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
Partner
She/Her/Hers
Senior Counsel
She/Her/Hers
Insights
Client Alert | 3 min read | 03.03.25
HHS Suggests It Will Provide Less Notice and Opportunity for Comment on Grant and Contract Rules
On February 28, the Department of Health and Human Services (HHS) announced that it was rescinding the Richardson Waiver, a policy in place since 1971 which said HHS would provide notice of proposed rulemaking in certain cases where it was not otherwise required to do so by law. This announcement signals a policy shift for the agency and suggests that where permitted by law, HHS will generally now issue rules relating to “agency management or personnel or to public property, loans, grants, benefits, or contracts” without providing notice and comment to stakeholders, and may otherwise find good cause to forego notice and comment procedures.
Client Alert | 2 min read | 02.28.25
Client Alert | 1 min read | 02.28.25
Client Alert | 3 min read | 02.28.25
