Defense contractors and subcontractors
DFARS compliance consulting and SPRS readiness
Connect the requirements in your contract to the controls and evidence in your environment. AeoliTech helps scope covered systems, identify NIST SP 800-171 gaps, prepare System Security Plans, and organize the evidence behind an SPRS assessment.
Discuss your DFARS requirementsStart with the contract and the CUI boundary
A useful readiness review starts with the clauses in your solicitation or contract and where Controlled Unclassified Information (CUI) is received, stored, processed, or transmitted. Map people, systems, cloud services, and subcontractors before selecting the evidence to collect. Federal Contract Information (FCI) and CUI have different safeguarding requirements. Contract requirements and applicable guidance determine the baseline for your review.
How the DFARS cybersecurity clauses fit together
DFARS 252.204-7012: safeguarding and incident reporting
This clause addresses covered defense information, adequate security, cyber incident reporting, and related obligations. Identify the covered systems, applicable NIST SP 800-171 requirements, external service providers, and subcontractor flow-downs. Evidence preparation does not replace incident reporting or the other duties in the clause.
Read the official requirementDFARS 252.204-7019: NIST SP 800-171 assessment information
Where applicable, offerors need a current NIST SP 800-171 assessment for relevant covered contractor information systems in the Supplier Performance Risk System (SPRS). The assessment scope, date, and score should be supported by the implementation record.
Read the official requirementDFARS 252.204-7020: government assessment support
This clause addresses access and information needed for government assessments and relevant subcontractor assessment requirements. Prepare control evidence and system documentation so reviewers can understand the basis for your assessment.
Read the official requirementDFARS 252.204-7021: CMMC requirements
CMMC requirements depend on the applicable contract and current implementation guidance. Confirm the required status and assessment path before planning an engagement. Consult the current official CMMC guidance for rollout changes.
Read the official requirementWhat a readiness engagement can produce
- A documented system boundary and CUI data-flow map.
- A NIST SP 800-171 gap assessment tied to implementation evidence.
- A System Security Plan (SSP) that describes the actual environment.
- A prioritized Plan of Action and Milestones (POA&M) for remediation, subject to applicable rules.
- An evidence index and supporting records for assessment and SPRS reporting.
Agree on scope and deliverables before work begins. Explore the CMMC Level 2 and NIST 800-171 gap assessment or review our readiness and remediation services.
What supports a defensible SPRS score?
Trace each assessment result to implemented requirements and supporting evidence. Record gaps accurately, use the applicable assessment methodology, and keep the SSP consistent with the system being assessed. The responsible organization owns its submission and affirmation. Consulting support and software do not replace that accountability or guarantee an assessment result.
Is DFARS readiness the same as an ATO?
Contractor safeguarding and assessment obligations differ from a federal system authorization to operate (ATO). Federal authorization work uses an applicable Risk Management Framework (RMF) process and selected NIST SP 800-53 controls. The authorizing official makes the authorization decision. For the software workflow, see PolicyCortex ATO evidence and NIST 800-53 support.
Consulting supported by PolicyCortex
AeoliTech provides scoped assessment and implementation assistance. PolicyCortex is the software used to organize requirements, evidence, and remediation work. Explore DFARS compliance evidence software and NIST 800-171 compliance software. Engagement deliverables support review; they are not a certification, legal opinion, or agency authorization.