Mark Hijar’s Post

Something somewhat interesting I was discussing with a client today: DFARS 252.225-7004 requires notice via DD2139 of all unanticipated performance by foreign suppliers. Per DFARS 225.7202, the notice requirement applies to all noncommercial orders exceeding $750,000 in total value; orders for commercial products or services are exempted from the requirement. But also ... DFARS 252.215-7013 says all products and services from nontraditional defense contractors can be procured on a commercial basis, even if the products and services themselves are not commercial and without a CID. Nontraditional defense contractor is defined as a contractor that is not subject to full CAS coverage. To my knowledge no foreign entity is subject to full CAS coverage, only those parts prescribed by FAR 52.230-4. Does this mean that the only orders awarded to foreign entities that require DD2139 notice are those awarded on a cost reimbursable basis? I would say ... per the regs, that seems to be the case.

Many defense contractors will be required to revise their subcontract terms and conditions for commercial products and services to comply with a recent DFARS final rule. DoD prime contractors will no longer be allowed to flow down FAR or DFARS clauses in commercial subcontracts beyond those that are required by the FAR or by the terms of the clause. Zachary Prince, Jonathan Shaffer, and I explain in a new client alert (see link in comment). #govcon #dod #subcontracts #commercial

Now that the CMMC rule has been dropped, many defense contractors are under pressure to make real progress on their compliance efforts. However, internal resource constraints, conflicting advice, and shifting timelines can take a toll on those efforts. Join C3 today at 2 pm ET for our ongoing webinar on how our Steel Root portfolio of solutions can help you overcome those challenges. Space is limited, so grab your seat now! 👇 https://lnkd.in/d_NSnnfu #CMMC #Webinar

Missed our content on the ITAR for aerospace and defense? Take a look at our blog post and white paper to learn how ShardSecure protects technical data and supports ITAR compliance: https://hubs.la/Q02nPx3D0 https://hubs.la/Q02nPj1l0 #datasecurity #dataprivacy #itar #compliance

Any DIB firms who'd like to focus on your DoD business and partner with a solid firm to help you attain and maintain your NIST / CMMC compliance, give me a direct message. Getting a 110 SPRS score doesn't have to be a major pain. Let's chat!

Join us for another insightful webinar on navigating the complexities of CMMC compliance for defense contractors with our CRO, Bill Wootton. With the recent rollout of the CMMC rule, defense contractors are under increasing pressure to meet compliance standards. Yet, navigating the intricacies of this framework can be daunting, especially with internal resource constraints and shifting timelines. Join us for a comprehensive discussion where we'll delve into: 🛑 Common Challenges: Explore the hurdles that often hinder progress in CMMC compliance efforts. 🔧 Solutions Showcase: Discover how our Steel Root portfolio of solutions can streamline your compliance journey. 🔑 Key Strategies: Learn actionable strategies to overcome obstacles and make tangible progress. Register now, and we will see you on Wednesday at 2 pm EST. https://lnkd.in/eJbbHCVV

📣 IMPORTANT UPDATE ON CMMC 2.0 📣 Key Takeaways: ✔️CMMC Final Rule expected publication: September - October ✔️Rule effective: ~60 days post-publication ✔️Defense contractors have less time than expected to prepare for CMMC What Matters: ✔️Industry experts estimate that CMMC can take up to 3-4 quarters to prepare for ✔️It is estimated that there are 80,000 companies falling into CMMC level 2 alone Our message to the defense industrial base remains consistent: Ensure you are planning and working towards CMMC readiness. Please reach out for support if you have any questions.

Read all about the government contracting industry trends in the Winter 2024 The Real Economy: Industry Outlook, including what the 2024 NDAA means for middle market defense contractors.

Read all about the government contracting industry trends in the Winter 2024 The Real Economy: Industry Outlook, including what the 2024 NDAA means for middle market defense contractors.

Read all about the government contracting industry trends in the Winter 2024 The Real Economy: Industry Outlook, including what the 2024 NDAA means for middle market defense contractors.