate degree in a related field and four years
of
recent specialized experience; or
(3) A major certification and six years
of
recent specialized experience; or
(4) A high school diploma and eight years
ofrecent
specialized experience; or
(5) For Aircraft Mechanics: An A&P (airframe and powerplant) license or FCC Radio
operator license and five years
of
specialized experience.
(6) A certification is a "major certification"
if
it is widely recognized, independently
administered, and difficult to obtain. Certifications listed on the DoD Contractor Personnel
Office (DOCPER) website as major certifications or listed by the Department
of
Labor as major
certifications, will be considered major certifications. Other certifications may be considered
major certifications
if
sufficient evidence is provided to make the determination that they are
widely recognized, independently administered, and difficult to obtain.
(7) Examples
of
positions that have been accredited as TRs include warranty repair
technicians for repair
of
complex equipment; key executive and supervisor positions in
government-owned, contractor-operated facilities that perfonn major maintenance on U.S.
government-owned vehicles; and computer software engineers.
(8) Examples
of
positions that have been denied
TR
status include administrative personnel;
automobile sales representatives; carpenters; masons; painters; plumbers; sales representatives
for china, jewelry, clothes, computers, encyclopedias, and similar items; secretaries and typists.
d.
Ordinarily Resident.
(I)
A person
is
ordinarily resident (OR)
if
he/she physically resides in Italy for more than
90 days without a mission sojourn permit (permesso soggiorno missione) for NA TO SOFA
status, or remains less than 90 days and takes any
of
the following actions:
3
USSSOINST 2010.01
25 Jan 2024
(2)
Registered
as
a resident at the Municipal Register (Ufficio Anagrqfe) in the town
where residing (N.B.: Because
of
the residency rules
of
the European Union, citizens or dual
citizens
of
any EU country are defined
as
ordinarily resident due
to
this requirement); or
(3)
Taken other affirmative steps
to
avail him/herself
of
permanent resident benefits,
including, but not limited to:
(a) voting, or registering
to
vote, in Italy;
(b) applying for unemployment benefits in Italy;
(c) obtaining, or having a legal obligation to obtain, documentation (such as a scheda
anagrafica or scheda professionale) aimed at attaining employment on the economy in Italy;
( d) obtaining, or having a legal obligation to obtain, registration with the Italian
national health care system;
(e) obtaining, or having a legal obligation to obtain, a work visa, or an employment
contract
of
sojourn, or an employment sojourn permit, or an autonomous work sojourn permit, or
a family sojourn permit, or another type
of
sojourn permit (vista di ingresso
per
lavoro, or
contratto di soggiorno per lavoro subordinato, or permesso di soggiorno
per
lavoro
subordinato, or permesso di soggiorno per lavoro autonomo, or permesso di soggiorno
per
motivifamiliari, or car/a di soggiorno), unless such permit was issued for employment with U.S.
Forces in Italy; or
(f) paying, or having a legal obligation to pay, Italian income taxes or property taxes
due
to
residency status.
e.
A temporary visit is a physical presence in Italy
of
less than 90 days.
f.
Contracting Officer's Representative (COR) serves as the liaison between the
contracting officer, the contractor, the command installation, or activity where the work is being
performed, and any other office or entity on matter pertaining
to
TRs performing work under the
terms
of
the contract.
g.
Proponent Office is the DoD agency, command, directorate, or office in Italy that is
utilizing, or requires the services of, the DoD contractor, or the office closely affiliated with U.S.
Forces that seeks to employ civilian personnel.
h.
Mission Visa is the required Italian visa for all Civilian Component and Civilian Personnel
assigned to U.S. military bases in Italy.
i.
Sojourn Permit is a required Italian government document that certifies that U.S. Forces
Civilian Component and Civilian Personnel are temporary legal residents
of
Italy. To obtain a
sojourn permit, an individual must first obtain the mission visa prior to arrival in Italy. The
4
USSSOINST 2010.01
25
Jan 2024
sojourn permit extends the Mission Visa from arrival until the individual's expected departure
from Italy.
j. Retiring or Separating Military Personnel may apply for accreditation as Civilian
Personnel but may not have dual status
as
both a member
of
the military and as Civilian
Personnel. Retiring or separating military members applying for Civilian Personnel status are
required
to
provide a copy
of
the DD-214 and are not eligible for employment as Civilian
Personnel with U.S. Forces in Italy until the day following the separation date on the DD 214.
