CMMC

Subscribe to CMMC via RSS

“I felt a great disturbance in the Force, as if millions of voices suddenly cried out in terror and were suddenly silenced.”

When Obi-Wan Kenobi says this in Star Wars: Episode IV – A New Hope, he senses that something profound just changed in the galaxy. A powerful presence has vanished. The balance of power shifting in ways that will ripple far beyond the immediate moment. As Yoda later describes the Force: “Life creates it, makes it grow. Its energy surrounds us, binds us.” In this way, artificial intelligence (AI) is beginning to play a role for the US Defense Industrial Base (DIB) not unlike the Force itself—quietly enhancing the capabilities of engineers, analysts, and compliance professionals across thousands of organizations supporting national defense programs.

So what could happen if a major AI player suddenly disappears from the board?Continue Reading Orbiting A.I.-deraan? A Disturbance in the Force for the Defense Industrial Base

The DoD has finally crossed the CMMC finish line, but for contractors, the race is just beginning. With the Final Rule effective Nov. 10, award eligibility will hinge on a “current” CMMC status in SPRS, backed by annual affirmations and strict compliance. The next two months are critical for getting race-ready. In this Featured Comment…

In Part I of this series we introduced readers to what Controlled Unclassified Information (CUI) is understood to consist of under the CUI Program at 32 CFR pt. 2002, differentiating and safeguarding CUI, CUI Program Authority and Control, and CUI policy as promulgated under the U.S. Department of Defense CUI Program. (See 66 GC ¶…

The U.S. Department of Defense’s Cybersecurity Maturity Model Certification (CMMC) Program will become operational at some point in fiscal year 2025. In October, the DOD issued a Final Rule to address evolving cybersecurity requirements and cyber threats while defining the security controls that DOD intends defense contractors and subcontractors to implement. The program will require…

Over the course of the past few years, gallons of ink have been spilled addressing the seemingly ever-pending US Department of Defense’s (DoD) Cybersecurity Maturity Model Certification (CMMC) Program. After keeping us waiting for years, it finally arrived when, on October 15, 2024, DoD published its Final Rule to establish the CMMC Program. See 89 Fed. Reg. 83092 (Oct. 15, 2024). Effective December 16, 2024, the Rule will require certain defense contractors to have implemented security measures to achieve a particular CMMC level necessary to safeguard Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) as a condition of contract award. Codified at 34 C.F.R. Part 170, the CMMC Program will be augmented by a separate proposed acquisition rule to add a new 48 C.F.R. Part 204, amending the Defense Federal Acquisition Regulation Supplement (DFARS) to address procurement considerations related to the CMMC Program, including allowing DoD to require a specific CMMC level in a solicitation or contract. See 89 Fed. Reg. 66327 (Aug. 15, 2024) or our analyses here and here. The date when that DFARS clause will become final is still unclear, but most suspect it will be soon.Continue Reading A Standard on Many Levels: A Look at CMMC 2.0 in Final

Sequels are rarely better than the films that precede them, and yet, sometimes a story is just too compelling to be limited to just one film. At the tail end of a summer full of Hollywood sequels, the Department of Defense (DoD) released a long-gestating sequel of its own. On August 15, 2024, DoD published a Proposed Rule that would revise the DoD Federal Acquisition Regulation Supplement (DFARS) to implement Cybersecurity Maturity Model Certification (CMMC) 2.0 into DoD contracts in the near(ish) future. This follows a December 2023 Proposed Rule, discussed here, establishing the CMMC 2.0 requirements in broad strokes. In this latest Proposed Rule, DoD proposes several changes to the DFARS that would do the following:Continue Reading CMMC and DFARS 252.204-7021—Is the Sequel Better than the Original?

On December 26, 2023, the Department of Defense (“DoD”) belatedly gifted defense contractors and subcontractors a Proposed Rule on the Cybersecurity Maturity Model Certification (“CMMC”) Program. DoD also released eight CMMC guidance documents, providing interested parties a one-two combo of what to expect under the Program. The Proposed Rule has already received over 100 comments. With commenting open until February 26, 2024, will DoD proceed with a final rule, or is the Proposed Rule a Groundhog Day scenario with DoD further delaying final implementation of the CMMC Program?Continue Reading DoD’s Proposed CMMC Rule: Groundhog Day… or a Final Rule in the Works?

The Cybersecurity Maturity Model Certification version 2.0 (CMMC 2.0) is here! Like a song you’ve heard before, the revised standards are a throwback but no less significant change to the standards that have evolved over the past three and a half years. McCarter & English Government Contracts and Global Trade co-leaders Alex Major and Franklin Turner detail the changes coming to federal contractors in a Feature Comment for Thomson Reuters’ The Government Contractor. Set against the recent Beatles documentary, the comment examines the impact of the Department of Defense’s most recent effort while detailing what contractors need to do before its new standards go into effect.
Continue Reading Get Back: DOD Retreats While Revealing Plans for CMMC 2.0

There’s an often mistranslated Taoist adage that counsels “A journey of a thousand miles begins with a single step.” So it is presently with the Department of Defense’s (DoD’s) Cybersecurity Maturity Model Certification (CMMC), which continues its cybersecurity journey with the recently released update of standard CMMC .6.
Continue Reading Cybersecurity Maturity Model Certification (CMMC) Version .6: Another Step on the Department of Defense’s Long and Winding Cybersecurity Road