NASA Proposes Cyber Lock-Down On Contractors
Client Alert | 1 min read | 08.11.06
Following an outbreak of highly publicized information security breaches ripping through the federal government and prompting new OMB "get-tough" directives, NASA is proposing a new crackdown on contractors that "(1) have physical or electronic access to NASA's computer systems, networks, or IT infrastructure; or (2) use information systems to generate, store, or exchange data with NASA or on behalf of NASA." 71 Fed. Reg. 43408 (Aug. 1, 2006). Under these proposed rules, NASA contractors face a variety of new and expanded cyber requirements that generally add cost and risk to contract performance, including: (1) submitting IT "Security Plans" compliant with National Institute of Standards and Technology (NIST) SP 800-18; (2) performing "Risk Assessments" consistent with Federal Information Processing Standards Publication (FIPS) 199; (3) preparing contingency plans per NIST SP 800-34; (4) conducting annual IT security training; and (5) assuring that contractor personnel with access to NASA IT systems have National Agency Check with Inquiries (NACI) screening.
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Client Alert | 1 min read | 07.08.26
CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117
As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material). The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs). Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests. Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”
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