DFARS compliance checklist to win and maintain DoD contracts for small businesses and consultants — GovScout
Meta description:
DFARS rules shape small business work with DoD. This guide shows which DFARS rules to meet, how to set up your policies, and how to stay ready for each contract.
TL;DR
• Find the exact DFARS rules that touch your current or planned DoD contracts.
• Set up a simple DFARS checklist for cybersecurity, supply chain, cost, and report tasks.
• Set controls (like NIST SP 800‑171 for CUI) and save your records for audits or proposals.
• Pull data from SAM.gov and USAspending.gov to sort chances by your current compliance.
• Track DFARS steps in your pipeline and use tools like GovScout to search SAM.gov faster, save & track opportunities, and build AI proposal outlines that meet DFARS.
Why DFARS Compliance Matters Now
When you work with the DoD, DFARS rules are not a choice.
DFARS adds rules on top of the FAR.
These rules guide how you protect data, control your suppliers, and report events.
Recent checks have tightened rules on:
• Cybersecurity (NIST SP 800‑171, CMMC)
• Counterfeit parts
• Sourcing matters
If you fail to meet these rules, you risk:
• Losing bids because of weak controls
• Contract termination
• Bad marks on past work that affect new bids
For small businesses and consultants, clear compliance builds trust and helps you work on larger projects.
Step‑by‑step: Building and Using a DFARS Compliance Checklist
Step 1: Find the DFARS Rules That Apply to You
Not all DFARS rules touch every contract.
Your task is to read:
- The solicitation (RFP/RFQ/RFI)
- The final contract or task order
Pull your latest or target DoD contract documents.
Where to look:
• Visit SAM.gov for live or past RFPs/RFQs.
• Use the contract text from the contracting officer or award documents.
• Visit USAspending.gov for an overview.
Checklist: Rule Identification
For each contract:
- Go to Section I – Contract Clauses.
- Look for clauses that start with DFARS or start with 252.
- Write each rule in a simple table.
Example table:
Field: Example
Contract: W91QF4‑24‑R‑0001
DFARS Rule: 252.204‑7012
Title: Safeguarding Defense Data
Type: Cybersecurity / Reporting
Flow‑Down: Yes/No
Status: Planned, Underway, or Done
Group rules by type:
• Cyber and information protection
• Counterfeit parts and supply chain
• Domestic sourcing and special metal rules
• Cost and business systems
• Reporting events
DFARS matters in a bid when the evaluator sees that you meet each rule with written proof.
Step 2: Focus on Four Main DFARS Areas
2.1 Cybersecurity & Controlled Unclassified Information (CUI)
Key DFARS numbers here include:
• 252.204‑7012 – How you shield defense data
• 252.204‑7019/7020 – How you assess NIST SP 800‑171
• 252.204‑7021 – CMMC steps
What you do:
• Follow NIST SP 800‑171 for systems with CUI.
• Do a self-check and post a score on SPRS.
• Build a clear plan to report a cyber incident.
• Get ready for CMMC if a bid asks for it.
Basic actions:
• Write a System Security Plan (SSP) that shows your steps.
• Make a Plan of Action & Milestones (POA&M) for any missing parts.
• Save and update your SPRS score.
• Create an incident response plan with clear contacts.
2.2 Supply Chain & Counterfeit Parts
Key DFARS rules include:
• 252.246‑7007/7008 – Checking for fake parts
• 252.225‑7000 series – Buy American and trade rules
Action list:
• Keep a list of approved suppliers with checks.
• Save certificates, lot numbers, and test reports for parts.
• Check where items come from when rules require.
• Write DFARS text to pass requirements to your subs.
2.3 Cost, Pricing & Business Systems
For cost-based or larger contracts, you face:
• 252.242‑7005 – Business system rules
• FAR and DFARS cost guides
At a small scale:
• Split direct and indirect costs clearly.
• Save labor records, time logs, and bills.
• Know which costs are allowed.
See FAR Part 31 and DFARS texts for details.
2.4 Reporting Tasks
Common reporting rules ask you to report:
• Cyber events (per 252.204‑7012)
• Fake or suspect parts
• Labor law issues when cited
• Pricing or cost errors
Make a clear report plan:
• List trigger events
• Note who gets the report (by role)
• State timelines and formats
Step 3: Create Your DFARS Compliance Matrix and Record Library
Once you list your rules, turn that list into a set of tracks.
