The DoD's CMMC Review Has a Scoping Problem

DoD suspended CMMC Phase 2, but defense contractors are still responsible for the cybersecurity requirements in their contracts. ILC Dover just agreed to a $13 million False Claims Act settlement involving nearly seven years of alleged cybersecurity noncompliance, missing SSPs, unsupported assessments, and a whistleblower who was the company's former Director of Cybersecurity. We dive into DOJ's allegations, the consequences for contractors with inaccurate or unsupported SPRS scores, and why CMMC's suspension doesn't suspend your contractual obligations or FCA liability.  ILC Settlement: https://www.justice.gov/opa/pr/defense-and-aerospace-contractors-ilc-dover-and-ilc-astrospace-agree-pay-13m-resolve  LOGZONE Settlement: https://youtu.be/T5wJYnQzWws?si=N_lzZE5BP_HU5cKB

Defense contractors spent years resolving NIST SP 800-171 scoping questions through CMMC. Now the proposed FAR CUI rule could bring those same problems to federal contractors across the government. The problem? FAR CUI doesn't incorporate CMMC's detailed asset categories and assessment scoping guidance. This week we examine what NIST actually requires, what CMMC added, and why personal devices, specialized equipment, security protection assets, and inconsistent agency interpretations could create new compliance costs and uncertainty. FAR CUI Rule: https://www.federalregister.gov/documents/2026/06/23/2026-12559/federal-acquisition-regulation-revolutionary-federal-acquisition-regulation-overhaul-parts-1-2-4-33 FAR CUI phased roll-out: https://youtu.be/wZuQ9rjk8ps?si=vJilw7ARVwpJoAom

CMMC’s phased rollout doesn’t determine when your other federal contracts could require NIST SP 800-171 Revision 3. The FAR CUI proposed rule contains no express implementation grace period and that could leave contractors managing two baselines on the same system. This week we examine DoD’s implementation extensions, explain what CMMC’s phases actually do, and discuss why contractors shouldn’t build their readiness plans around another extension. 2013 Rule: https://www.federalregister.gov/documents/2013/11/18/2013-27313/defense-federal-acquisition-regulation-supplement-safeguarding-unclassified-controlled-technical 2015 Rule: https://www.regulations.gov/document/DARS-2015-0039-0026 2016 Rule: https://www.federalregister.gov/documents/2016/10/21/2016-25315/defense-federal-acquisition-regulation-supplement-network-penetration-reporting-and-contracting-for 2020 Rule (CMMC 1.0): https://www.federalregister.gov/documents/2020/09/29/2020-21123/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of 2024 Rule (CMMC 2.0): https://www.federalregister.gov/documents/2024/10/15/2024-22905/cybersecurity-maturity-model-certification-cmmc-program 2025 Rule: https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of FAR CUI Proposed: https://www.federalregister.gov/documents/2026/06/23/2026-12559/federal-acquisition-regulation-revolutionary-federal-acquisition-regulation-overhaul-parts-1-2-4-33 DoD Rev 2 vs Rev 3: https://youtu.be/iOKvkxcIivA?si=TeZZKmDvW7lgpqBz

Can DoD reward contractors for CMMC certification without making it mandatory? In a protest involving the Army's $50 billion MAPS contract vehicle, GAO upheld bonus evaluation points for companies that had obtained or were pursuing third-party CMMC certification. But DoD's subsequent suspension of CMMC Phase 2 raises an important question about how far agencies can go. Government contracts attorney Eric Crusius joins us to examine the decision, what GAO actually ruled, and whether CMMC certification could become a competitive advantage even when it isn't a condition for award. GAO Protest: https://www.gao.gov/products/b-424433.14%2Cb-424433.16%2Cb-424433.17%2Cb-424433.20%2Cb-424433.21%2Cb-424433.25 Follow Eric: https://www.linkedin.com/in/ericcrusius/

The DoD says Brilliant at the Basics will reduce cybersecurity compliance costs and administrative burden. But its new guidance leaves a critical question unanswered: What's actually in scope? We examine all 10 IT security practices, compare their language with NIST SP 800-171 and CMMC's existing scoping rules, and explain why eliminating administrative complexity could actually make compliance more expensive for defense contractors. Brilliant at the Basics: https://dowcio.war.gov/BrilliantBasics/ Phishing Resistant MFA: https://youtu.be/7aMxKNNlOxo?si=wJ8XA97UB26oZJPJ CMMC Scoping: https://www.ecfr.gov/current/title-32/section-170.19 

