1. Home
  2. |Insights
  3. |Uncontrolled Information: DoD Audit Finds Contractor Lapses in Protecting Controlled Unclassified Information

Uncontrolled Information: DoD Audit Finds Contractor Lapses in Protecting Controlled Unclassified Information

Client Alert | 1 min read | 08.02.19

The Department of Defense Inspector General has released a much-anticipated audit report regarding the protection of Controlled Unclassified Information (CUI) on contractor networks.  Begun last summer at the Defense Secretary’s request, the audits found that contractors are not consistently implementing cybersecurity standard NIST SP 800-171, despite being required to do so under DFARS 252.204-7012.  The report calls particular attention to common shortcomings regarding multifactor authentication, strong passwords, vulnerability management, and removable media, among others.

The report recommends that DoD:

  • Verify that contractors are identifying, responding to, and reporting cyber incidents involving CUI;
  • Assess contractors’ ability to protect CUI as part of the solicitation process; and
  • Validate, at least annually, that contractors are complying with their contractual cybersecurity requirements.

These recommendations are consistent with recent DoD efforts to establish a “Cybersecurity Maturity Model Certification” that would require contractors to be certified compliant with contractually-specified cybersecurity requirements to be eligible for award.

Contacts

Insights

Client Alert | 3 min read | 10.10.25

New Post Appeals Mediation Pilot Program

On October 1, 2025, the IRS Independent Office of Appeals launched a two-year pilot program to make Post Appeals Mediation (PAM) more attractive and accessible to taxpayers. See IRS Announcement 2025-10. The new PAM pilot program offers taxpayers the opportunity to be assigned to a new Appeals team, which is otherwise unconnected to the underlying case, who will represent the original Appeals team in the mediation session. The assignment of the new Appeals team does not begin a new appeals process but rather is intended to help facilitate an expedited and impartial look at the underlying case with the goal of further exploring all potential paths to resolution prior to litigation....