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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.

Insights

Client Alert | 1 min read | 11.04.24

OFCCP Invites Federal Contractors to Object to Production of their “Type 2 EEO-1 Reports” in Response to New FOIA Request

On October 29, 2024, the Office of Federal Contract Compliance Programs (“ ”) published a notice in the Federal Register that it received two requests under the Freedom of Information Act (“ ”) for 2021 Type 2 EEO-1 Reports filed by federal contractors. The two requests came from the University of Utah and a non-profit organization named “As You Sow.” The notified federal contractors that the information might be protected from disclosure under Exemption 4, which protects disclosure of confidential commercial information, and requested that any entities that filed these reports and object to their disclosure submit objections by December 9, 2024. Objectors are strongly encouraged to use the portal. Alternatively, contractors may also submit written objections via email at OFCCPSubmitterResponse@dol.gov, or by mail. ...