1. Home
  2. |Insights
  3. |DCMA Revises Cyber Supply Chain Review: Updated Guidebook Modifies Audit Standards

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.

Contacts

Insights

Client Alert | 4 min read | 08.25.26

Recent Court Decision Highlights Effectiveness of “Second Bite” Protests

A recent U.S. Court of Federal Claims (COFC) decision serves as an important reminder that when the Government Accountability Office (GAO) denies a protest, this is not necessarily the end of the road. Often, contractors retain the right to file a new protest at the COFC, which conducts its own de novo review of the procurement record. This so-called “second bite at the apple” protest is a powerful tool as the COFC’s recent decision in Chugach Logistics & Facility Services JV, LLC v. USA makes clear....