Sum IT Up: CMMC News Roundup

The DoD Inspector General is raising concerns about CUI marking again and the numbers don't add up. In 2023, the IG found that 48% of reviewed CUI documents lack proper markings. Yet the DoD CUI Program website reports only 9% were unmarked that same year. So which is it? In this episode we break down the latest DoD IG management advisory, where the recommendations fall short, and why the CUI program and the CMMC program (although closely related) are owned by different offices that can't fix each other's problems. For defense contractors, this isn't academic. CMMC enforcement depends on the integrity of the CUI program. If CUI marking is inconsistent, compliance risk increases downstream. Summit 7 Live: https://www.summit7.us/s7live 2026 IG Report: https://www.dodig.mil/reports.html/Article/4397146/management-advisory-dod-policy-and-training-on-dissemination-controls-for-contr/ 2023 IG Report: https://www.dodig.mil/reports.html/Article/3413433/audit-of-the-dods-implementation-and-oversight-of-the-controlled-unclassified-i/

CMMC is a condition of contract award and many defense contractors are waiting until they see CMMC requirements in a solicitation to get started. But the department of defense wants the period between solicitation and award to be as short as possible. This week we crunch the numbers on 1,070 upcoming Navy contracts to see what a realistic timeline ought to look like. Summit 7 Live: https://www.summit7.us/s7live PALT Pod 2024: https://youtu.be/NZs4f5voyrg?si=S-xarOpYyiSG00Bs NAVAIR Forecast: https://www.navair.navy.mil/LRAE

The largest change to DFARS cybersecurity requirements other than CMMC took place on February 1st, 2026, and nobody knew it happened. DFARS 7019 and 7020 have been replaced by DFARS clause 252.240-7997. Basic self-assessments have been eliminated. FAR 52.204-21 has a new number. And none of this went through rulemaking. This week we're diving deep into the mysterious world of class deviations and what they mean for defense contractors moving forward. RFO Website: https://www.acquisition.gov/far-overhaul DFARS RFO Deviations: https://www.acq.osd.mil/dpap/dars/dfars_far_overhaul_class_deviations.html CMMC class deviation: https://youtu.be/vC4IJ2JQ5NU?si=B8I9DII4ZEbQ2dNx 7012 class deviation: https://youtu.be/voziZRAMvv4?si=HxIkpUWnxyergEUQ

After a brief hiatus, the Cyber AB has gathered the CMMC Ecosystem to deliver its monthly update. On this week's show, we breakdown the information distributed on this month's meeting that you need to know. Things like: • Who is the new DoW CIO? • Pending shutdown and CMMC Impacts • Ecosystem Growth and Certification updates • Does this show count for CPEs? And so much more...Tune in to find out! ISACA Webinar - CMMC: Requirements, Roles, and Professional Credentials: https://store.isaca.org/s/community-event?id=a33VQ000001otC1YAI DAU CMMC microlearning: https://www.dau.edu/acquipedia?combine=cmmc&title=C&field_functional_area_target_id=All&field_topic_area_target_id=All ISACA CMMC Page: https://www.isaca.org/credentialing/cmmc

Defense contractors aren't the only ones who need to implement NIST cybersecurity requirements for CUI. The big question has always been whether other agencies would require proof of implementation via the CMMC program. The GSA just revised their process for assessing nonfederal systems handling controlled unclassified information and it's way closer to NIST's Risk Management Framework than CMMC. CIO-IT Security-21-112r1 (PDF): https://www.gsa.gov/system/files/Protecting-Controlled-Unclassified-Information-%28CUI%29-in-Nonfederal-Systems-and-Organizations-Process-%5BCIO-IT-Security-21-112-Rev-1%5D.pdf Summit 7 Live San Diego: https://www.summit7.us/s7live

This week we sit down with Supply Chain Director Bo Birdwell to discuss Elbit America's latest open letter to suppliers regarding CMMC. Elbit's letter doesn't mince words: CMMC is here and the time to act is now. Bo not only walks us through the perspective of a major prime contractor on cost, timelines, outsourced services, CMMC Level 3, and more – he also drops a ton of helpful tips for current and prospective suppliers. Elbit Supplier Page: https://www.elbitamerica.com/suppliers#cyber MSP Collective: https://www.mspcollective.org/ Bo Birdwell: https://www.linkedin.com/in/bobirdwell/

The defense department has updated the CMMC FAQs for the second time in 3 months. In lieu of rulemaking updates the CMMC FAQs are the best place for updated guidance. This week we're exploring DoD's answers regarding everything from encryption to enclaves to VDI endpoints. CMMC FAQs: https://dodcio.defense.gov/CMMC/

Another year another set of eerily accurate predictions about defense cybersecurity requirements and the CMMC program. Like usual we got most of our 2025 predictions correct. For 2026 we're getting specific with False Claims settlements, CMMC 3.0, FAR CUI, and more! FCA episode: https://youtu.be/tPA-ALjW1Hk?si=KgPUAo4VqqmX3mNF DoD IG report: https://www.youtube.com/watch?v=RNafaUlgBGo Golden Dome: https://youtu.be/y88JqZdJsj0?si=eGpIm1jqKRYpW4n3

