1. Commercial Items. Proposed FAR and DFARS rule issued to change the definition of a commercial item to implement Section 836 of the 2019 NDAA and how commercial item determinations are made. NDIA published a good summary of the proposed regulation with links.
  2. DCAA Audits - Expressly Unallowable Costs. DCAA updated its guidance on identifying expressly unallowable costs to align the DCAA practices with recent court cases and limits the scope to only those costs that are “expressly unallowable”.
  3. CyberSecurity and Supply Chain Management. Defense Contract Management Agency (DCMA) revised its Contractor Purchasing System Review (CPSR) Guidebook on June 14, 2019, with the most significant updates to Appendix 24, Supply Chain Management Process, to further address cybersecurity concerns. The update requires DCMA to ask i) how contractors have determined subcontractors have adequate systems, ii) broadens application from first-tier subcontractors to all subcontractors, and iii) explicitly states that a review will focus on “Covered Defense Information”.
  4. Receipts-Based Size Standards. SBA issued an interim rule to increase the receipts-based size standards with inflationary adjustment on July 18, 2019. Comments to the rule are due September 16, 2019. The revisions may result in some government contractors shifting from "other than small" to "small,". Companies will need to reevaluate their size status and update their SAM profile if applicable.
  5. EEO-1 Filing Requirements Update and Deadlines. Companies with more than 100 employees shall report data to the Equal Employment Opportunity Commission (EEOC). An overview article is available here. May 31, 2019 — Employers must report the number of employees by job category, race, ethnicity and sex for calendar year 2018. September 30, 2019 — Employers must report wages paid and total hours worked for all employees by race, ethnicity and sex for calendar years 2017 and 2018.
  6. Dentons provides a monthly summary of all new legislative and regulatory updates:

New NDIA National Regulatory Tracker -

Comments – Contact Karri ([email protected]) if you or your company is interested in submitting comments on any of the above. If there is sufficient interest, we can assess submitting comments as a chapter.

  1. NDIA Events: Lunch with Col Teehan and Mr. Dickey to discuss the future architecture of the US military space – Aug 23 at the Hotel Elegante in Colorado Springs. Click here for more information and to register
  2. OTHER EVENTS - Community Calendar of Events - a fairly comprehensive list of various CO events is now posted. It is updated regularly so I invite you to bookmark it and visit regularly.
  3. Lockheed Martin will host a free Supply Chain Cybersecurity Academy on Aug 20th from 8-12 at 12999 Deer Creek Canyon Road, Littleton CO 80127. Targeted audience includes small businesses, both current and potentially new Lockheed Martin subcontractors. Training will include areas such as: Legislation and Policy, Safeguarding Covered Defense Information, Cyber Incident Reporting, and Best Practices. Sign up at here.
  4. Free NDIA Export Webinar – August 22. NDIA is proud to announce a new initiative “ITAR Compliant: Industry Tools to Effectively Operate Within the International Market”. The first webinar, “Exporting By or For the U.S. Government: ITAR 126.4 Exemption Expansion and Benefits to Exporters”, will walk you through the expanded 126.4 Exemption language.
  5. SAVE THE DATE – On Sep 12, the Department of Commerce (DOC) Boulder Laboratories, the DOC Office of Space Commerce, and the University of Colorado Boulder (CU) are presenting a one-day workshop to bring together industry, academia, and federal government organizations to identify key technology and measurement barriers to deploying and safely operating commercial space technology.

  1. Protecting company information submitted to the government with a contract is now easier to protect from public disclosure under the Freedom of Information Act.
  2. Doing Business Internationally - Companies face potentially significant legal, regulatory, financial and reputational risks when engaging with overseas third parties. NDIA published a great article on the risks with tips to overcome.
  3. New DOD Cybersecurity Maturity Model Certification Creates New Cyber Enforcement Mechanism
  4. Senator Cory Gardner (R-CO) Urges Secretary of Defense to Establish U.S. Space Command Headquarters in Colorado. Washington, D.C.  Full letter available here.

List of other Training Resources (free and not) available here .

  1. Catalyst Space Accelerator - Applications and Sponsorships. The fourth cohort is gearing up and will be focused on Space-Based ISR. All small businesses with an innovative, space-based ISR technology should apply to the program by 8 August. (Accelerator dates will be Sept 9 – Nov 22, 2019.) There are also other ways for industry and members of the community to become involved with the Catalyst Space Accelerator. For example, commercial sherpas adopt a cohort company throughout the Accelerator, as well as subject matter experts and mentors, who provide guidance to the entire group through short-term engagements. Finally, Sponsorships are an excellent way to get exposure while showing your support for the Accelerator providing opportunities to be included on print and promotional materials, host events, and mentioned alongside the Accelerator in audiences of high-level public and private decision makers. Click here for more information and to submit an application.
  2. Job Posting. Immediate need for Senior Acquisition SME in Colorado Springs area with 20 years Acquisition and 10 years of Space related experience with TS. Pays well, $200,000 plus a year. Selected individual would need to sign a one-year commitment. Interested candidates contact: Jim Monopoli; email: [email protected]; phone: (781) 271-9757.

As always, feel free to send any updates that may be of interest to the membership to Karri L. Palmetier ( [email protected] ).
Colorado Springs, Co