Hardie said Forward Always Farmstead is not her family’s primary source of income — she and her husband have unrelated jobs off the property — but that it’s a labor of love for her and her family, and she’s grateful for the assistance BEGAP provided.

On the opposite end of the spectrum is Forward Always Farmstead, a small farm in Waterbury that received $147.45, the lowest amount of any BEGAP grant.

The audit requirements only require DCMA direct assessment of tier-one suppliers, however this is expected to impact the entire DoD supply chain for contractor business partners as well.  If an organization wants to compete for DoD contracts in the supply chain market and be able to demonstrate accountability with an easy “Yes” on a DFARS vendor survey, be proactive and contact an expert security focused third-party Managed Security Service Provider (MSSP). An MSSP with specialized expertise in DFARS compliance requirements for DoD contractors will assist your organization in performing the required assessment and audit, and conducting any remediation work necessary to achieve DFARS compliance.

“We had moved [to Waterbury] after Irene so we knew it was a possibility, though we had hoped it would be another 100 years before that happened.” Hardie said, noting the farm is situated on a hundred-year floodplain. “Unfortunately, that field has now flooded three times in the past year.”

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Among the businesses decimated by last year’s flooding was Simon Pearce, a glass and pottery company. Floodwaters infiltrating the company’s flagship location in Quechee, which includes a restaurant, store, and glassblowing facility, and caused over $2 million in damage, CEO Jay Benson said.

If you are a client or a business that supports clients that serve the Department of Defense (DoD) as a contractor or subcontractor you’ve likely heard of Defense Federal Acquisition Regulation Supplement (DFARS).  Protecting sensitive national defense information shared with and created and maintained by private organizations that support federal government contracts is vital to our national security. DoD contractors that process, disseminate, store or transmit Controlled Unclassified Information (CUI) are required to meet DFARS minimum security standards or risk losing existing DoD contracts and eligibility for future contracts.

Our security services are first class all the way, utilizing the best tools, provisions, and practices to keep your company safe from disruptive security data breaches. Vulnerability assessments, real-time behavioral monitoring, intrusion detection, sophisticated digital pattern tracking and an inherent understanding of how hackers operate are just a few of the reasons why RSI Security is a leader in digital cybersecurity solutions.

If malicious software is determined to be part of the reported incident, a description of the event must also be submitted to the DoD’s Cyber Crime Center. Incident reporting guidance requires preservation and protection of images of all known affected information systems and all relevant monitoring/packet capture data for a minimum of 90 days from a cyber incident report submission. If the DoD decides to conduct a formal assessment of damage caused by a cybersecurity event, a contractor would be required to submit media and other materials that support that assessment.

A defense contractor that is audited by the DoD and found to not be in compliance would likely face a stop-work order. This would mean any work done for a DoD contract would be suspended until appropriate security measures are implemented to effectively protect CDI. The DoD could also levy financial penalties that may include damages for breach of contract or false claims. In severe noncompliance cases, the DoD could terminate contracts or even suspend a contractor from ever working with the DOD again.

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The program is a bit more complicated this year, as it covers three main sets of businesses: those damaged in just the 2023 floods, like Simon Pearce; those damaged in just the 2024 floods; and those damaged in both, like Forward Always Farmstead. The application should take 30-45 minutes if applicants have all of the required documents ready, Department of Economic Development Commissioner Joan Goldstein said. And for businesses with an edge case, Goldstein still recommends applying.

The glassblowing facility, one of two kitchens, the hydroelectric turbine that powers the building, and the dam the turbine lives in were all damaged by floodwaters. To make matters worse, the Quechee covered bridge was also damaged — making it hard for customers to reach the facility even once the restaurant reopened, Benson said.

To achieve DFARS cyber security compliance, a defense contractor’s information systems must provide the same protections and meet the same DFARS compliance requirements for federal data as an internal federal information system. Protection of Covered Defense Information (CDI) is a core DFARS requirement, and CDI is a subset of Controlled Unclassified Information (CUI). CDI is provided to a contractor by the DoD, and it becomes the responsibility of the contractor to protect the security and integrity of the information. CDI has four subcategories, controlled technical information (CTI), operations security information, export-controlled information, and other marked information that requires protection.

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The company ultimately received $422,800 from BEGAP, the fourth-highest amount of all businesses in the state. Benson said they spent the funds on cleanup, replacing kitchen equipment and electrical equipment for glass blowing, and new flood prevention measures.

