June 26, 2019

    DoD Contractor Options to Meet DFARS Compliance

    Department of Defense contractors are trusted with some of the government’s most sensitive information. As such, these contractors have a unique responsibility to keep that data secure. DFARS (Defense Federal Acquisition Regulation Supplement) is a set of requirements designed DoD contractors must fulfill to keep sensitive data protected.

    All DoD contractors and subcontractors were required to align with DFARS requirements by the end of 2017. Unfortunately, meeting DFARS compliance standards can be a challenge. With a large quantity of requirements and the comprehensive nature of DFARS (it impacts aspects of your entire organization), aligning with these standards is often overwhelming, especially since partial compliance isn’t good enough.

    Compliance with DFARS is essential, as this set of requirements focuses on how to protect Controlled Unclassified Information (CUI). If you want to maintain your DoD contractor status, you must implement the security framework provided by DFARS. Non-compliance has other negative impacts, too. You could also be subject to data breaches and non-compliance fines if you fail to implement these guidelines.

    To manage the implementation and alignment with DFARS guidelines, you have two options: manage the process yourself or partner with an outside vendor to inherit some of their controls. Let’s explore the benefits and drawbacks of these two possibilities, and find out which one is right for your DFARS compliance needs.

    In-House Compliance

    In-house compliance management is an option many companies choose. Many think it’s easier (and more affordable) to dedicate in-house resources to this effort. As with any business decision, in-house compliance management comes with pros and cons.


    Having a team in-house means you can easily see the progress of your compliance efforts. These teams are easily managed, and directly responsible for your compliance. Having an internal team that is specifically responsible for compliance means that you mitigate the risk of noncompliance, and your have team members constantly working to keep your security measures up to date and effective.

    Also, DFARS provides resources to help in-house teams manage compliance. The best way for your in-house teams to maintain compliance is to follow a DFARS compliance checklist. The Self Assessment Handbook – NIST Handbook 162 provided by NIST is a great resource for companies managing this aspect of their business themselves. This handbook offers instructions on how to self-assess your business operations, ensuring you’re meeting DFARS guidelines.


    While you may believe that you’re saving money by keeping these responsibilities in-house, managing your own compliance efforts can actually come with high costs. In many cases, unless you have a compliance expert already employed at your company, you will need to hire one. Long-term salary and benefits will cost your company hundreds of thousands of dollars over the course of a few years. And, compliance needs never stop. You will always need to monitor your security controls and assess your organization for risk.

    Unless you already have experts in-house to take on this objective for you, it will be a costly challenge for your company to take on this responsibility. Because the risks of noncompliance are so serious, you can’t afford to cut corners or have employees who aren’t compliance experts manage your DFARS compliance. Even with a DFARS compliance checklist to help, there are still mistakes that could be made.


    Outsourced Compliance Management

    In the face of these serious cons that come with managing your own DFARS compliance measures, you may want to consider outsourcing your compliance management. As with in-house management, there are both pros and cons associated with this choice.


    Unlike your own team members who may have other responsibilities or priorities, an outside vendor’s sole focus is on complying with regulations, managing security controls, and regularly assessing your organization for risk. They will be constantly in tune with the latest DFARS compliance checklist updates, as they are watching for any newly released updates.

    These experts will have “seen it all” when it comes to compliance, and they will know how to tackle any challenge that arises for your organization. Unlike the ongoing fees associated with having an in-house team, you save money by only paying a one-time fee to the vendor, and perhaps an annual smaller fee for reassessments. However, these fees are a mere fraction of what an annual salary would cost for an in-house compliance expert.

    Most compliance vendors use a template with each client they assess to ensure they meet compliance standards. This template typically includes:

    • Analysis for security gaps and vulnerabilities
    • Creation of a remediation plan to address vulnerabilities
    • Ongoing monitoring and reporting of cyber security effectiveness
    • Legal documentation for compliance efforts

    The biggest pro in the outsourcing column is that the responsibility of compliance is taken off your shoulders and put on those of an expert vendor. You don’t have to worry about errors or partial compliance. You can trust that your partner vendor has successfully complied with DFARS regulations on your behalf.


    Although there are so many benefits to working with an outside vendor, there are a few drawbacks as well. For example, since the vendor is not an official part of your organization. This means they don’t know the ins and outs of your organization, which could make it hard to put your security controls in context.

    The best way to combat miscommunication and inform your partner is to designate a single point of contact within your organization to work with the vendor. This point of contact can explain your business processes and assist the vendor in their compliance efforts. They can also keep your team up to date on the vendor’s progress.

    DFARS and Cloud Service Providers

    DFARS compliance not only affects many parts of your organization, it also applies to things you outsource to vendors such as Cloud Service Providers (CSP). If your company’s internal and external communications requires cloud-based file sharing, one option to assist with your DFARS compliance efforts is to adopt a secure file sharing solution. The right solution will already have extra security features built in, and can make both your initial and your ongoing compliance easier. A secure file sharing solution allows you to store and share your CUI using DFARS-approved methods. This is an option you could discuss with your compliance partner to gain more insight.

    Working with vendors who understand your requirements alleviates much of the burden that comes with DFARS compliance. Because this process can be so complicated and failure to comply could have serious impacts on your business, it’s best to trust this to the experts. While you could manage compliance completely on your own, it’s often too expensive and too laborious to do so successfully. With the help of a compliance partner and the right outsourced CSP’s, you can maintain the controls appropriate for a DoD contractor, ensuring your CUI is not at risk.

    Learn more about the government compliance regulations your business should adopt. Explore this comprehensive guide now.


    Tag(s): Government

    Martin Horan

    Martin, Sharetru's Founder, brings deep expertise in secure file transfer and IT, driving market niche success through quality IT services.

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