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Defense & Intelligence Spotlight
February 2024
As outlined below, PSC's brisk pace of 2024's advocacy and engagement continues as we head into March. To date across the the eight elapsed weeks of 2024, PSC submitted ten comments packages, several of which are highlighted below. Most recently, PSC submitted comments on DoD’s Cybersecurity Maturity Model Certification (CMMC) Program Proposed Rule. Found here on our website, PSC's comments provide DoD perspective on the impact the proposed rule will likely have on industrial base partners, as well as recommendations for improvement prior to issuance of a final rule. Thank you to all the members who contributed their time and effort in preparing these comments.
Continuing our member advocacy, David Berteau will present a PSC research paper entitled “LPTA By Any Other Name” – Recapturing Requirements Discipline in Solicitation and Award,” at the Naval Post Graduate School’s 21st Annual Acquisition Research Symposium in May 2024. In order to fully represent how such behaviors affect our members, and the Defense Industrial Base, we seek your feedback on a short survey, found here. To allow us to incorporate your responses into the paper and peer review cycle, please be so kind as to take 10-15 minutes to complete the survey by Monday, March 11, 2024. Thank you in advance and please feel free to reach out if you have any questions or specific feedback as we prepare the analysis.
Additionally, PSC continues to closely track the progress of FY 2024 appropriations. With continuing resolutions expiring soon, we will continue to update and share all appropriations progress and contractor guidance within PSC'sGovernment Funding and Shutdown Resource Center.
As always, we look forward to engaging on the topics that matter to you. If you’d like to share topics with us – for our consideration or simply for our awareness – please do not hesitate to reach out to me (ayers@pscouncil.org).
Sincerely,
Lauren C. Ayers
Vice President, Defense and Intelligence
ayers@pscouncil.org |571-643-6340
In this edition:
Member Survey: “LPTA By Any Other Name” | Vision Federal Market Forecast – Volunteer Opportunities | Government Affairs Committee Meeting | PSC Member Forum with Senator Mark Warner (VA) | Getting the Most Out of Your Membership | PSC’s 2023 Events Calendar | PSC Comments: NIST SP 800-171 Revision 3 (Final Public Draft) | PSC Comments: Federal Acquisition Supply Chain Security Act (FASCA) Orders | PSC Comments: NISPOM Amendment Proposed Rule | PSC Comments: CMMC Program | CODSIA Comments: CMMC Program | Inside Cybersecurity: "Major industry coalition seeks clarity from DOD on controlled unclassified information, addressing assessment gaps for CMMC program" | Government Funding and Shutdown Resource Center
Member Survey: "LPTA By Any Other Name - Recapturing Requirements Discipline in Solicitation and Award" (Due: March 11, 2024)
In support of a PSC research paper that David Berteau will present at the Naval Post Graduate School’s 21st Annual Acquisition Research Symposium in May 2024, we request your company’s timely feedback via a survey, found here. We would appreciate your response by Monday, March 11, 2024 to support peer review and submittal timelines. Note: We estimate that this survey will take 10-15 minutes to complete. PSC staff will ensure that all responses are aggregated and anonymized; no identifying information will be used (for either an individual or a company). Also, if you have any questions and/or would like to share a specific case study or example relevant to the research analysis and abstract noted in the survey, please feel free to reach out to me directly at ayers@pscouncil.org.
Vision Federal Market Forecast - Volunteer Opportunities
Volunteers will gain valuable insight into the Federal marketplace through exclusive, face-to-face meetings with government agency planners and decision makers, think tank experts, and Wall Street analysts. These engagements will discuss issues facing the federal market, future programs, and budgets. Volunteers will also access in-depth information on government requirements including forecasts, budget trends, reform initiatives, drivers, and potential business opportunities, as well as opportunities to network with your industry peers and competitors. Reach out to Vision Program leads (Michelle Jobse (jobse@pscouncil.org) or Donald Baumgart (baumgart@pscouncil.org) to learn about opportunities on our following teams: Defense Topline, Services, Platforms, and IT/Cyber.)
Government Affairs Committee Meeting – March 1, 2024
Available exclusively to our members, attend the March 1 GAC meeting to get the latest updates on Hill activity, including a conversation with staff of Chairman Jodey Arrington and Sen. James Lankford who will discuss the Prevent Government Shutdowns Act of 2023. This bi-partisan, bi-cameral legislation seeks to end the cycle of government shutdowns that severely impact the efficient spending of government funding, and the ability of Federal contractors to support the federal government. Learn more and register here on our website.
