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The Defense Federal Acquisition Regulation Supplement (DFARS) is a set of regulations meant to ensure that defense contractors maintain adequate cybersecurity measures. The DFARS Clause 252.204-7012 requires contractors to protect covered defense information (CDI) and controlled unclassified information (CUI). This clause also requires contractors to establish and maintain controls over the dissemination of information within their organizations and take steps to protect the confidentiality of such information. Contractors who violate this clause may be subject to criminal and civil penalties.
The rule established a DoD Assessment Methodology and Cybersecurity Maturity Model Certification (CMMC) framework to evaluate contractor compliance with cybersecurity standards and increase the security of unclassified data throughout the DoD supply chain.
Defense contractors that are not compliant with DFARS can face severe consequences including contract suspension, termination, or fines. In addition, failing to comply with DFARS can damage a company’s reputation and make it more challenging to do business.
The Department of Defense (DoD) has implemented a series of clauses within the Defense Federal Acquisition Regulation Supplement (DFARS) aimed at strengthening cybersecurity for contractors and subcontractors who handle sensitive DoD information. These DFARS clauses are essential for safeguarding Controlled Unclassified Information (CUI) and protecting the defense supply chain from cyber threats. Compliance with these clauses is mandatory for contractors working on DoD contracts and helps to ensure their systems and processes meet the rigorous standards required to secure federal information. Here, we’ll cover each clause’s primary objectives and requirements, along with insights into how they work together to support the DoD’s cybersecurity goals.
DFARS Clause 252.204-7012: Protecting CUI and Reporting Cyber Incidents (Effective December 2017)The DFARS clause 252.204-7012, titled “Safeguarding Covered Defense Information and Cyber Incident Reporting,” mandates specific protections for Controlled Unclassified Information (CUI) and requires reporting of cyber incidents. Here are the key points:
Information Sharing and Analysis: In some cases, contractors must provide the government with access to information related to the incident. This clause underscores the DoD’s commitment to understanding the nature of cyber incidents affecting contractors and ensuring continuity in national defense operations.
Clause 252.204-7019, titled “Notice of NIST SP 800-171 DoD Assessment Requirements,” adds an extra layer of cybersecurity requirements to contractors by formalizing the need for an assessment of NIST SP 800-171 compliance.
The DFARS clause 252.204-7020, titled “NIST SP 800-171 DoD Assessment Requirements,” outlines additional measures beyond the Basic Assessment for contractors who may be required to submit to a Medium or High NIST SP 800-171 DoD Assessment based on contract requirements. This clause focuses on government oversight and the ability to verify contractors’ compliance at a higher level when needed.
Documentation and Cooperation: Contractors must be prepared to provide evidence of their cybersecurity controls, including system logs, policies, and procedures. Maintaining up-to-date documentation is essential for successful compliance in the event of a government-led Medium or High Assessment
DFARS Clause 252.204-7021: Cybersecurity Maturity Model Certification (CMMC) Requirement (Effective 2021)The Cybersecurity Maturity Model Certification (CMMC) program introduced through DFARS clause 252.204-7021 establishes a cybersecurity framework specifically designed to protect CUI within the defense industrial base. The clause formalizes requirements for contractors to achieve CMMC certification at the level designated by the contracting activity, depending on the sensitivity of the information they handle.
Complying with these DFARS cybersecurity clauses is not only a contractual obligation for DoD contractors but also a strategic business necessity. Non-compliance can result in lost contracts, penalties, and potential exclusion from future DoD contract opportunities. Furthermore, by adhering to these clauses, contractors strengthen their cybersecurity posture, protect sensitive defense information, and contribute to national security.
These clauses work together as a comprehensive security strategy:
Compliance can be complex, but understanding these requirements and incorporating them into cybersecurity planning enables contractors to successfully navigate the DoD’s cybersecurity landscape.
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The Defense Federal Acquisition Regulation Supplement (DFARS) is a set of regulations meant to ensure that defense contractors maintain adequate cybersecurity measures. The DFARS Clause 252.204-7012 requires contractors to protect covered defense information (CDI) and controlled unclassified information (CUI). This clause also requires contractors to establish and maintain controls over the dissemination of information within their organizations and take steps to protect the confidentiality of such information. Contractors who violate this clause may be subject to criminal and civil penalties.
