DoD Meets Contractors Half-Way at Industry Information Day
Client Alert | 1 min read | 06.28.17
On June 23, the Department of Defense hosted its highly anticipated Industry Information Day to respond to feedback received from the contracting community regarding last year’s finalization of DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting. Top of mind for many in attendance was the looming end-of-year deadline to implement NIST SP 800-171, including its requirements regarding multifactor authentication. By the end of the session, however, DoD representatives repeatedly stated that contractors may use system security plans (SSPs) and plans of action and milestones (POAMs) to document their anticipated implementation of the required controls and thus comply with the Clause – even if the actual implementation of those controls extends beyond 2017. A revised set of FAQs is expected next month, which should provide additional details regarding this new guidance.
Contacts
Partner, Crowell Global Advisors Senior Director
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Insights
Client Alert | 3 min read | 11.21.25
On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future.
Client Alert | 3 min read | 11.20.25
Client Alert | 3 min read | 11.20.25
Client Alert | 6 min read | 11.19.25
