Joint AAU/COGR Letter on FAR FISMA Rule

Abstract

This October 18, 2012 letter from the Association af American Universities (AAU) and the Council on Governmental Relations (COGR) sent to the U.S. General Services Administration (GSA) is a response to the proposed amendment to the Federal Acquisition Regulation (FAR) to hold contractors responsible "for the basic safeguarding of contractor information systems that contain information provided by or generated for the Government (other than public information)" (see https://www.federalregister.gov/articles/2012/08/24/2012-20881/federal-acquisition-regulation-basic-safeguarding-of-contractor-information-systems#h-4).

AAU and COGR had previously commented on the DFARS (Case 2008-D028, “Safeguarding Unclassified Information”). In this letter, they express concern "about the broad potential scope of the information subject to these requirements."