DFARS Clause 252.204-7012 was amended to limit flow-down compliance to subcontractors and suppliers whose efforts involve CDI or are considered operationally critical support. DoD prime contractors under DFARS are obligated to be proactive by strengthening the entire supply chain, ensuring not only their own DFARS compliance, but ensuring subcontractors demonstrate compliance as well. Consequently, subcontractors are responsible for reporting any practices that could deviate from the DFARS and NIST 800-171 guidelines before any CDI is shared with the subcontractor. It is important that a prime contractor control what information flows down to subcontractors based on the CDI data a subcontractor will need to access to perform their assigned work under a federal contract.

In January 2019, the Under Secretary of Defense issued a memo documenting the intent to audit the DoD supply chain for DFARS compliance. The memo tasks the Defense Contract Management Agency (DCMA) with auditing all tier one contractors to validate contractor compliance with DFARS clause 252.204-7012 requirements. A DCMA audit for an organization with a DoD contract with CDI will generally include the following:

If a contractor uses a cloud service provider to store, process or transmit CDI for a DoD contract, there are three security standards that may be relevant for DFARS compliance:

DFARS (Defense Federal Acquisition Regulation Supplement) standards were rolled out in an interim rule published in August 2015 with the rule amended in October 2016. DFARS provides a regulatory structure for DoD contractors to proactively comply with certain security frameworks in order to reinforce cybersecurity for the DoD supply chain. Under DFARS Clause 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting,” DoD contractors must comply with NIST Special Publication 800-171 that provides a requirement framework for contractors to protect sensitive defense information on unclassified, non-federal systems and report cybersecurity incidents.

CTI is technical information related to military operations, however it is not considered general DoD information. Viewing CTI does not require a security clearance however it is not publicly available information. CTI is subject to controls on its access, display, use, disclosure, reproduction, modification, performance, or dissemination.  DFARS provides additional definition for CTI to include:

“We put flood doors on some of the lowest access points in the space,” Benson said. “Given that we’ve now had two hundred-year floods in the last 15 years, we decided it was appropriate to spend some of it to prevent future water penetration.”

Combined with around $500 from the U.S. Department of Agriculture’s Farm Service Agency and their own money, the Hardies were able to replant, only to see their land inundated again in December 2023 and this past July.

Cybersecurity events experienced by subcontractors must be reported to the prime contractor or to the next tier subcontractor, with evidence provided per DFARS requirements.  The prime contractor is responsible for DoD incident reporting with evidence submitted as detailed for contractors above.

Laura Hardie and her husband primarily grow lavender plants, annual cut flowers and Christmas trees. The Hardies planted their first crop of about 300 lavender plants and 200 Christmas trees in the spring of 2023, only to lose a third of the lavender and half of the trees to flooding that July.

An MSSP like RSI Security who has specialized expertise in compliance services for DoD contractors can assist your organization in assessing current compliance and conducting any remediation work necessary to achieve DFARS/NIST SP 800-171 compliance. Contact us today for personal help with all your assessment and compliance needs.

DFARS security compliance requirements must be applied by both contractors and subcontractors, following guidance in National Institute of Standards and Technology’s (NIST) Special Publication 800-171 “Protecting Controlled Unclassified Information in Non-Federal Information Systems and Organizations.” Fortunately, DFARS compliance requirements are a set of standard security controls based on best practices that are already in use for information security, so compliance is not a daunting challenge. The DFARS Cybersecurity Rule Subpart 204.73 (revised December 28, 2017), “Safeguarding Covered Defense Information and Cyber Incident Reporting” can be found here: http://www.acq.osd.mil/dpap/dars/dfars/html/current/204_73.htm

Hardie said she appreciated BEGAP’s straightforward application process, especially compared to other agencies like the USDA.

“Even though it’s not a significant amount of money, when you’re doing this as something that you enjoy and that you love, and that really brings something to your family and the community, it’s helpful to have something keep you going when it’s just a small operation,” said Laura Hardie. “And you know, if it's not sustainable, we're not going to keep doing it. And so having a little bit of support to help us get it going again is really helpful.”

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A contractor’s responsibility under DFARS standards in the event of a cybersecurity incident that compromises information integrity or an information system is rapid reporting, which requires reporting the incident to DoD within 72 hours. To determine the extent of a potential compromise, an assessment is required that at a minimum must include a list of compromised systems, technical data and users, and a list of any other systems that might have been compromised. The assessment must also provide a thorough system review and provide methods for preventing any future incidents.

For manufacturers who provide products within supply chains for the DoD, NIST provides a self-assessment handbook, NIST Handbook 162, “NIST MEP Cybersecurity Self-Assessment Handbook for Assessing NIST SP 800-171 Security Requirements in Response to DFARS Compliance Cybersecurity Requirements.” The handbook provides a step-by-step guide for assessing a small manufacturer’s information systems against the security requirements in NIST SP 800-171.