3.1 DFARS Compliance Matrix
Extend the table to add:
• A clear rule description
• The process you follow
• The role in charge
• Where proof is kept
• The review interval (e.g., quarterly, yearly)
Sample row:
Clause: 252.204‑7012
Requirement: Keep CUI safe with NIST 800‑171
Process: SSP; quarterly log check; incident plan
Owner: IT Manager
Proof: SSP version 3.1; POA&M; incident plan; logs
Status: Active
3.2 Record Library
Build a folder setup (using SharePoint, Teams, etc.) like:
• DFARS/01 Cyber
– SSP folder
– POA&M folder
– SPRS score records
– Incident response files
• DFARS/02 Supply Chain
– Approved Supplier List
– Fake part checks
– Origin records
• DFARS/03 Cost & Accounting
– Guidelines for indirect cost
– Timekeeping records
• DFARS/04 Reporting
– Incident logs
– Reports to contracting officer
This record setup helps you show clear written proof when someone asks, “Are you DFARS ready?”
Step 4: Match DFARS Compliance to Your Bidding Process
Each bid need not require full DFARS coverage.
Fit your work to the bid.
4.1 Use Market Data to Pick Contracts
Check:
• SAM.gov (for live bids) to read rule needs as they show up.
• USAspending.gov (to see past awards and types).
Watch for:
• Which NAICS and PSC codes match your work
• Whether bids need heavy DFARS cyber checks
• The type of contract (firm‑fixed, cost-type, IDIQ)
Tools like GovScout help you:
• Search SAM.gov faster by filtering for DoD, your NAICS, and words like “DFARS 252.204‑7012” or “CUI.”
• See past award data to know who asks for tight DFARS before you send a bid.
4.2 Bid or Skip by DFARS Readiness
Include DFARS questions in your bid checklist:
• Does the bid list DFARS 252.204‑7012 and require NIST 800‑171 with a SPRS score?
• Do you work with CUI? If not, can you plan to do so?
• Do sourcing rules affect your supply chain?
• Are you set for CMMC Level 2 if needed?
If you are not ready, think about:
• Working as a subcontractor for a prime that meets the rules.
• Choosing bids that do not need CUI or strict parts checks until you upgrade your controls.
Step 5: Build DFARS in Your Proposals and Daily Work
5.1 In the Proposal Phase
In your technical and management sections, mention DFARS clearly.
Place details in Sections L and M if the rules matter.
Write in your:
• Technical plan: "Our systems that work with CUI follow NIST SP 800‑171 as set in DFARS 252.204‑7012. We keep an SSP and a current SPRS score."
• Management plan: explain your DFARS checklist, review process, and how you check on your subs.
• Past work: list projects with strong DFARS marks (no incidents, quick reports, good performance scores).
GovScout’s AI proposal outlines can shape bid answers that match the DFARS points. Add your details and proof.
5.2 In Daily Work and Contract Performance
After a win:
- Read the final contract to note any DFARS changes.
- Check that your subs share DFARS rules.
- Set a regular check (e.g., every three months) to:
– Review DFARS rules in active contracts
– Update your SSP, POA&M, and files
– Ensure your suppliers keep up with sourcing and parts rules
Data Snapshot: DFARS and DoD Small Business
Good, straight data help you plan:
• DFARS texts:
– Read the DFARS on Acquisition.gov.
• DoD small business work:
– Check reports on business.defense.gov.
• Award counts by NAICS/PSC/agency:
– Use USAspending.gov.
• Cyber trends:
– See info at acq.osd.mil/cmmc.
When you build your business case, pull:
• 3–5 years of USAspending.gov data for your NAICS and DoD work.
• Up-to-date DoD scorecards.
• The latest DFARS text from Acquisition.gov.
Evaluator Insight
Contracting officers and evaluators care first about clear risk cuts.
A firm that shows:
• Which DFARS rules apply
• How it meets each rule
• How it checks on its subs
seems less risky than a firm with vague words and no proof.
Compliance Watch
Watch out for these red flags:
• Claiming NIST 800‑171 without an SSP or SPRS record.
• Ignoring DFARS 252.204‑7012 in a bid that includes it.
• Missing flow‑down rules to subs where needed.
• Using parts from outside when rules demand local sources.
• Missing a quick report for a cyber or parts issue.
Mini Case Example: A Small SDVOSB IT Firm Meets DFARS
Scenario:
A 12‑person SDVOSB IT firm aims to move from low‑risk work to DoD app development that may need CUI.
How they act:
-
Market Scan with GovScout
– On GovScout, they search SAM.gov faster for:
• Agency: "Department of the Army"
• NAICS: 541512/541513
• Words: "DFARS 252.204‑7012", "CUI", "NIST 800‑171"
– They spot 10 open bids and 20 past awards. -
Clause Extraction and Matrix
– For 5 good bids, they get the RFPs and list DFARS rules in a table.
