How a case gets countersigned

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1. Three approvals, in order

A finished foreign military sales agreement is not signed once. "All LOA documents require coordination and DSCA countersignature" (SAMM C5.6.11), and the sequence runs through three separate approvals held in two different systems.

The drafting agency approves first, its review recorded as a milestone rather than a signature. "The MILSGN milestone is a mandatory precursor to coordinating LOAs with State or offered/implemented as required" (SAMM C5.6.11). The date then travels: "The IAs review and approval date (MILSGN) auto-populates in CTS and annotates the first page of the LOA document" (SAMM C5.6.11).

The state department comes second, reached through a list transmitted daily rather than a document sent for signature. Only then does the third approval land. "Upon e-mail approval from State, DSCA (IOPS/GEX/CWD) countersigns the LOA document in DSAMS via the DCSGN milestone, culminating in an LOA approved to be offered (or Implemented status for modifications)" (SAMM C5.6.11). What the agreement itself contains is set out in inside the Letter of Offer and Acceptance.

2. The package, and a 24 hour rule

A single milestone starts the machinery. Posting it moves the document out of development into write status "and creates a case record on their respective CTS dashboard" (SAMM C5.6.11.1) for the supporting files.

Those files have a deadline attached. "Concurrent with movement of the document to Write status via MILAP, the IA must upload ONLY UNCLASSIFIED off-line documentation into the CTS application no later than 24 hours after the MILAP submission" (SAMM C5.6.11.4). The list of what must go in is long. It covers the request itself, the cover memorandum and the manpower sheet. It also covers missile technology and excess article approvals, nonrecurring cost waivers, approvals for night vision and communications security, and any grant agreements (SAMM C5.6.11.3.5).

Nothing starts without both halves. "The DSCA (IOPS/GEX/CWD) cannot initiate action to prepare the case until both the MILAP milestone and the UNCLASSIFIED off-line documentation is uploaded into the CTS application" (SAMM C5.6.11.5). Miss the 24 hours and the document goes back to development status, with a consequence worth reading twice: "Returning documents back to Development status in DSAMS, will DELETE the previously uploaded off-line package in the CTS application" (SAMM C5.6.11.5).

3. Foreign markings on an incoming request

Classified material never enters the tracking system. Only the unclassified portion is uploaded, with the classified part sent separately by secure e-mail (SAMM C5.6.11.4.1).

A quieter problem is the partner’s own marking. A request arriving with foreign government markings has to be re-marked so that everyone handling it afterwards knows how to protect it. The method is physical. "A single line through the host marking (to ensure it is still readable) and then re-marking with U.S.-equivalent marking is required" (SAMM C5.6.11.4.1.1.1), with a block at the foot of each page naming who re-marked it, under what authority, and when.

Getting it wrong stops the case. "If the document is not clearly remarked with U.S. Government equivalent markings, the document will be returned to the IA" (SAMM C5.6.11.4.1.1.1.1). The wider rules on handling another government’s classified material are covered in disclosure of classified military information.

4. Write, review, proposed

In write status the reviewing division assembles the document and checks it. "DSCA (IOPS/GEX/CWD) will conduct a final quality assurance review on the submitted LOA document before moving the package to Review status in DSAMS" (SAMM C5.6.11.6).

Review status is where the headquarters offices and the agency coordinators read the final version. The document moves on only when both sides are content: "Once the required DSCA HQ offices approve within the CTS application, and the IA approves via the MILSGN milestone in DSAMS, the document is moved to Proposed status in DSAMS" (SAMM C5.6.11.7).

Comments are recorded twice over, in the tracking system and in the case remarks, with a naming convention so a remark can be tied to the right version of the document. "Records in the CTS application are automatically date/time/username identified and saved when entered" (SAMM C5.6.11.7.1).

A return unwinds several stages at once. "A WDOCRTN milestone moves a case back to Writing Status for corrections, at which point DSCA (IOPS/GEX/CWD) returns it to Case Development status for the IA to make the corrections" (SAMM C5.6.11.7.3). The earlier upload then archives rather than vanishing, and "All iterations of a case record can be searched via a browse option in the CTS application" (SAMM C5.6.11.6.1).

A return can be contested. "The IA may request adjudication of any Write or Review status return it believes was returned in error through IA Policy POCs" (SAMM C5.6.11.6.1.1), and an approved challenge changes the return codes in the record.

5. What the state department is shown

The threshold for state department approval is narrower than it first appears. "State approval is required for LOA and subsequent Amendments that add or increase scope" (SAMM C5.6.11.8.1). An amendment that moves money between lines or shifts a delivery date is a different animal.

What arrives is a list rather than a file. "DSCA (IOPS/GEX/CWD) submits the State List Report daily, which provides State with descriptions of defense articles and services being transferred on LOA documents" (SAMM C5.6.11.8.1). The text in it is written by the drafting agency, and the manual sets out what it must say. A new case needs quantities and major items. An amendment to a major equipment case needs the added end items, and a follow on support document needs the platforms being supported. Sensitive munitions such as white phosphorus or depleted uranium must be called out in the same field (SAMM Table C5.T16).

6. Jumping the queue, and cancelling

Priority handling exists and is rationed. A request goes through the country portfolio director "within 48 hours after the LOA is determined by the IA to be an emergency/priority" (SAMM C5.6.11.2), stating the desired offer date, how long the document has been in development, and any known reasons for delay. Approval is held at director level: "Each request will be approved by the Principal Director or Principal Deputy Director for the DSCA (IOPS) on a case-by-case basis" (SAMM C5.6.11.2).

A tight offer window is not a reason. "Short OEDs should not be used as justification to prioritize the processing of an LOA document" (SAMM C5.6.11.2.1).

Cancellation after offer is close to final. "Once an offered LOA has been cancelled, it will remain cancelled in most instances" (SAMM C5.6.11.9.2), and the reason is technical as much as procedural: "Reactivating cancelled cases eliminates the data history" (SAMM C5.6.11.9.2). It is also not a parking space. "Cancellation cannot be used to place a document on hold" (SAMM C5.6.11.9.2). An exception runs through a data fix request coordinated across three offices.

7. What a supplier can take from this

The countersignature stage is where a case can lose weeks for reasons unconnected to the equipment. A missing waiver, a request still carrying another government’s classification marks, or a supporting file uploaded a day late will each send the document backwards.

The scope test is the point to watch commercially. An amendment that adds items needs approval outside the defense department, while one that realigns funds or moves a delivery date does not, and the two travel at different speeds. Anyone quoting against a signature date should know which kind of change is being asked for.

Key terms

MILSGN	The milestone recording the drafting agency approval, a precursor to state coordination.
DCSGN	The milestone by which the reviewing division countersigns, after state department approval.
Case Tracking System	The application holding the electronic package during coordination, where headquarters offices record approval.
Off-line documentation	The unclassified supporting files, due within 24 hours of the approval milestone.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

The signature date is the point a delivery plan can be built against, and it moves for paperwork reasons. Sentfore provides secure movement, protective security, facilities and life support for defense programs once equipment and people are in country. Requirements can be sent through the contact page.