Retiring or separating military members may
be
employed as members
of
the Civilian
Component as soon
as
the day their terminal leave starts,
if
they have an approved waiver from
the 180-day waiting period. Retiring or separating military members must obtain the appropriate
passport and a Mission Visa and Sojourn Pe1mit.
6.
Civilian Component and Civilian Personnel Status in Italy.
a.
Joint Civilian Personnel Committee - Italy. Implementation
of
the policies regarding
Civilian Component status contained within this directive are the responsibility
of
the Tri-
Service Joint Civilian Personnel Committee (JCPC) for Italy. All base/installation-level
procedures regarding application for employment must be consistent with this directive and
written guidance issued by the JCPC.
b.
U.S. citizens and third country nationals
of
a NATO country, other than Italy or any other
EU country, who are employed by U.S. commands and activities, and who otherwise meet the
definition
of
Civilian Component, become members
of
the Civilian Component unless they are
ordinarily resident in Italy.
c.
Italian citizens, and citizens
of
other EU countries, may not obtain Civilian Component or
Civilian Personnel status. Former Italian citizens present in Italy on orders, or orders
of
their
sponsor,
do
not regain Italian citizenship without an affirnmtive act. U.S. citizens who may have
acquired or reacqnired Italian citizenship under Italian law may
be
required to obtain and file
with civilian personnel offices, certificates from Italian authorities - ( e.g., Italian consulates
abroad, Ministry oflnterior, municipality
of
birthplace)-
stating that they are not Italian citizens,
are not listed in Italian records as Italian citizens, or have renounced Italian citizenship.
d.
Individuals who are ordinarily resident (OR) in Italy will not be accredited as Civilian
Component or Civilian Personnel. U.S. citizens ordinarily resident in Italy arc not eligible
to
be
hired in U.S. designated positions.
e.
Individuals applying for continuation or renewal
of
Civilian Personnel accreditation may
have their application revoked, or renewal denied,
if
they have taken action consistent with OR
status.
f.
Persons who depart Italy after becoming OR, with the intent to establish permanent
residence elsewhere, may be considered for Civilian Component or Civilian Personnel
accreditation only
if
the facts and circumstances clearly demonstrate that they departed Italy with
5
USSSOINST 2010.01
25 Jan 2024
the intent
to
establish permanent residence outside
of
Italy. Persons who have departed and spent
at least I year outside
ofitaly
will be presumed to not be OR in Italy, unless the facts and
circumstances demonstrate otherwise. USSSO retains ultimate discretion to determine whether
extraordinary circumstances exist that affect OR status in Italy.
g.
Members
of
the Civilian Component must have the following identifying documentation:
(I)
A
cunent
no-fee or official passport containing a U.S. Government endorsement that
the bearer is abroad on official U.S. Government business.
(2) An Italian Mission Visa in the official or no-fee passport. Italian regulations require
that the Visa must be applied for from the person's home
of
record in the United States, or
if
serving outside the United States, from the Italian Embassy or Consulate closest
to
their place
of
residence; and
(3)
A sojourn permit (permesso
di
soggiorno) endorsed for "Missione - componente
civile," or language
to
that effect
1
. The permesso
di
soggiorno must
be
requested within eight
days
of
arrival
of
the Civilian Component member in Italy, through the appropriate office on the
military installation.
h.
Dependents
of
active-duty military members, Civilian Component personnel, and
Civilian Employees are authorized to be employed on U.S. Forces installations without
modification
of
their passports, visas, and sojourn permits that may otherwise reflect a family
member status. Such employment must terminate upon the sponsor's departure from Italy unless
the dependent self-sponsors.
i.
Persons who acquire Civilian Component status may become "ordinarily resident" and
lose civilian component status
if
at any time they take action contrary to
NA
TO SOFA status.
Loss
of
Civilian Component status may result in termination
of
employment or failure
to
maintain eligibility requirements.
j. DoD ID cards will
be
issued
to
all members
of
the Civilian Component, qualifying
Civilian Personnel, and their eligible dependents.
k.
Base/installation Civilian Personnel offices will determine Civilian Component status,
after consultation with their servicing legal office. The affected individual/employee may
request review
of
a negative determination. A request for review must be submitted within ten
working days to the cognizant Component Commander at the address indicated below via the
civilian personnel office that rendered the initial determination. The Component Commander's
decision is final. For record purposes and to ensure consistency across the services, decisions
1
Civilian Component members continuously employed prior to the implementation
of
the Italian visa requirement
in 1999/2000. Such persons must possess a no fee/official U.S. passport described above; however, civilian
component
sojourn
permits
issued
prior
to
the
visa
requirement
reflect
an
endorsement
of"lavoro subordinato
componente civile personale NATO.'
