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Open Access Publications from the University of California

UC Comments on Defense Federal Acquisition Regulation Supplement: Assessing Contractor Implementation of Cybersecurity Requirements (DFARS Case 2019-D041/RIN 0750-AK81; Docket DARS-2020-0034)

Abstract

This comment letter responds to the Department of Defense’s interim rule implementing new cybersecurity assessment and certification requirements for federal contractors. UC supports strengthened cybersecurity protections but requests clearer guidance on how the requirements apply to fundamental research, greater transparency regarding assessment levels, and confirmation that compliance costs are allowable as direct costs on DoD awards.