Overview
FAR 4.2302 mandates that executive agencies identify and share relevant supply chain risk information with the Federal Acquisition Security Council (FASC) when a substantial risk is identified regarding a source or product. It establishes a formal communication bridge between procurement activities and government-wide security risk management.
Key Rules
- Mandatory Reporting: Executive agencies must share information with the FASC if there is a "reasonable basis" to conclude that a "substantial supply chain risk" exists.
- Scope of Risk: Reporting requirements apply to both "sources" (specific vendors/contractors) and "covered articles" (specific information technology items or services).
- Internal Coordination: The Contracting Officer (CO) is required to collaborate with the program office or requiring activity to identify and share information discovered during the procurement process.
- Regulatory Alignment: These requirements are designed to satisfy the information-sharing standards set forth in 41 CFR 201–1.201.
Practical Implications
- Enhanced Due Diligence: Government contractors can expect more rigorous vetting during the procurement process, as agencies are now formally tasked with identifying and reporting potential vulnerabilities to a centralized federal council.
- Inter-Agency Communication: A risk identified by one agency during a specific procurement may lead to government-wide visibility through the FASC, potentially impacting a contractor's ability to secure work across the entire federal marketplace.