1
Upon
renewal,
these
older
sojourn
permits
must
reflect
the
mission
language
described above.
6
USSSOINST 2010.01
25 Jan 2024
will
be
reported to the U.S. Sending State Office for Italy and
to
the Chair, Joint Civilian
Personnel Committee - Italy.
(!)
Army: Headquarters, U.S. Army Europe and Africa, Unit 29351, Box 100, APO
AE
09014-9351 (military); Clay Kaseme, 65205 Wiesbaden, Germany (civilian).
(2) Navy: COMUSNAVEUR PSC 809, Box 70, FPO AE 09622-0070 (military); 81030
Gricignano
di
Aversa, Province
of
Caserta, Italy 81030 ( civilian).
(3)
Air Force: HQ USAFE/DPC, Unit 3050 Box 25, APO AE 09094-5025 (militaiy); HQ
USAFE/DPC, Bldg.
525
66877, Ramstein Air Base, Germany (civilian).
7.
Solicitations and Contracts for Technical Representatives.
a.
Consistent with individual component contracting procedures, solicitations shall:
(1) Identify contract work that the U.S. Government intends to be performed by
Technical Representatives (TRs), identify the positions that would conduct that TR work, and
specify that any contractor employees sent by the contractor
to
Italy for other than a temporaiy
visit who have not received
TR
accreditation and a mission visa, will not be accredited as a TR.
(2) Identify applicable regulations and policies concerning Individual Logistic Support
(!LS) and state what !LS privileges,
if
any, will be provided
to
accredited TRs.
If
the availability
ofILS
is unknown, the solicitation shall
so
state.
b. Contracts
to
be used in Italy shall, to the extent possible:
(I) Identify positions for which TR accreditation will be requested.
(2)
Define whether ILS will be provided to contractor employees who are accredited as
TRs.
(3)
Identify any applicable service component regulations and policies limiting !LS.
(
4)
State that
no
equitable adjustment will be made for unavailability
of
ILS to any non-
TR positions or personnel.
(5)
Contain a clause requiring the DoD contractor to ensure that positions intended
to
be
filled
by
TRs need to be identified as soon as possible following award, and prior to the
contract's first use in Italy, in accordance with this guidance. The contract also shall specify that
any employee sent by the contractor to Italy, for other than a temporary visit, who has not
received TR accreditation and a mission visa, will not be accredited as a TR.
c.
A service component or individual base commander may notify USSSO or the DoD
Contractor Personnel Office (DOCPER) at any time regarding the extent
of!LS
to be granted to
TRs under any specific contract or located on specific installations.
7
8.
Accreditation Process for Technical Representatives.
USSSOINST 2010.01
25 Jan 2024
a.
General:
TR
accreditation is a two part-process, involving the Contracting Officer's
Representative (COR), DOCPER, USSSO and the vendor/contractor. The first part
of
the
process is contract approval; the second part is accreditation
of
individual applicants for
TR
status.
b. There are two categories
of
DoD contractor employees in Italy:
(!)
Those who are accredited
as
TRs require a mission visa and sojourn permit (permesso
di soggiorno ). They are considered Civilian Personnel and are exempt from Italian income
taxation, labor legislation and social contributions. Eligibility for accreditation for TRs generally
is addressed above in paragraphs S(b) and
6.
TRs are eligible for !LS, as described in 6.b. above.
(2) Those who are employed under locally prevailing conditions
of
employment, and are
not considered TRs, require Italian working visas. In addition, they are subject to Italian income
taxation, labor legislation, and social contributions; and they are not eligible for individual and
family !LS.
c.
Dependents may apply for positions as Civilian Personnel ( either as Essential Personnel
or TRs). Their status
as
Civilian Personnel expires upon their sponsor's end
of
tour in Italy, the
sponsor's retirement, or for any other reason whereby the sponsor no longer retains his/her status
as a member
of
the military, Civilian Component or Civilian Personnel. However, dependents
may transition from being a sponsored dependent to self-sponsorship
as
Civilian Personnel. This
transition would require the dependent to obtain the appropriate passport and mission visa
if
not
already in their possession.
d.
