Comment on FR Doc # 2026-12559
Sintavia, LLCSupportBusiness
Summary: Sintavia, LLC, a defense subcontractor, supports the FAR Council's effort to standardize CUI requirements but argues that the proposed rule should be revised to make the flowdown of Standard Form XXX (SF XXX) mandatory rather than discretionary. They contend that making it mandatory ensures subcontractors receive the necessary information to identify CUI categories, apply correct safeguarding controls, and meet incident reporting deadlines.
Sintavia, LLC, a defense subcontractor and Tier 1/2 supplier operating under the National Industrial Security Program, submits this comment to urge the FAR Council to revise FAR 52.240-7(g) to require mandatory flowdown of the SF XXX (or a subcontract-specific derivative containing equivalent information) to all subcontractors who will handle CUI in the performance of a federal contract. As currently proposed, SF XXX flowdown is discretionary, which will predictably result in primes omitting it from subcontracts. This leaves subcontractors without the information necessary to identify applicable CUI categories, implement the correct safeguarding controls, apply the correct NIST SP 800-171 Rev. 3 organizationally-defined parameters, and accurately route incident reports within the rule's 72-hour reporting window. Mandatory flowdown of the SF XXX's informational content is consistent with the rule's stated uniformity goals and with the existing mandatory flowdown framework established by DFARS 252.204-7012.
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