In response to a chorus of implementation questions raised by
the contracting community, the US Department of Defense (DoD) has
announced an industry information day, during which contractors who
have questions or wish to provide feedback regarding DoD's
Network Penetration Reporting and Contracting for Cloud
Services final rule can raise those questions. On April 5,
2017, DoD published a notice of meeting in the Federal
Registerannouncing the "Industry Information Day" on
June 23, 2017.
The public meeting will address the implementation of DFARS Case
2013-D018, and the associated DFARS clauses, including DFARS
252.204-7012, Safeguarding Covered Defense Information and Cyber
Incident Reporting (Oct. 2016). The final rule, published October
21, 2016, finalized an interim rule mandating that both prime and
subcontractors safeguard covered defense information, report on
network penetrations, and require adequate security from external
cloud computing services.
We have previously analyzed these new requirements.
The industry day announcement is an important reminder to
contractors of the upcoming December 31, 2017, deadline for
implementing the new security requirements required under the final
rule to qualify for new DoD awards. The event will be held on
Friday, June 23, from 9 a.m. to 1 p.m. at the Mark Center
Auditorium in Arlington, VA. Any contractors with questions or
feedback about the rule's requirements or implementation should
attend. The registration deadline is June 12, 2017. Contractors may
register via email at: OSD.DIBCSIAEvents@mail.mil.
DoD will accept written questions until May 1 at the same address,
and contractors grappling with various implementation questions are
encouraged to submit questions in advance.
For additional details regarding the Industry Information Day,
registration and process for submitting questions, please consult
the meeting notice.
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