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DCMA’s Cybersecurity Oversight Takes Shape: Revised CPSR Guidebook Outlines DFARS Safeguarding Clause Audit Standards

March 6, 2019

Following guidance issued by Under Secretary of Defense Lord, the Defense Contract Management Agency (DCMA) has revised its Contractor Purchasing System Review (CPSR) Guidebook to incorporate new standards DCMA auditors will use to assess contractor supply chain management under the DFARS Safeguarding Clause 252.204-7012.  Notably, the new standards require contractors to “validate” that their subcontractors have information systems “that can receive and protect” Covered Defense Information (CDI) and to “determine” whether subcontractor systems are “acceptable.”  Other new standards require contractors to demonstrate:

  • How CDI is properly marked and securely transferred to subcontractors; and
  • How subcontractor notifications regarding requests to vary from the NIST requirements and the submission of cyber incident reports are managed and documented.

The revisions also emphasize that 252.204-7012 is not an indiscriminate flowdown and applies only where the subcontractor will be utilized for operationally critical support or performing duties that involve CDI.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Nicole Owren-Wiest
Partner – Washington, D.C.
Phone: +1.202.624.2863
Evan D. Wolff
Partner – Washington, D.C.
Phone: +1.202.624.2615
Maida Oringher Lerner
Senior Counsel – Washington, D.C.
Phone: +1.202.624.2596
Christopher D. Garcia
Counsel – Washington, D.C.
Phone: +1.202.688.3450
Michael G. Gruden, CIPP/G
Associate – Washington, D.C.
Phone: +1.202.624.2545