In September 2020, the Department of Defense (DoD) published an interim rule to update the DFARS. The rule established a DoD Assessment Methodology and Cybersecurity Maturity Model Certification (CMMC) framework to evaluate contractor compliance with cybersecurity standards and increase the security of unclassified data throughout the DoD supply chain.
To comply with DFARS, defense contractors must have a written system security plan, implement risk management processes, and undergo annual vulnerability assessments.
A system security plan is a document that outlines the security measures for a computer system. It includes information about the system’s hardware and software and the people who have access to it, and should address how you will protect the system from unauthorized access and backup data in an attack or disaster. System security plans are essential for businesses and organizations that rely on computer systems to store sensitive information and can ensure that your systems are protected against potential threats.
Risk management processes are required for DFARS compliance, as they help identify and mitigate potential threats to the security of a defense contractor’s systems and data. Companies can use many different risk management processes, but there are common steps to creating a well-conceived plan for risk management.
Annual vulnerability assessments help identify weak-spots in defense contractors’ systems and determine their risk level. The assessments involve scanning systems for vulnerabilities and examining them for signs of attack. They also include tests to see how well the security measures are working and interviews with personnel to better understand the organization’s security posture.
If you discover a cyber incident that affects a computer or data related to your contract, you are required to investigate whether any covered defense information was compromised. You must identify which computers were affected, any stolen data, and which user accounts the intruder used. The review will also involve analyzing covered contractor information systems and other systems on your network that the intruder may have accessed during the incident. The main focus is identifying any compromised covered defense information or impact on the contractor’s ability to provide operationally critical support. The cyber incident then must be reported to https://dibnet.dod.mil. If malicious software was used in conjunction with the incident, it must be submitted to the DoD Cyber Crime Center following the directions that they will provide.
Risk management is a critical component of DFARS compliance, as it allows you to assess and mitigate cybersecurity risks. By implementing risk management processes, you can ensure that you take the necessary steps to protect your networks and data from potential threats. To comply with DFARS, you must have a comprehensive risk management plan.
You can take several steps to implement effective risk management processes. Some of the most important steps include:
1. Identifying and assessing risks: You should evaluate the nature of the data being processed and stored and the potential threats that could put that data at risk.
2. Developing mitigation strategies: Once you identify your risks, you must develop a mitigation strategy. You should tailor these risk strategies to the identified risks and include measures such as security controls and contingency plans.
3. Implementing risk management processes: This is possibly the most challenging part of the process. It would be best to implement the risk management processes to prioritize operations while minimizing risk. Implementation is not the only focus, as you must put mitigation strategies in place and then monitor the environment for changes that could impact data security.
4. Reviewing and updating risk management plans: You should regularly review your plans to ensure that they address the present risks effectively. You should also update plans as you identify new risks, or as the threat landscape changes.
Defense contractors that are not compliant with DFARS can face severe consequences including contract suspension, termination, or fines. In addition, failing to comply with DFARS can damage a company’s reputation and make it more challenging to do business.
1. Keep track of the General Services Administration (GSA) updates. The GSA provides regular updates on DFARS compliance, including changes to the regulations and helpful resources like fact sheets and guidance documents. Companies can find this information at www.acquisition.gov.
2. Sign up for email alerts from your favorite news sources. Automated tools such as Google Alerts provide tailored access to breaking news and analysis on cybersecurity issues, including updates on DFARS compliance.
3. Attend industry events and webinars. Industry events allow networking with other professionals and learning about the latest compliance issues. Webinars offer convenient online access to expert insights on various topics.
Alluvionic provides Project Assurance by combining certified cybersecurity expertise and technical project management. Additionally, we will leverage organizational change management and risk management to assure the successful delivery of DFARS-compliant projects. Our team will work with you to ensure your organization is compliant with DFARS regulations and that your system security plan is adequate and properly implemented.
Failure to comply with DFARS can result in significant consequences, so it’s vital to stay up-to-date on the latest information on this topic. At Alluvionic, we are committed to helping our clients achieve and maintain compliance with DFARS and other cybersecurity regulations. Let us know if you need help getting started or need more information on DFARS compliance.
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NAICS Codes: 541611, 541330, 541511, 541512 ,541519, 541613, 541614, 541618, 541990, 561990, 611420, 611430, 813910, 813920