“If something’s not clear, [you] should just explain it in the spots that allow for that. If we don’t have enough space, just upload a document with your story because we realize we’re not going to capture every single permutation,” Goldstein said.

RSI Security is the nation’s premier cybersecurity and compliance provider dedicated to helping organizations achieve risk-management success. We work with some of the world’s leading companies, institutions, and governments to ensure the safety of their information and their compliance with applicable regulations.

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After a revision, BEGAP in 2023 provided for 30% of net uncovered damage, with a maximum payout of $500,000 in damage for each property affected by flooding. The agency defines net uncovered damage as the remaining need after subtracting insurance proceeds and other grants or donations.

RSI Security is the nation's premier cybersecurity and compliance provider dedicated to helping organizations achieve risk-management success.

This time around, the state Agency for Commerce and Community Development’s Department of Economic Development, which runs the program, is setting the limit at 30% up to $100,000 of uncovered damage. Unlike last time, 40% of funds will be reserved for agricultural and silvicultural businesses until Nov. 15, and a portion of the two funds will be reserved for Black-, Indigenous- and people-of-color-owned businesses.

The company wasn’t eligible for FEMA aid, and did not apply for Small Business Administration loans. It also didn’t have flood insurance, which wasn’t helpful the last time the facility suffered catastrophic flooding, in 2011, Benson said.

Achieving DFARS/NIST SP 800-171 compliance is not a one-time solution. It is a continuous process of assessment, monitoring and improvement to ensure your organization maintains compliance with constantly evolving security requirements, and thus eligibility as a DoD contractor. An MSSP like RSI Security with specialized expertise in compliance services for DoD contractors required to meet DFARS compliance and monitored cybersecurity will assist your organization in performing the required assessment and audit, and conducting any remediation work necessary to achieve DFARS/NIST SP 800-171 compliance. Contact us today for personal help with all your needs for compliance advisory services.

Welcome to RSI Security’s blog! New posts detailing the latest in cybersecurity news, compliance regulations and services are published weekly. Be sure to subscribe and check back often so you can stay up to date on current trends and happenings. RSI Security is the nation's premier cybersecurity and compliance provider dedicated to helping organizations achieve risk-management success.

Self-attestation is currently considered sufficient to prove DFARS compliance, so a third-party audit is not a requirement. A well-documented SSP based on NIST 800-171 which connects controls to their implementation, or a compensating control, is sufficient to resolve any questions that should arise. The technical evaluation of a government contract proposal can use the SSP and may also request a Plan of Action and Milestones (POA&M) to document compliance as part of consideration for a DoD contract award.

The Business Emergency Gap Assistance Program, or BEGAP, granted $19.4 million to Vermont businesses and nonprofits last year to repair physical damage to their property. The new, revamped version of BEGAP has $7 million for businesses damaged by the 2024 floods as well as $5 million for businesses with remaining damage from last year’s flooding.

Welcome to RSI Security’s blog! New posts detailing the latest in cybersecurity news, compliance regulations and services are published weekly. Be sure to subscribe and check back often so you can stay up to date on current trends and happenings.

The DFARS Clause 252.204-7012 regulatory framework requires defense contractors to specifically document how the following requirement components are met:

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“They will make you jump up and down, do jumping jacks, stand on your head, spin around 10 times and then run a mile before you can get your funding, and by the time you’re done, you’re so worn out that you wonder why you did it,” Hardie said.

BEGAP, on the other hand, is just a form with some document uploads. If the process were more arduous, Hardie said, she would not have applied for such a small amount of money. As it stands, she said she’ll probably apply to cover damage sustained in this year’s July flood, with an eye on being more resilient to future floods.

RSI Security is the nation’s premier cybersecurity and compliance provider dedicated to helping organizations achieve risk-management success. We work with some of the world’s leading companies, institution and governments to ensure the safety of their information and their compliance with applicable regulation. We also are a security and compliance software ISV and stay at the forefront of innovative tools to save assessment time, increase compliance and provide additional safeguard assurance. With a unique blend of software based automation and managed services, RSI Security can assist all sizes of organizations in managing IT governance, risk management and compliance efforts (GRC). RSI Security is an Approved Scanning Vendor (ASV) and Qualified Security Assessor (QSA).

RSI Security has been helping everyone from corporations to individual contractors pass DFARS compliance for 10 years. We are one of the leaders in digital security and consulting. We are well versed in all aspects of security compliance and will have you DFARS compliant in a timely manner. We also have a positive relationship with the DoD that can ease some of the hurdles that come such a complicated endeavor.

All Vermont businesses with proof of property damage costs not covered by insurance were and are eligible for grants under BEGAP. (Community service nonprofits who received a public assistance grant from the Federal Emergency Management Agency are ineligible.)