AUSA Supply Chain Cyber Readiness Preview: https://tinyurl.com/AUSAsupplychain The CIRCIA final rule has entered regulatory review, putting publication potentially just months away. For defense contractors, one major question remains unresolved: will CISA accept existing DFARS 252.204-7012 cyber incident reports, or will contractors have to report the same incident twice? We break down why the two 72-hour reporting requirements are far less similar than they appear, what “substantially similar” actually means, and why CIRCIA could create an entirely new reporting obligation for the defense industrial base. CIRCIA Proposed Rule: https://www.federalregister.gov/documents/2024/04/04/2024-06526/cyber-incident-reporting-for-critical-infrastructure-act-circia-reporting-requirements CIRCIA Pod 1: https://youtu.be/bvwnNSpDZgU?si=bJjZjrhzHJQxqYKH CIRCIA Pod 2: https://youtu.be/ngYSaO5fg5Y?si=vk-9dTSqT1HrNakq CIRCIA Pod 3: https://youtu.be/kUdhl5QfziU?si=kEnHdlWD8D17w0Pf

Managed Service Provider (MSP) Grader: https://summit7.us/mspgrader Congress has introduced new legislation aimed at helping small businesses navigate CMMC, promising clearer guidance, lower costs, and better federal assistance. But then the CMMC provisions changed before the bill even left committee. We break down what the Cybersecurity for Small Businesses Act actually requires, what it doesn't give the SBA authority to do, how the amended version differs from the original, and whether it would meaningfully change anything for defense contractors struggling with CMMC. Press Release: https://wied.house.gov/media/press-releases/rep-wied-introduces-bill-strengthen-cybersecurity-and-reduce-costs-small Bill tracker: https://www.govtrack.us/congress/bills/119/hr10238

CMMC L2 Suspended, Learn What This Means For You: https://summit7.us/blog/cmmc-phase-2-suspended-with-60-day-review-what-happens-next DoD said it was conducting a 60-day review of CMMC. More than 60 days later, contractors are still waiting for answers. We break down the conflicting CMMC timelines, the additional 15-day window described by DoD CIO Kirsten Davies, what the suspension actually means today, and when we might realistically see the CMMC Reform Task Force recommendations. July 13th memo: https://dodcio.defense.gov/Portals/0/Documents/Library/CMMC-ReformMemo.pdf Davies (DefenseScoop): https://defensescoop.com/2026/07/17/pentagon-task-force-to-review-cmmc-hits-the-ground-running/

Rachel Tenney was working in counterintelligence and insider risk at Honeywell when she raised cybersecurity concerns involving sensitive defense technology. Years later, her False Claims Act case ended in a $2 million settlement. In this episode, Rachel joins us to tell the story from her perspective: SolarWinds, raising concerns inside Honeywell, becoming a relator, the years-long government investigation, and what security practitioners, CISOs and defense contractors can learn from her experience. Settlement: https://www.justice.gov/opa/pr/honeywell-aerospace-inc-agrees-pay-over-2m-settle-false-claims-act-allegations-failing  Solarwinds (GAO): https://www.gao.gov/products/gao-22-104746

Speak With Our Team: https://summit7.us/contact CMMC may be on hold, but cybersecurity rulemaking isn't. We break down five major requirements defense contractors need to watch, including the FAR CUI rule, CIRCIA, DFARS 252.204-7012 updates, CMMC 3.0, and post-quantum cryptography. FAR CUI Proposed Rule: https://www.federalregister.gov/d/2026-12559/p-116 FAR CUI pod: https://youtu.be/l7BHnTdD9yM?si=7LQJ9LDup4LoJaCr CIRCIA: https://www.regulations.gov/docket/CISA-2022-0010 CIRCIA pod: https://youtu.be/bvwnNSpDZgU?si=PvyO3JaXJJFWJFRi CMMC 3.0: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=0790-AM01 DFARS 7012: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=0750-AM24 PQC: https://youtu.be/6zqaXGhP7SE?si=jefs2Pbjm_sPknnV