– They note most ask for DFARS 252.204‑7012 and 252.204‑7019/7020; none ask for CMMC 7021 yet. -
Cyber Uplift
– They hire a part-time CISO to draft an SSP and POA&M for NIST 800‑171.
– In 60 days, they finish an assessment and post a SPRS score.
– They keep all files in a DFARS/Cyber folder and tie them to their table. -
Proposal Integration with GovScout
– For one Army bid, they use GovScout AI proposal outlines to shape a bid section on "Information Security and DFARS Compliance."
– They add specifics: the SSP, incident plan, and SPRS score. -
Pipeline Tracking
– They use GovScout save & track opportunities and tag each bid as:
• "DFARS Cyber Required"
• "CUI Likely"
– This helps them target bids they can win with strong DFARS work.
Outcome:
Within 9 months, they win a small Army order that needs CUI work. At kickoff, the COR asks for cyber files; they send the SSP and proof in one day. This act builds trust in their work.
Common Pitfalls and How to Avoid Them
-
Treating DFARS as a one‑time task
– Many finish an SSP once and then forget it.
– Set annual or semi‑annual checks of your DFARS table and records. -
Using generic cybersecurity text in bids
– Many bids contain boilerplate that does not tie to the DFARS rules.
– Match each claim to a DFARS rule with a clear pointer to your files. -
Ignoring subcontractor tasks
– Some assume DFARS only touches the prime contractor.
– Put DFARS clauses in your sub agreements and check their cyber steps if they use CUI. -
Misaligning DFARS scope with data flow
– Some over‑scope or under‑scope systems that handle CUI.
– Map your data flow to show where government data and CUI live and then set NIST 800‑171 steps. -
Waiting on final CMMC steps before acting
– Some wait on clear CMMC rules before they add cyber strength.
– Build your NIST 800‑171 base now; CMMC Level 2 will formalize what DFARS 252.204‑7012 asks.
Quick FAQ on DFARS Compliance
-
What is DFARS compliance for a small business?
It means you meet the DoD rules added via DFARS. This often means you follow steps for NIST 800‑171/CUI, control your supply chain, meet sourcing rules, and keep good records. -
How do I know which DFARS rules touch my contract?
Read Section I – Contract Clauses in your RFP and final contract. Any rule marked DFARS or that starts with 252.xxx-7xxx applies. Use Acquisition.gov for the full text and note them in a table. -
Is NIST SP 800‑171 needed for all DoD contracts?
No. You need it only if your contract lists DFARS 252.204‑7012 and you move, store, or process CUI. Some bids may not include CUI and thus not need this rule. -
What is the link between DFARS and CMMC?
DFARS 252.204‑7012 needs NIST 800‑171 for CUI. CMMC builds on this with third‑party reviews and levels. When DFARS 252.204‑7021 shows up, you must meet the specified CMMC level. -
Can a subcontractor face DFARS rules?
Yes. Many DFARS steps, especially in cyber and sourcing, pass to subcontractors. Your prime asks you to show the same clear steps if you handle CUI or key parts.
Call to Action: Make DFARS Part of Your Pipeline with GovScout
You do not need a full team to handle DFARS.
You need clear checks on:
• Which rules show in your work
• A living table with your steps and proof
• Bids that speak simple and match DFARS and risk cuts
GovScout can help you:
• Search SAM.gov faster to spot bids heavy on DFARS and filter by DoD, NAICS, and words like "DFARS 252.204‑7012" or "CUI."
• Save & track opportunities and mark them by DFARS steps so your pipeline shows your work.
• Build responses with AI proposal outlines that match technical steps to DFARS points and Section L/M needs.
Next Steps Checklist
[ ] Get 3–5 current or target DoD documents and list each DFARS rule.
[ ] Build a basic DFARS table with rules, steps, owners, and records.
[ ] For DFARS 252.204‑7012 contracts, write an SSP and POA&M for NIST 800‑171 and post your SPRS score.
[ ] Add DFARS text in your sub agreement templates.
[ ] Use GovScout to match your pipeline with your current DFARS steps and plan upgrades as needed.
Author bio:
Written by GovScout (Cartisien Interactive). The team has delivered over 100 government and enterprise projects. CAGE 5GG89. Editorial note:
This text has been checked against primary sources for accuracy.
About GovScout
GovScout helps SMBs and consultants win more public-sector work: search SAM.gov fast, save & track opportunities, and draft AI-assisted proposal outlines grounded in the RFP.
Contact: hello@govscout.io
Editorial Standards
We cite primary sources (SAM.gov, USAspending, FAR, SBA, GSA). Posts are reviewed for compliance accuracy. We don’t fabricate figures. If a rule changes, we update.
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