Department of Defense Subcontractors

News & Analysis as of

Expanding Cybersecurity Safeguarding Requirements, Reporting Obligations, and Cloud-Based Security: A Brief Guide to Understanding...

The United States Department of Defense promulgated an “interim” rule, effective August 26, 2015, which placed imposing and costly burdens on all DoD contractors and subcontractors (including small businesses and commercial...more

More Cybersecurity Rules

This update will cover two things: (1) the new (yes, again) Department of Defense cybersecurity interim/final rule on reporting cyber incidents by contractors / subcontractors and (2) the money to fund these new rules and...more

Alert: New Department of Defense Regulations Mandate the Reporting of Cyber Incidents

The Department of Defense (DoD) has published regulations that require DoD contractors to report cyber incidents impacting unclassified DoD contractor systems. The new regulations mandate compliance with elements of the...more

Department of Defense Issues New Cybersecurity Rules for Defense Agencies That Use Contractors and Cloud Services to Hold...

The U.S. Department of Defense (DOD) recently published an interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS).1 The interim rule, effective August 26, 2015, focuses on two issues. First, the...more

Have DoD Contractors and Subcontractors Been Drafted? Once Voluntary Defense Industrial Base CS/IA Regulations Now Mandatory and...

When last we left the Department of Defense, they had issued a rather wide-reaching interim DFARS rule addressing cybersecurity practices, data retention, and cloud services purchasing guidance. Now, effective October 2,...more

Proposed rule clarifies contractor requirements for counterfeit electronic part detection and avoidance

Yesterday, September 21, 2015, the Department of Defense (DOD) published a proposed rule in the Federal Register that would amend the Department of Defense FAR Supplement (DFARS) to further implement Section 818 of the...more

Weekly Update Newsletter - September 2015

GOVERNMENT CONTRACTS - President Obama Signs Executive Order Establishing Paid Sick Leave for Federal Contractors - President Obama signed an Executive Order on Monday September 7, 2015, requiring federal...more

DoD's New Cybersecurity and Cloud Standards and Reporting Requirements

The Department of Defense (DoD) released interim rules implementing provisions of the 2013 and 2015 National Defense Authorization Acts. The rules, released on Aug. 26, 2015, are effective immediately and establish the...more

Defense Department Issues Interim Rule Requiring Contractor and Subcontractor Reporting of Cyber Incidents

On August 26, 2015, the Department of Defense (DoD) published a long-awaited Interim Rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to require “rapid” reporting of “cyber incidents” that result in...more

DoD Addresses Cybersecurity Preparedness, Incident Reporting, and Cloud Computing Acquisitions with new DFARS interim rule

Announced and effective today, August 26, 2015, DoD has issued an interim rule that significantly expands existing DFARS provisions and clauses requiring contractors and subcontractors to report cyber incidents. The interim...more

DoD Inspector General Publishes List of Postaward Fraud Indicators

On July 29, 2015, the Office of the Inspector General for the Department of Defense published on its website new “Contract Audit Fraud Scenario and Indicators for Material Pricing Deficiencies in a Postaward Audit.” While...more

Proposed FAR Changes To Implement SBA Small Business Subcontracting Rules

DOD, GSA, and NASA have proposed a number of changes to the FAR to implement changes made by the Small Business Administration in 2013 regarding small business subcontracting goals and plans. While the proposed FAR changes...more

Agencies Issue Proposed Rule, Guidance on Blacklisting Executive Order

The federal agencies charged with implementing President Obama's July 31, 2014 Fair Pay and Safe Workplaces Executive Order have released their much-anticipated proposed rule on this directive. On May 27, 2015, the Department...more

Weekly Update Newsletter - January 2015 #4

GOVERNMENT CONTRACTS - SBA Considering Extending Comment Period for Proposed Rule on the Limitations on Subcontracting - Although not yet official, we anticipate that SBA will grant an extension until April 6th...more

Weekly Update Newsletter - January 2015 #3

GOVERNMENT CONTRACTS - DoD Issues Proposed Rule to Amend DFARS Past Performance Information Retrieval System – Statistical Reporting (PPIRS-SR) (DFARS Case 2014-D015) - The Department of Defense (DoD) issued a...more

Weekly Update Newsletter - September 2014 #3

8(A) Subcontracting Limitations: Continued Noncompliance with Monitoring Requirements Signals Need for Regulatory Change - The Government Accountability Office (GAO) has conducted a study to review how federal agencies...more

Weekly Update Newsletter - August 2014

In this issue: - DoD, GSA, and NASA Issue an Interim Rule to Amend FAR: Equal Employment and Affirmative Action for Veterans and Individuals With Disabilities - DoD, GSA, and NASA Issue a Final Rule to Amend...more

Government Contracts Quarterly Update - July 2014

The Government Contracts Quarterly Update is published by BakerHostetler’s Government Contracts Practice team to inform our clients and friends of the latest developments in federal government contracting. Topics will...more

The OFCCP Calls a Moratorium on Enforcement Activities Against TRICARE Providers

On May 7, 2014, a Directive of the Office of Federal Contract Compliance Programs (“OFCCP”) placed a five-year moratorium on enforcement activities regarding health care providers that are TRICARE subcontractors. TRICARE is...more

Construction Ahead: How Our Construction Industry is Fueled by the Energy Environment

In 2007, Global Business Network (“GBN”) released the report, “Energy Strategy for the Road Ahead.” The goal of the report was to “understand the factors that are likely to influence the U.S. energy environment in the...more

Victory in House of Representatives for Improvements to WOSB Federal Contract Program

On May 7, 2014, the Office of Federal Contract Compliance Programs (OFCCP) issued Directive 2014-01, instituting a five-year moratorium on the OFCCP enforcement over TRICARE subcontractors. The moratorium applies to health...more

OFCCP’s New Tricare Moratorium Directive: Delay of Game

On March 7, 2014, the Office of Federal Contractor Compliance Programs (OFCCP) issued Directive 2014-01, TRICARE Subcontractor Enforcement Activities concerning the affirmative action obligations of subcontractors of...more

OFCCP Setting Its Sites On TRICARE Providers?

Healthcare providers are waiting anxiously to see the Office of Federal Contract Compliance Programs’ (OFCCP) most recent position on whether it will continue trying to assert jurisdiction over them on the basis of...more

Data Security Advisory for Federal Contractors: Safeguarding Unclassified Controlled Technical Information

The Department of Defense (DoD) has published its new final rule governing the security measures imposed on DoD unclassified technical information resident on or passing through the unclassified information systems of its...more

DOD Updates Contractor Whistleblower Regulations—Increased Enforcement and Litigation on the Horizon

On September 30, 2013, the Department of Defense (DOD) published a potentially significant Interim Rule to amend the Defense Federal Acquisition Regulations (DFARS)—DFARS Case 2013-D010. This rulemaking brings DOD regulations...more

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