Cybersecurity for Department of Defense (DoD) contractors is an ongoing issue. Now, DoD is issuing an interim rule to implement an Assessment Methodology and Cybersecurity Maturity Model Certification framework. This will assess contractor implementation of cybersecurity requirements and enhance the protection of unclassified information within the DoD supply chain. (Federal Register, DFARS Case 2019-D041 Action: Interim Rule)
The current self-attestation of NIST Special Publication (SP) 800-171 is not working due to a lack of DoD verification. Until the implementation of the interim rule, DoD did not have a mandate to verify contractor basic safeguarding or security requirements prior to contract award. This regulation changes that. The interim rule adds a process for contractors to implement cybersecurity requirements. This is to be accomplished while the DoD’s Cybersecurity Maturity Model Certification (CMMC) and the procedures with the Accreditation Body (AB) are solidified. (Meritalk, September 28, 2020)
Questions about how the new rule will affect your contract or upcoming bid and what you can expect? Give us a call.
After almost 60 years of utilizing a DUNs number, every organization doing business with the government will receive a new identification number. Beginning in December 2020, the number and the process to acquire the Unique Entity Identifier (UEI) will change. The new identifier will be generated through SAM.gov; however, DUNS numbers will be retained for historical purposes and Dunn & Bradstreet open data limitations remain in effect in perpetuity.
GSA is moving to a new, non-proprietary identifier, a 12 character alpha-numeric value, will be assigned by the System for Award Management. The Federal Register announced the new (UEI), including the identifier standards. Additional updates to the UEI can be found here: gsa.gov/entityid. (GSA.gov Unique Entity Identifier Update, September 9, 2019)
As you can imagine, many questions surround the upcoming change, and GSA’s recent online meeting answered some of them. Those that missed the meeting or want to listen again can find the presentation at beta.SAM.gov and selecting the UEI video link. All questions submitted and answers provided are also available on this downloadable pdf.
The transition phase began in July of 2019, but DUNS will continue as the official identifier until December 2020. During the transition, all existing entity registrations will automatically be assigned a new UEI which will be displayed in SAM.gov and no one will be required to re-enter this data. (ibid)
Thinking this small change can lead to a lot of confusion? Have some questions that didn’t get asked or answered during the GSA public meeting? Give us a call.
The 2015 National Defense Authorization Act mandated that the Small Business Administration (SBA) discontinue self-certification of women-owned and other small businesses. In 2020, SBA plans to finalize a self-certification rule that closes a loophole allowing participants in the SBA’s Women-Owned Small Business (WOSB) program to self-certify. (Federal News Network, June 2019)
Approximately one-quarter of all federal contracts are held by small businesses, which over the past six years has helped federal agencies to exceed SBA’s governmentwide small business contracting goal. This year’s spending of more than $120 billion on small business contracts surpasses last year’s spending by nearly $15 billion.
The Government Accountability Office reported in March that almost 40 percent of WOSB-certified businesses were ineligible. Meanwhile, SBA’s Office of Inspector General June 2018 audit found 89 percent of sole-source (50 out of 56 contracts) did not meet all program criteria. Basically, there is currently no way to know if the contracts, listed in the chart below, were actually eligible for the sole-source awards. (ibid)
Rob Wong, SBA’s associate administrator of the Office of Government promotes a formal certification to give the program some much-needed integrity. Wong said, “simply put, the wrong companies were receiving our contracts, we want to make sure that, if a company receives a contract through these programs, they’re actually eligible to receive it.” (ibid)
SBA has subsequently published a proposed rule in the Federal Register eliminating self-certification and providing a free online certification application to WOSB. Comments on the proposed rule are being accepted until July 15. In Wong’s opinion, it is high time to streamline the vetting process for the many other set-aside programs, all of which have different sets of eligibility criteria. Wong feels that going to three formal certifications for 8(a), Historically Underutilized Business Zones, women-owned, and service-disabled veterans will unify the processes. The rule with set-aside screening is expected to take a year for the changes to take effect. (ibid)