Accreditations for TRs are required for contractor employees on any new contract that
proposes the use
of
TRs in Italy. Accreditations for
TR
are also required for the addition
of
new
TRs on existing contracts. Each contract requires that a COR act as the link between DOCPER
and the vendor or applicant. To begin the process, the COR must provide DOCPER the COR
designation memorandum for the contract at issue. Upon receipt
of
the COR-Designation
memorandum, and a favorable review
of
the Contracting Action Submission Form, contract, and
Performance Work Statement (PWS) or Statement
of
Work (SOW), the new record will be
opened in the European Contractor Online Processing System (ECOPS), DOCPER's online
processing system. The COR will be given access to DOCPER's online processing system.
Contracts will be approved
if
the contract's Statement
of
Work (SOW), i.e., purpose
of
the
contract, and the positions to
be
used in contract performance meet the requirements for TR
accreditation. All contracts listed below are to be submitted through DOCPER's online
processing system.
(1) New Contracts: A new contract is any contract, newly awarded
or
existing, that has
not yet been used in Italy. Follow-on or successor contracts, even
if
awarded to the same
company with the same SOW (SOW) and
job
descriptions (IDs), are new contracts.
8
USSSOINST 2010.01
25
Jan 2024
(2)
Existing Contracts: Contracts for which TRs currently are approved. TRs may be
added when a
TR
contractor employee terminates, or in the case
of
changed contractual
requirements (described below). In general, only the Application for Accreditation as a Technical
Representative in Italy is required.
(a)
Extensions: Contract documents that extend the length
of
a conh·act must be
submitted before the expiration
of
the existing period
of
performance to renew TR status for the
accredited contractor employee.
(b)
Modifications: Contract documents that materially amend the terms
of
a contract
must
be
submitted. These modifications usually consist
of
one or more
of
the following:
1.
Change in SOW; and
2.
Change in type or number
of
TR
positions; and
3.
Change
of
performance location; and
4. Extensions
of
the Period
of
Performance beyond the contract final end date
5.
Change/Removal/ and/or addition
of
new
CO
Rs
e.
Contracts that propose performance
by
a TR require two determinations before contractor
employees can be accredited
TR
status in Italy:
(1) Whether the positions
to
be utilized in contract performance meet the definition
of
TR
positions, and,
(2) Whether the persons proposed
to
fill the positions can be accredited as TRs, including
determination
of
whether such persons are ordinarily resident in Italy.
f.
For each contract that proposes
to
use TRs in Italy, the Contracting Officer or the COR
shall submit to DOCPER a completed Contracting Action Submission Form, COR designation
letter, PWS, and awarded signed contract. The Contracting Action Submission Form, in addition
to other references, are provided through DOCPER' s website at
https://www.europeafrica.army.mil/contractor/. Among other items, the Contracting Action
Submission Fotm requires the following information:
(I)
Contract Number;
(2) Name
of
contractor;
(3) Date
of
contract award;
(
4)
Contract expiration date;
9
(5) Expiration date
of
current period
of
performance;
(6) Proponent office in Italy (name, address, POC, etc.);
(7) COR (name, address, etc.);
USSSOINST 2010.01
25 Jan 2024
(8)
Summary
of
work to
be
performed
by
the contractor, and job descriptions for
positions requiring the use
of
TRs;
(9) The provisions in the contract that provide for ILS; and
(10) Total number
of
employees in each
job
description
to
be employed.
g.
For each employee proposed
as
a TR, the Contracting Officer, or the COR, shall provide
to DOCPER a completed Application for Accreditation, through DOCPER's online processing
system,
as
a Technical Representative in Italy, and include the following information:
(!)
Identification
of
employee by full name, date
of
birth, place
of
birth, and social
security number, identification
of
spouse and nationality, and date
of
birth and relationship
of
all
dependents.
(2) Information for each contractor employee necessary
to
verify nationality and
ordinarily resident status. In particular, the contractor employee should provide legible
photocopies
of
the inside cover
of
the tourist passport and front page with the photograph, and
any pages containing Italian Visa Stamp(s), including the mission visa. Additionally, the
contractor will provide legible copies
of
any previous sojourn, or applications for a sojourn,
if
applicable;
(3) Information identifying the contract, the position under the contract for which the TR
accreditation is sought, and the anticipated location and start date
of
employment;
(4) Resume
of
contractor employee. (The resume should show dates and locations for
each position held for the previous
10
years);
(
5)
Signature
of
contractor employee attesting to the truth
of
the information provided,
and acknowledging that abuse
of
NA
TO
SOFA privileges may result in loss
of
TR accreditation
and its' attendant privileges, and that the U.S. Government retains the right
to
withdraw
privileges as a result
of
contractor employee abuse at no additional cost to the U.S. Government.
h.
