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Title The New Baseline: Self-Attesting to Cyber Hygiene
Category Business --> Business Services
Meta Keywords SAM.gov registration
Owner Federal Contracting Center
Description

The days of "trust but don't verify" regarding cybersecurity are over. The Department of Defense is rolling out the Cybersecurity Maturity Model Certification (CMMC). While Level 2 and 3 require third-party assessments, Level 1—which applies to almost every contractor handling Federal Contract Information (FCI)—allows for self-attestation. This means the contractor must legally certify that they meet basic cyber hygiene standards (like using passwords and antivirus software).

This score is reported into the Supplier Performance Risk System (SPRS). Crucially, access to SPRS is controlled via your SAM registration service credentials. If you cannot log into the entity management system, you cannot post your cyber score. If you have no score in the system, contracting officers are instructed not to award you the contract. The entity registration has become the gatekeeper for cyber compliance. It is no longer just about banking info; it is about proving you are not a security risk to the DoD network.

Linking the PIEE Account

The Procurement Integrated Enterprise Environment (PIEE) is the DoD’s main contracting platform. To get a PIEE account, you must have an active CAGE code from your entity registration. The "Contractor Administrator" (CAM) in PIEE must be validated against the "Electronic Business Point of Contact" in the federal profile. If these names don't match, or if the email addresses differ, the account setup fails. This breaks the chain of command for managing cyber scores and contract awards. Synchronisation of personnel data is vital.

Representation Regarding Covered Telecommunications

Section 889 of the NDAA prohibits the government from buying equipment from certain Chinese telecommunications companies (like Huawei or ZTE). Every federal contractor must represent—within their entity profile—whether they use this banned equipment. This is a "Yes/No" question with massive legal implications. A false "No" is a False Claim. During the registration process, contractors must conduct an internal audit of their IT hardware to ensure they can truthfully answer this question. It turns the registration update into an IT inventory audit.

Cyber Insurance and Liability

While not a direct field in the database, the "Corporate Information" section establishes the legal entity that holds the cyber insurance policy. If a breach occurs and government data is lost, the liability falls on the registered entity. Ensuring that the entity structure in the database matches the entity on the cyber insurance policy ensures that coverage applies. If there is a disconnect—e.g., the contract is in a subsidiary's name but the insurance is in the parent's name—the insurer might deny the claim, leaving the contractor exposed to federal damages.

Subcontractor Flow-Down Verification

Prime contractors are responsible for their supply chain’s cyber hygiene. Primes are increasingly using the public entity search to verify that their subs exist and are in good standing before sharing sensitive data. If a sub’s registration is expired or flagged, the Prime cannot securely share the drawings or specs needed to bid. Maintaining an active profile is the signal to the Prime that you are a "cyber-ready" partner who won't compromise their CMMC compliance.

Conclusion

Cybersecurity is now a "go/no-go" criterion for federal contracts. The administrative mechanism for proving this compliance is tightly woven into the entity registration process. By treating the registration as a component of your security posture, you ensure that your digital doors remain open for government business.

Call to Action

Align your cybersecurity compliance with your federal profile by professionalising your registration today.