Is a DPAS rating considered CUI?

Started by Former_DCAA · Aug 5, 2021 · 9 replies

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    Former_DCAA

    Aug 5, 2021 · 4y ago

    Original post

    I read the DPAS regulations and can't seem to find an answer. Is a DPAS rating on a contract (or subcontract/purchase order) considered CUI? Does a foreign national need to be restricted from seeing it?

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    Neil Roberts

    Aug 5, 2021 · 4y ago

    You may start your research with DOD by reviewing https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/520048p.PDF

  3. V

    Vern Edwards

    Aug 5, 2021 · 4y ago

    Neil Roberts said:

    You may start your research with DOD by reviewing https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/520048p.PDF

    Instead of that, which doesn't mention DPAS, start with DoDD 4400.01E, Defense Production Act Programs.

    https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodd/440001p.pdf?ver=2018-11-09-111906-183

    Then look at DoD 4400.1-M, Department Of Defense Priorities And Allocations Manual.

    https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodm/440001m.pdf?ver=2018-12-11-110803-913

    To the best of my knowledge, DPAS ratings are not controlled unclassified information. But check around.

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    C Culham

    Aug 5, 2021 · 4y ago

    Not saying a deep dive will answer the question but here is another possible reference to check around in.   As I understand it does provide help regarding DFARS 252.204.7102 and NIST SP 800-171......

    http://dodprocurementtoolbox.com/ at the Cybersecurity tab

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    Don Mansfield

    Aug 5, 2021 · 4y ago

    Former_DCAA said:

    I read the DPAS regulations and can't seem to find an answer. Is a DPAS rating on a contract (or subcontract/purchase order) considered CUI? Does a foreign national need to be restricted from seeing it?

    Does the document that has the DPAS information have CUI markings?

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    formerfed

    Aug 6, 2021 · 4y ago

    The rating is evident on solicitations.  Why would orders with the same rating be marked CUI?

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    Vern Edwards

    Aug 6, 2021 · 4y ago

    Former_DCAA said:

    Is a DPAS rating on a contract (or subcontract/purchase order) considered CUI? Does a foreign national need to be restricted from seeing it?

    No, to both questions.

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    here_2_help

    Aug 6, 2021 · 4y ago

    Back in the day I used to work on secret and above programs. Many, many aspects of those contracts were classified. But nobody ever worried about the DPAS rating. Which is to say, it was neither classified nor was it controlled.

    Short answer: I agree with Mr. Edwards' position on the matter.

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    Neil Roberts

    Aug 6, 2021 · 4y ago

    The DOD CUI Registry lists the laws, regulations and government-wide policies requiring DOD safeguarding of each CUI category. See, https://www.dodcui.mil/Portals/109/Documents/CUI Registry/CUI Registry PDF 18 MAY 21.pdf?ver=oY8Aux88iwaicCIJbabl8A%3d%3d. There is a Procurement and Acquisition category. I reviewed it and did not find any inclusion of DPAS related ratings (FAR 52.211-15 , FAR 11.6, 15 CFR 700).

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    Former_DCAA

    Aug 10, 2021 · 4y ago

    Thank you all. It does not appear to be CUI.

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