DOCPER will process the Contract Registration and Application for Accreditation as a
Technical Representative in Italy and provide its recommendations
to
USSSO within 5 working
days
of
receipt
of
all required information. USSSO will typically provide an accreditation
decision within
IO
working days ofreceipt
ofDOCPER's
recommendation.
10
9.
Approvals and Denials for Technical Representatives.
USSSOINST 2010.01
25
Jan 2024
a.
Initial accreditations: USSSO will evaluate each request for accreditation, and as
appropriate, issue an individual letter
of
accreditation for each contractor employee to be
accredited
as
a
TR
under the Shell Agreement, or issue a letter
of
denial for each contractor
employee ineligible for TR accreditation. USSSO and DOCPER will maintain copies
of
submissions and letters
of
accreditation and letters
of
denial issued.
(1) Individual letters
of
accreditation and corresponding DD 1172-2 forms will be issued
for the length
of
the current period
of
performance for each contractor employee determined
eligible for TR accreditation.
(2) ILS: ILS will be authorized for TRs
if
the contract provides for ILS.
If
the contract
does not provide for !LS, or service component regulations and policies preclude granting
of
ILS, the accreditation documents will provide for
TR
accreditation without ILS.
(3) USSSO shall issue individual letters
of
denial for those deemed not to qualify for
accreditation as TRs. Denial letters will indicate whether the denial is based on the position (as
defined by the SOW and JD), the individual's qualifications, or that the individual is ordinarily
resident in Italy.
(4) USSSO shall transmit accreditation and denial letters through DOCPER to the
Contracting Officer or COR, who shall transmit the determinations to the DoD contractor.
b.
Renewal accreditations: DOCPER will evaluate renewal requests for accreditation and
verify the contract period
of
performance for each contractor employee for whom renewal
of
TR
accreditation is requested.
(1) DOCPER will issue individual letters
ofrenewal
of
accreditation,
if
appropriate.
Individual letters
of
renewal
of
accreditation and corresponding DD 1172-2 forms will be issued
for the length
of
the current period
of
performance for each contractor employee determined
eligible for renewal
of
TR
accreditation.
(2) USS SO shall issue individual letters
of
denial for those deemed not to qualify for
renewal accreditation
as
TRs.
(3) Accreditation and denial letters shall be transmitted by DOCPER to the Contracting
Officer or COR, who shall transmit the determinations to the DoD contractor.
c.
Upon receipt
of
the letter
of
accreditation or denial, the Contracting Officer or COR will
notify the contractor regarding the disposition
of
TR status for each contractor employee for
whom TR accreditation has been requested.
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USSSOINST 20 I
0.01
25 Jan 2024
10. Accreditation Procedures for Civilian Personnel other than Technical Representatives.
a.
Individuals accredited as Civilian Personnel require mission visas and sojourn permits.
They are exempt from Italian income taxation, labor legislation and social contributions.
Eligibility for accreditation for Civilian Personnel generally is addressed above in paragraphs
5(b) and
6.
b.
To
obtain accreditation, the proponent office shall submit to DOCPER the Application
for Accreditation as a Member
of
the Civilian Personnel in Italy for each individual for whom
the proponent office seeks such status.
c.
List
of
Essential Personnel: Proponent offices for the USO, credit unions,
schools/universities (other than DoDEA schools) and the Red Cross will propose to USSSO
Rome through DOCPER a listing
of
job descriptions and salary scales
of
positions deemed by
the proponent agency to qualify as "essential personnel." The proponent office will describe why
each position is essential, and the number and locations
of
the personnel to be assigned to such
positions in Italy. The USSSO will determine which positions are essential in light ofreferences
(a) and (b) and respond with a final approved list
of
essential personnel to the proponent office.
Employees in positions that are not approved
as
"essential personnel" cannot be accredited as
Civilian Personnel, or continue their current status,
if
currently holding accreditation
as
Civilian
Personnel.
d.
