RESOURCES
NEW 48 CFR Proposed Ruling Published by DoD
The Federal Register has published a proposed 48 CFR ruling "Assessing Contractor Implementation of Cybersecurity Requirements (DFARS Case 2019-D041)" This proposed ruling would amend the DFARS to incorporate contractual requirements related to the CMMC program. Public comments will be accepted for 60 days after the date of publication in the Federal Register. Link | Download
NEW eResilience article on cyber assurance for prime contractor bidding teams
A new Contract Management magazine article from eResilience discusses supply chain cyber compliance risk and explores issues and strategies that prime contractors should be aware of when sharing CUI with suppliers and subcontractors. This article appeared in the August 2024 issue of Contract Management magazine, published by the National Contract Management Association. Used with permission. Link | Download
NEW Department of Defense (DoD) Defense Industrial Base (DIB) Cybersecurity (CS) Activities
The DoD released a final rule that revises eligibility criteria for the voluntary DIB Cybersecurity Program, allowing all contractors who handle CDI (DoD CUI) to benefit from bilateral information sharing, which was previously available only to cleared contractors. This ruling also replaces the need for a Medium Assurance Certificate to access the DIBNet portal for cyber incident reporting by allowing registration for DIBNet access through the Procurement Integrated Enterprise Environment (PIEE). Link | Download
NEW eResilience article on supply chain cyber compliance risk published in September issue of NCMA Contract Management Magazine
The September 2023 issue of Contract Management magazine features an article from eResilience focused on supply chain cyber risk management. Download (NCMA members can view the article online by logging in to see the complete September issue at "https://ncmahq.org/Web/Web/Insights/Contract-management-Magazine.aspx") This article appeared in the September 2023 issue of Contract Management magazine, published by the National Contract Management Association. Used with permission.
Contractual Remedies to Ensure Contractor Compliance with Defense Federal Acquisition Regulation Supplement Clause 252.204-7012
The DoD has circulated this Memo to contracting officers to remind them of contractor cyber compliance requirements and emphasize penalties that can be levied against non-compliant contractors. Link|Download
CMMC 2.0: Level 1 Self-Assessment Guide
The DoD has released the new Assessment Guide for CMMC 2.0 Level 1. This document provides guidance for companies to correctly perform their Level 1 self-assessments, which must be conducted annually, reported to SPRS, and affirmed by a senior company official when contracts require CMMC 2.0 Level 1. Link | Download
Department of Justice Announcement of new initiative to enforce DoD Cybersecurity Regulations
The DoJ has announced a new civil cyber-fraud initiative that will use the False Claims Act to enforce DoD cybersecurity regulations. Link
Defense Federal Acquisition Regulation Supplement: Assessing Contractor Implementation of Cybersecurity Requirements (DFARS Case 2019-D041)
The DoD has issued an interim rule to amend the DFARS cybersecurity regulations to implement a DoD Assessment Methodology and Cybersecurity Maturity Model (CMMC) framework in order to assess contractor implementation of cybersecurity requirements and enhance the protection of unclassified information within the DoD supply chain. (Comments on the interim rule should be submitted in writing on or before 60 days after date of publication in the Federal Register.) Link | Download
Update: NIST SP 800-171 DoD Assessment Methodology Version 1.2.1
The DoD has released an update of its NIST SP 800-171 Assessment Methdology, introducing the ability for the DIBCAC to perform remote "virtual" assessments at the Medium and High Confidence level due to the COVID-19 pandemic. Basic assessments will still be self-reported by contractors, and the subtractive, weighted scoring system is still in place. Link | Download
National Archives Controlled Unclassified Information (CUI) Registry – CUI Categories List
The CUI registry helps you understand what type of information is considered sensitive. There are many types and categories of CUI, and the registry provides descriptions as well as information and resources about marking and dissemination controls. Link
Memorandum: NIST SP 800-171 DoD Assessment Methodology v1.0 (November 14, 2019)
This Memo and associated document describes the new DoD Assessment Methodology that includes both a scoring system to establish an overall score based on the number of requirements that have been successfully implemented, as well as a confidence rating of Basic, Medium, or High depending on the type of assessment / attestation conducted in determining the score. Link | Download
Memorandum: Change 18-08 of the Navy Marine Corps Acquisition Regulation Supplement (NMCARS) (September 6, 2019)
This memo from the Deputy Assistant Secretary of the Navy (Acquisition and Procurement) announces immediate changes to the NMCARS, requiring the inclusion of Annex 16 in the statements of work of solicitations, contracts, and task or delivery orders when the DON Program Manager, Program Executive Officer, or Chief of Naval Research, in coordination with the Resource Sponsor, determines that the risk to a critical program and/or technology warrants its inclusion. Link | Download
Audit of Protection of DoD Controlled Unclassified Information on Contractor-Owned Networks and Systems DoDIG-2019-105 (July 23, 2019)
The Department of Defense Office of Inspector General (DoD OIG) released an audit report regarding the protection of Controlled Unclassified Information (CUI) on contractor networks. The audit found that DoD contractors did not consistently implement DoD-mandated system security controls for safeguarding Defense information. Link | Download
- Brief Results: Link
DCMA Contractor Purchasing System Review (CPSR) Guidebook (June 14, 2019)
This is the most recent update of the DCMA Guidebook for auditors conducting Contractor Purchasing System Review (CPSR). APPENDIX 24, starting on Page 97, includes instructions to evaluators on how to assess contractor compliance with DFARS / NIST Cybersecurity regulations and requires contractors to demonstrate how they are tracking and assessing the compliance of their suppliers. Link | Download
Cybersecurity Maturity Model Certification (CCMC) Website (June 2019)
The Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD(A&S)) launched a website that hosts additional background on the proposed CMMC, including a list of FAQs. Link
Memorandum from The Under Secretary of Defense: Addressing Cybersecurity Oversight as Part of a Contractor’s Purchasing System Review (January 21, 2019)
This memo instructs the Defense Contract Management Agency (DCMA) to begin validating contractor compliance with the requirements of DFARS clause 252.204-7012 and review contractor procedures to assess compliance of their Tier 1 Level Suppliers with DFARS 252.204-7012 and NIST 800-171. Link | Download
DFARS 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting (October 2016)
This cybersecurity safeguarding clause is now in all DoD contracts other than purely commercial off-the-shelf procurements, and says that at a “minimum”, contractors must implement NIST 800-171 requirements in order to provide “adequate security” if they store or handle Covered Defense Information (CDI). Link
