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CUI Program Toolkit

CUI or FCI? Decide It Per Contract, Defend It in an Audit

A step-by-step decision worksheet plus a determination-memo template for every contract you have to classify.

The hardest call is which flowdown clauses actually apply

You have a contract on your desk and you are not sure whether the information is Federal Contract Information or Controlled Unclassified Information, which clauses flow down to your subcontractors, or which safeguarding standard they have to meet. Misclassifying FCI as CUI, or the reverse, creates compliance gaps that auditors and C3PAOs will find during assessments. The two categories carry distinct safeguarding obligations, and the analysis has to be documented per contract, not assumed at the program level.

Get instant access to the toolkit

Ten ready-to-adapt templates, not a sales deck. Pull the artifact you need, assign an owner, and build an audit-ready record per contract.
Step 1, Identify what the contract involves
  • Answer six yes/no questions about government-generated data, DFARS 252.204-7012, FAR 52.204-21, and the DD Form 254
  • Record the source document beside each answer
Step 2, Apply the CUI vs FCI distinction
  • Determine whether a law, regulation, or government-wide policy specifically authorizes the information to be controlled
  • If yes, it is CUI under a registered category
Step 3, Confirm flowdown obligations
  • Map obligations to subcontractors across 7012, 7020, 7021, and FAR 52.204-21
  • Mapped by whether CUI or FCI applies
Step 4, Produce the determination memo
  • One page for the contract file
  • Records classification result, sources, safeguarding standard, and who signed off
Ten ready-to-adapt artifacts across the full CUI lifecycle
Four-step CUI vs FCI decision worksheet, worked in order
Clause-trigger logic for DFARS 252.204-7012 vs FAR 52.204-21
Flowdown obligation table (7012, 7020, 7021, 52.204-21) by CUI vs FCI
One-page determination memo template for the contract file
CUI Category Reference Table aligned to the NARA CUI Registry, with authorizing instruments per category
Retention guidance: life of the contract plus three years as a recommended baseline
Full lifecycle artifacts: classify, inventory, mark, handle, share, train, destroy, and crosswalk

Make the call with a record behind it

Resolve each classification at the first affirmative answer and attach a signed, dated memo to the contract file instead of relying on an undocumented assumption.

Know exactly what flows down to each subcontractor

Confirm whether a subcontractor must meet NIST SP 800-171 under 7012 or only the 15 basic safeguarding requirements under FAR 52.204-21, before you grant access.

Hand assessors evidence, not drafts

Produce determination records with a version number, effective date, and approval signature so they qualify as audit evidence for CMMC Level 2 and DCSA review.

Extend from one call to a whole program

Move from classification into inventory, marking, handling, sharing, training, destruction, and SSP crosswalk templates without assembling evidence from scratch.

Mapped to a named regulatory hook

Every artifact maps to a named hook under 32 CFR Part 2002 or a NIST SP 800-171 Rev 2 control family.

Citations throughout

32 CFR 2002.14, 2002.16, 2002.20, 2002.30, and 2002.32, DFARS 252.204-7012/7020/7021, FAR 52.204-21, and the NARA CUI Registry at cui.gov.

CUI Category Reference Table

Aligned to the NARA CUI Registry with the authorizing instrument listed per category.

800-171 / 800-172 crosswalk

Artifact-to-control crosswalk citing specific requirement identifiers such as 3.1.3, 3.8.3, and 3.13.8.

Destruction guidance with real specs

Aligned to NIST SP 800-88 Rev. 1 and DIN 66399 Level P-4 cross-cut shredding.

Per contract. The analysis must be completed for each contract and attached to that contract file, not assumed at the program level, because clause triggers and data types vary from award to award.

Classify the contract. Defend the call.

Download the CUI Program Toolkit, ten ready-to-adapt templates, not a sales deck.