Information Required for Accreditation: The Proponent Office may designate a
representative (Proponent Office Designee or POD) to work with DOCPER in the process
of
approving applicants for essential personnel positions. Upon nomination
of
the POD, DOCPER
will provide the POD access to DOCPER's online processing system. The proponent office will
submit a completed Application for Accreditation
as
a Member
of
the Civilian Personnel in Italy
for each individual proposed for Civilian Personnel status, and include the following
information:
(I)
Identification
of
employee by full name, date
of
birth, place
of
birth, and social
security number; identification
of
spouse and nationality, and date
of
birth and relationship
of
all
dependents;
(2) Information for each employee necessary to verify nationality and ordinarily resident
status. In particular, the employee should provide photocopies
of
the inside cover
of
the tourist
passport and front page with the photograph, and any pages containing Italian Visa Stamp(s).
Provide copies
of
any previous sojourn or applications for a sojourn,
if
applicable;
(3) Information identifying the organization, and the position in the organization that the
individual will be assigned to. For the USO, credit unions, schools and the
Red
Cross, the
position must be on the USSSO-approved listing of"essential personnel";
(
4)
Resume
of
the employee. (The resume should show dates and locations for each
position held for previous
IO
years);
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USSSOINST 2010.01
25 Jan 2024
(5) Signature
of
the employee attesting
to
the truth
of
the information provided and
acknowledging that abuse
of
NATO SOFA privileges may result in loss
of
status and its
attendant privileges, and that the U.S. Government retains the right to withdraw privileges as a
result
of
employee abuse at no additional cost to the U.S. Government.
e.
DOCPER will process applications and provide its' recommendations to USSSO within 5
working days
of
receipt
of
all required information.
11.
Approvals and Denials for Civilian Personnel other than Technical Representatives.
a.
Initial Accreditations: USSSO will evaluate each request for accreditation, and as
appropriate, issue an individual letter
of
accreditation for each individual
to
be
accredited as a
member
of
the Civilian Personnel under the Shell Agreement, or issue a letter
of
denial for each
employee ineligible for accreditation. Each newly-approved applicant receives the following
three items
of
documentation, all
of
which can be downloaded from DOCPER' s online
processing system:
(I) Memorandum to the Italian Consulate (signed by the Officer-in-Charge or delegate
of
the USSSO), which authorizes the Italian consulate nearest
to
the applicant's home
of
record to
place the "mission" visa in the applicant's passport [NOTE: Not necessary nor authorized for
dependents
of
military or civilian personnel already in Italy];
(2) Individual letters
of
accreditation signed by DOCPER for presentation
to
the
Sojourn Liaison office on base [NOTE: Not necessary, nor authorized, for dependents
of
military
or civilian personnel already in Italy];
(3) DOCPER authorized DD 1172-2 form
to
present to the
US
Government
ID
card
processing facility to receive the correct identification card, which may be issued for up
to
three
years or date
of
passport expiration, whichever is less. [NOTE: Dependents
of
military or civilian
personnel are authorized a computer-use-only CAC].
(a) MP-ICAM Requirement. In order for an ID card facility to issue a CAC to the
applicant, the Mission Partner Affiliation Sponsor (MPAS) must have approved the applicant in
MP-ICAM using the same "Eligibility Expiration Date" as the CAC expiration date that
DOCPER provided in the DD 1172-2 (Block #33).
If
the same date is not used, the ID card
facility will not issue the CAC.
b. USSSO and DOCPER will maintain copies
of
submissions and letters
of
accreditation
and letters
of
denial issued.
c.
Individual letters
of
accreditation and corresponding DD 1172-2 forms will be issued for
up to three years.
d.
USS
SO
shall issue individual letters
of
denial for those deemed not
to
qualify for status.
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USSSOINST 2010.01
25
Jan 2024
e.
USSSO shall transmit accreditation and denial letters
to
the proponent office, who shall
transmit such determinations to the applicant.
f.
Renewal accreditations: DOCPER will evaluate renewal requests for accreditation.
DOCPER will issue individual letters
of
renewal
of
accreditation,
if
appropriate. Approved
renewal accreditations will receive the same three documents as the approved initial
accreditations. Individual letters
of
renewal
of
accreditation and corresponding
DD
1172-2 forms
will
be
issued for up to three years for each employee determined eligible for renewal
of
accreditation.
g.
USS SO shall issue individual letters
of
denial for those deemed not
to
qualify for renewal
accreditation.
h.
Accreditation and denial letters shall be transmitted to the proponent agency, who shall
transmit the determinations to the applicant.
i.
