The SF XXX: What Federal Contractors Can Learn from the DD-254

Federal contractors familiar with the DD-254, the Department of Defense form used for managing classified information, may find it helpful in understanding the proposed SF XXX under the recently introduced rule “Federal Acquisition Regulation: Controlled Unclassified Information” (FAR Case 2017-016). While the SF XXX focuses on Controlled Unclassified Information (CUI) rather than classified information, the purpose and function of the form bear similarities to the DD-254, making it an excellent reference point for contractors navigating these new requirements.

What is the SF XXX?

The SF XXX is a placeholder name for a forthcoming document aimed at standardizing how CUI is handled in federal contracts. This form will specify:

• What CUI is involved in a contract
• How that CUI must be safeguarded
• How contractors should mark, store, and transmit CUI

It is part of a broader effort to bring consistency and clarity to the protection of CUI across all federal agencies. Contractors will be required to reference and comply with the SF XXX in contracts involving CUI, just as they currently do with the DD-254 in classified contracts.

How Does the SF XXX Compare to the DD-254?

While the SF XXX is still being developed, it is helpful to draw on the DD-254’s structure and purpose to anticipate what the SF XXX might entail.

| Aspect | DD-254 (Classified Information) | SF XXX (Controlled Unclassified Information) | | ---------------------- | ------------------------------------------------------------------- | -------------------------------------------------------------- | something

| ------ | ------ | | abc | test |

| Scope | Focuses on national security information (e.g., Secret, Top Secret).| Focuses on unclassified but sensitive information. | | Examples of Use | Used in defense contracts involving national security information. | Expected to apply broadly across all federal contracts with CUI.| | Key Requirements | Outlines security measures per National Industrial Security Program Operating Manual (NISPOM).| Will specify safeguarding per NIST SP 800-171 standards. |

The key takeaway: If you’ve worked with DD-254 forms before, you can approach the SF XXX with a similar mindset. Both forms provide contractors with specific instructions for protecting sensitive information based on the type of data and the associated risks.

Using the DD-254 to Understand the SF XXX

1. Role in a Contract
   Just as the DD-254 is included in defense contracts to outline requirements for classified information, the SF XXX will be included in contracts involving CUI. It will serve as a “guidebook” for contractors, detailing what specific protections are necessary.

2. Breaking Down Requirements
   The DD-254 specifies who can access classified information, what markings to use, and how to secure it. Similarly, the SF XXX will define CUI categories, marking instructions, and safeguarding procedures based on NIST SP 800-171.

3. Flow-Down Obligations
   Contractors who flow classified information to subcontractors must provide a DD-254. With the SF XXX, prime contractors will need to share the form with subcontractors who handle CUI and ensure they comply with its requirements.

4. Accountability and Compliance
   Both forms establish accountability. The DD-254 makes clear who is responsible for protecting classified information. The SF XXX will do the same for CUI, ensuring everyone in the supply chain understands their obligations.

Preparing for the SF XXX

Federal contractors can draw on their experience with DD-254 forms to prepare for the SF XXX:

1. Familiarize Yourself with NIST SP 800-171
   While the DD-254 relies on the NISPOM, the SF XXX will hinge on the National Institute of Standards and Technology (NIST) guidelines, particularly SP 800-171 Revision 2. Start reviewing these requirements now to avoid surprises later.

2. Establish Documentation Processes
   Just as the DD-254 requires documentation of classified handling procedures, the SF XXX will likely require evidence of how CUI is marked, stored, and transmitted. Prepare to keep detailed records.

3. Update Subcontractor Vetting Procedures
   The SF XXX will place responsibility on prime contractors to ensure subcontractor compliance, just as the DD-254 does. Review your current subcontractor oversight processes to ensure they are robust enough to handle CUI requirements.

4. Train Your Team
   Both the DD-254 and SF XXX emphasize training. Develop or update training programs focused on CUI safeguarding and marking to prepare employees for the SF XXX’s eventual rollout.

Gray Beard Cybersecurity: Your Partner in CUI Compliance

At Gray Beard Cybersecurity, we’ve worked extensively with federal contractors to implement compliance frameworks for classified and unclassified information. Drawing on the parallels between the DD-254 and the SF XXX, we can help you:

• Understand the nuances of CUI safeguarding requirements.
• Implement policies and processes that meet NIST SP 800-171 standards.
• Train your workforce on CUI compliance to avoid costly missteps.

By leveraging our expertise, you can approach the SF XXX with confidence, knowing that your organization is well-prepared to handle these new requirements.

Conclusion

The SF XXX may still be under development, but contractors can look to the DD-254 as a model for understanding its purpose and preparing for its implementation. Both forms play a crucial role in safeguarding sensitive information, whether classified or controlled unclassified. By proactively aligning your practices with expected SF XXX requirements, you can maintain compliance and build stronger relationships with federal clients.

For more information on the proposed SF XXX, visit the Federal Register or contact Gray Beard Cybersecurity for tailored guidance.