PSC Member Forum with Senator Mark Warner (VA) – March 5, 2024
PSC will host a dialogue with U.S. Senator Mark Warner (VA) from 9:30-10:30 am, Tuesday, March 5, 2024. We anticipate the Senator’s remarks to spotlight the current state of play in Congress, including the FY24 budget, continuing resolutions, possible government shutdowns, supplemental funding, etc. Attendees are invited to come prepared to highlight for him those issues which you face every day as contractors, supporting every mission and function across the federal government. Space is limited; learn more and register here on our website.
Getting the Most Out of Your Membership – March 12, 2024
Over the last several years PSC has made considerable investments in people and capabilities to meet the needs of its members. The value you receive from your membership is directly connected to your level of engagement. Having a clear understanding of the valuable opportunities available with your membership is critical to ensuring that you make the most of your membership and get the highest return on your investment. If you’re new to PSC or it’s been a while since you’ve been able to engage with us, our PSC Membership Orientation is an excellent way to learn about all the opportunities available with your membership, map out an engagement plan for your team and kick-off or re-invigorate your membership. Learn more and register here.
PSC's 2024 Events Calendar
PSC has many other great events coming up. Please check out our events page here for more information.
PSC Comments: NIST SP 800-171 Revision 3 (Final Public Draft) (Jan. 26, 2024)
PSC submitted our comments to NIST's "Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations (NIST Special Publication [SP] 800-171 Revision 3)." on Friday, January 26, 2024, a copy of which is found here on our website. Thank you to all our members who provided feedback.
PSC Comments: Federal Acquisition Regulation: Implementation of Federal Acquisition Supply Chain Security Act (FASCSA) Orders (Feb. 2, 2024)
On February 2, 2024, PSC submitted comments on the Interim Rule, “Implementation of Federal Acquisition Supply Chain Security Act (FASCSA) Orders.” While PSC supports the intent of the statute and of the overall goals of the Interim Rule, our comments identify a number of elements that we believe fail to meet that intent, and which may lead to outcomes that are inconsistent with the goals of the legislation. Click here to access PSC's comments.
PSC Comments: NISPOM Amendment Proposed Rule (Feb. 12, 2024)
On February 12, 2024, PSC submitted comments on needed clarifications regarding: the National Background Investigative Services; specific activities that may adversely impact contractors' national security eligibility; guidance on how and where to report such activities; and guidance on Controlled Unclassified Information. You can access PSC's submission here.
PSC Comments: Cybersecurity Maturity Model Certification (CMMC) Program (Feb. 26, 2024)
On February 26, 2024, PSC submitted comments to the Department of Defense on the “Cybersecurity Maturity Model Certification (CMMC) Program” (Docket ID: DoD-2023-OS-0063). Comments included nine overarching concerns and recommendations, as well as an addendum with specific industry-driven feedback and recommendations on key elements of the proposed rule. Click here to access PSC's comments.
CODSIA Comments: Cybersecurity Maturity Model Certification (CMMC) Program (Feb. 26, 2024)
PSC joined our fellowCoalition of Defense and Space Industry Associations (CODSIA) in comments to DoD’s “Cybersecurity Maturity Model Certification (CMMC) Program” (Docket ID: DoD-2023-OS-0063) proposed rule. Included in the CODSIA letter are specific recommendations in the following key areas 1) Ensure the protection of DoD data by delineating clear and actionable CUI marking instructions and responsibilities in contracts; 2) Futureproof the rule by defining a clear transition process for forthcoming standards revisions; 3) Specify assessment instructions and any applicable reciprocal procurement agreements for international subcontractors; and 4) Enable more flexible Plans of actions and milestones (POA&Ms). Click here to access the CODSIA comments.
Inside Cybersecurity: "Major industry coalition seeks clarity from DOD on controlled unclassified information, addressing assessment gaps for CMMC program"
In this February 28, 2024 article, Inside Cybersecurity highlights the comments submitted by the CODSIA on DoD’s CMMC proposed rule (noted above).
Government Funding and Shutdown Resource Center
Visit PSC’s Government Funding and Shutdown Resource Center for the most up-to-date information and guidance documents from across the federal government, including a link to the August 2023 updated DoD contingency plan, issued on September 12, 2023. Send any suggested revisions to policy@pscouncil.org.