Reconsideration Process:
If
the proponent office disagrees with the determination
of
USSSO to deny accreditation, the proponent office may request that the USSSO reconsider its
decision.
(I) In coordination with the Servicing SJA, the proponent office will prepare an appeal
letter setting forth the basis for its disagreement with the decision. The letter must be signed by
an
0-6
or above, or civilian equivalent and provided to USSSO within 30 days
of
the date
of
the
decision under appeal.
(2) USS SO may consult with the servicing SJA or the proponent office prior to reaching
its decision.
(3) The reconsideration decision ofUSSSO is final.
12.
Civilian Personnel Compliance with Italian Requirements.
a.
All Civilian Personnel for whom accreditation is granted will apply for and obtain a
mission visa prior
to
arrival in Italy. This visa can
be
obtained from the Italian Consulate
authorized
to
issue the mission visa for the jurisdiction in which the individual resides. Any
employee arriving in Italy without the mission visa does not have Civilian Personnel status and
may not commence work without a proper work visa.
(1) By direction
of
the Italian Ministry
of
Foreign Affairs, no Italian Consulate may issue
the mission visa to a Civilian Personnel employee without presentation
to
Consulate authorities
of
a letter
of
accreditation issued by USS SO. A Civilian Personnel employee who improperly
obtains the mission visa will
be
denied accreditation.
(2) Within eight (8) days
of
arrival in Italy, Civilian Personnel employees will report to
the servicing Staff Judge Advocate (SJA) and present (i) a copy
of
the letter
of
accreditation;
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USSSOINST 2010.01
25 Jan 2024
and, (ii) the original passport containing the mission visa issued by an Italian consulate.
If
in
order, the individual must then apply through the appropriate installation office for a sojourn
from the local Questura.
(3) Note that neither a work visa nor a mission visa is required for personnel who are in a
temporary visit status (less than 90 days in the European Union).
b.
ID
Cards:
(1) The employee shall take the sojourn permit ( or a copy
of
the application letter for the
sojourn permit), passport, letter
of
accreditation as a member
of
the Civilian Personnel, and
accompanying form
DD
1172-2
to
the ID card facility to receive the United States
DoD/Uniformed Services Identification and Privilege Card [ also known
as
the Common Access
Card (CAC)].
(2) All ID card facilities for all components shall be instructed
to
issue no ID cards
granting status unless the Civilian Personnel employee presents both a valid accreditation letter
and an accompanying DD 1172-2 signed
by
DOCPER. For TRs, the
DD
1172-2 will be issued
only
for
the length
of
the current period
of
performance in the contract and must be the same as
the period
of
performance specified in the Letter
of
Accreditation. For other Civilian Personnel,
the DD 1172-2 will
be
issued for
up
to three years.
c.
Initial accreditation letters: Valid only
if
signed by USSSO.
d.
Renewal accreditation letters: Valid only
if
signed by USS
SO
or DOCPER.
e.
Termination
of
Civilian Personnel Status:
(1) For TRs, the COR and the contractor program manager will ensure that contractor
employees follow installation procedures for returning identification cards, sojourn, access
passes, or other documents granting privileges upon termination or transfer out
of
Italy
of
any
contractor employee who is accredited
as
a TR. In cases where a TR loses his or her
TR
accreditation, the COR will notify the contractor that the contractor employee is no longer
accredited
as
a TR. As the mission visa only is intended for those contractor employees with
TR
accreditation, the contractor employee is responsible for obtaining documents that allow that
employee
to
remain lawfully in Italy.
(2) For other Civilian Personnel, the proponent office or the sponsoring agency will
ensure that Civilian Personnel under their sponsorship follow installation procedures for
returning identification cards, sojourns, access passes, or other documents granting privileges
upon termination or transfer out ofitaly. An individual losing his or her accreditation is
responsible for obtaining any documents needed to remain lawfully in Italy.
15
13.
Comprehensive Review
of
Civilian Personnel.
USSSOINST 2010.01
25 Jan 2024
a.
DOCPER may conduct a Comprehensive Review (CR)
of
current Civilian Personnel
to re-assess the status
of
all individuals currently accredited as Civilian Personnel as
necessary.
b.
Prior to conducting a CR, DOCPER will issue specific guidance regarding the
informati
on
required, responsible parties, and deadline
s.
Failure to submit required
information during a
CR
will result in termination of Civilian Personnel accreditation.
S. J.
GA
WRONSKI
16
