DCMA Revises Cyber Supply Chain Review: Updated Guidebook Modifies Audit Standards
Client Alert | 1 min read | 07.16.19
As anticipated, the Defense Contract Management Agency (DCMA) revised its Contractor Purchasing System Review (CPSR) Guidebook as of June 14, 2019, with the most significant updates to Appendix 24, Supply Chain Management Process, to further address supply chain compliance with DFARS 252.204-7012. As we previously noted, the CPSR Guidebook was revised earlier this year to address DoD guidance related to management and oversight of the supply chain in connection with DFARS 252.204-7012.
While much of the CPSR review criteria remain the same, noteworthy revisions include:
- Asking contractors to “show how they have determined” that their subcontractors have an adequate information system that can handle Covered Defense Information, versus the prior guidance to ask contractors to “validate” the adequacy of subcontractor systems.
- Broadening supply chain requirements by applying the Guidebook’s language to “subcontractors,” rather than just “first tier suppliers” as in the prior version.
- Clarifying that the CPSR review is focused only on the protection of “Covered Defense Information” and not “Controlled Unclassified Information” more broadly.
Contacts

Partner and Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 4 min read | 08.07.26
Missouri AG Sues Kansas City Over Race- and Sex-Based Contracting Program
On July 22, 2026, Missouri Attorney General Catherine L. Hanaway filed a federal lawsuit against the city of Kansas City, Missouri, challenging the city’s longstanding Minority and Women Business Enterprise (MWBE) program as unconstitutional. The AG filed the complaint in the U.S. District Court for the Western District of Missouri alongside private plaintiffs Charles Cacioppo Jr. and his company, Industrial Salvage and Wrecking Co.
Client Alert | 2 min read | 08.06.26
Client Alert | 2 min read | 08.03.26
New York Becomes First State to Restrict Addictive Social Media Features for Minors
