Policy Action Brief
Common Access Card (CAC) for TWIC
Eliminating Redundant Credentialing for Military to Mariner
Program Overview
For service members who qualify for the USCG credentialing fee waiver under the Military to Mariner program only: their Common Access Card (CAC) is accepted in lieu of a TWIC for MMC application purposes. TWIC remains the baseline requirement for all commercial mariners. This provision does not affect any mariner who does not hold a CAC. Fee-waiver-eligible applicants have already completed federal security vetting that meets or exceeds TWIC requirements. Requiring them to obtain a redundant $124 credential that serves no additional security purpose is wasteful government spending.
The Problem
- Redundant Cost: Fee-waiver-eligible service members must still pay $124 for a TWIC despite holding a CAC that reflects a higher-level security clearance.
- Wasteful Duplication: The government pays to re-screen personnel it has already cleared to a higher standard.
- Unnecessary Barrier: A redundant credential requirement discourages qualified military personnel from pursuing merchant mariner credentials.
The Solution
- Accept CAC in Lieu of TWIC: Amend 46 CFR 10.203 to accept a valid CAC as satisfying the TWIC requirement for fee-waiver-eligible applicants under Military to Mariner.
- DMDC Photo Agreement: Establish a data-sharing agreement with the Defense Manpower Data Center to obtain the CAC photograph for use on the physical MMC.
- TWIC Baseline Preserved: TWIC remains the requirement for all commercial mariners. This change applies only to CAC holders eligible for the Military to Mariner fee waiver.
Strategic Benefits
Redundant
Fee Eliminated
Existing
Clearance
New
Technology
TWIC Baseline
Preserved
Seamless Credentialing
Eliminates key barriers for active duty personnel earning merchant mariner credentials.
Cost Savings
Eliminates the redundant $124 TWIC fee for Military to Mariner fee-waiver-eligible applicants.
Efficient Resource Use
Leverages existing rigorous background investigations to avoid redundant government screenings.
Workforce Development
Builds a stronger pipeline of qualified personnel transitioning from military to civilian service.
Why Now
The Coast Guard controls what it accepts for MMC applications under 46 CFR 10.203. CAC holders already use their cards for access to MARSEC facilities. Accepting the CAC for fee-waiver-eligible applicants eliminates a redundant federal credential.