2022 Year End CMMC Program Status Update

2022 saw a lot of changes to the CMMC program, and even to the government’s approach to supply chain cybersecurity. In this post, we summarize some of the key DoD-related changes in an effort to help contractors understand what they will likely encounter in 2023.

The $0 CMMC Level 2 Compliance Fallacy

Government representatives have stated that complying with CMMC 2.0 Level 2 shouldn’t cost contractors or the government anything, because contractors have been attesting to the government that they are doing these things for years. This article explores why this is correct only for a small minority (17 out of 110) of the controls in CMMC 2.0 Level 2.

Can DCMA’s DIBCAC Teams Handle the CMMC C3PAO Authorization Workload?

CMMC depends upon Authorized C3PAOs. DCMA’s DIBCAC team plays a crucial role in the C3PAO authorization process. However, the DIBCAC teams’ calendars were already full prior to CMMC. In this article, co-authored with Kyle Lai, Carter Schoenberg, Tony Buenger, and Derek White, we discuss whether the current system is likely to clear the CMMC C3PAO backlog in a timely manner and explore a few alternatives.

Coming in September: Final CMMC DFARS Rule and More

Changes to the FAR/DFARS imposed by the recent Executive Order on Increasing our Nation’s Cybersecurity and the expected publication of the Final Rule for CMMC are now both expected in September, although the exact dates are still unknown. With all the expected changes, October promises to be a very busy time for defense contractors!