Defense Logistics Agency suppliers got a special Christmas gift: detailed estimates of CMMC requirements by DLA supply class! The Defense Department buys a lot of different products and services and the estimates make it clear that different types of contractors will experience CMMC requirements in very different ways. If only we could get every agency and mega prime to put out info like this. Episode Links: DLA SMB Website: https://www.dla.mil/Small-Business/Resource-Center/Cybersecurity-Resources/ What DLA Buys: https://www.dla.mil/Small-Business/Getting-Started/What-DLA-Buys/ Supply Classes: https://www.dau.edu/acquipedia-article/supply-classes

Another defense contractor is paying six figure fines after settling with the Department of Justice for allegedly failing to comply with DFARS clause 252.204-7012. The kicker: their own employee blew the noncompliance whistle and got a cut of penalty money. This is the fifth such settlement in 2025 and the DOJ is crystal clear that the don't discriminate just because a company is small. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo Memo: https://dodcio.defense.gov/cmmc/Resources-Documentation/ Swiss Automation: https://www.justice.gov/opa/pr/illinois-precision-machining-company-agrees-pay-421234-resolve-alleged-false-claims-act MORSECORP: https://www.youtube.com/watch?v=ZnePk6jaezA Raytheon: https://www.justice.gov/opa/pr/raytheon-companies-and-nightwing-group-pay-84m-resolve-false-claims-act-allegations-relating Aero Turbine: https://www.youtube.com/watch?v=hFEEVGXv_00 GTRC: https://www.justice.gov/opa/pr/georgia-tech-research-corporation-agrees-pay-875000-resolve-civil-cyber-fraud-litigation DFARS 7012: https://youtu.be/cy4e28YAkXU?si=MqGKGNAHTPyvj-DI

A recent webinar from the US Army Corps of Engineers told suppliers that if they only handle paper CUI, then CMMC requirements don't apply to them. That's a significant concession to industry on par with COTS exemption and POAMs. But is this USACE flexing their discretion or are they setting up a conflict by setting policy around CMMC applicability? Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo

Register for CMMC Industry Week: https://www.summit7.us/industry-week Since the 48 CFR CMMC final rule was published in September 2025 we've seen supplier notices from Lockheed, RTX, BAE, HII, and many others. Most recently, Northrop Grumman recently published a supplier announcement titled “CMMC 2.0 is Final – Are You Ready?”. The big takeaway: don't expect CMMC waivers from your prime customers because they can't grant them to you. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo DFARS 7012: https://youtu.be/cy4e28YAkXU?si=KvezY7Vu7zXf9qYZ 32 CFR Final rule: https://www.federalregister.gov/documents/2024/10/15/2024-22905/cybersecurity-maturity-model-certification-cmmc-program 48 CFR Final rule: https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of January Memo (PDF): https://dodprocurementtoolbox.com/uploads/DOPSR_Cleared_OSD_Memo_CMMC_Implementation_Policy_d26075de0f.pdf

While everyone has been focused on the start of CMMC phase 1, many contractors are discovering that DFARS clause 252.204-7020 has been lurking in their contracts since 2020. DoD reserves the right to show up at any time and audit compliance with DFARS clause 252.204-7012. This week we're diving into everything that DIBCAC will be asking for when they show up on your doorstep. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo DIBCAC intake forms: https://www.dcma.mil/DIBCAC/ DFARS 252.204-7012: https://youtu.be/cy4e28YAkXU?si=x4tmDKcCc44dLnJE DFARS 252.204-7020: https://youtu.be/D4JLkfvB-Ws?si=6_yyMYrU7DVoxoBt

The final Cyber AB TH of 2025 took place this week which means it's time for the team to unpack all the important information you need to know. On this week's show, Jason and Joy sit down for one one last time in 2025 as we discuss things like: •The final ecosystem update of 2025 •The biggest highlights of 2025 •DO I have to affirm my C3PAO assessment score? •What the AB expects for 2026 Tune in as we close out this year of Cyber AB Town Halls with a little fun! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

As of November 10th, 2025, CMMC is now a condition of award for new defense contracts. “Phase 1” of the CMMC rollout will last until November 10th, 2026. This week we discuss seven predictions we have for the new normal. Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo 32 CFR 170.3(e): https://www.ecfr.gov/current/title-32/part-170#p-170.3(e) DFARS 7012: https://youtu.be/cy4e28YAkXU?si=yC_wKI42JNxIHKME Phase 1 Blog: https://www.summit7.us/blog/cmmc-begins-today

After four years of rulemaking here we are at the last podcast before the official start of CMMC phase 1. What better way to usher in the new normal of CMMC than a quick refresher on how and why CMMC became a thing in the first place? Nothing helps contextualize the CMMC program like remembering how resistant the DoD has been to third party verification until they were left with no other choice.

On this week's spine-tingling episode of the show, Jason and Joy sit down unwrap the October Cyber AB Town Hall like a bag of pillowcase full of candy. With less than two weeks until the November 10th launch, this marks the final town hall before the CMMC becomes a fully operational reality. Tune in as we mix up a cauldron of all the important information you need to know to assure no tricks as you pursue your CMMC bag of treats… no costumes required! Summit 7 Live: https://www.summit7.us/S7Live Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo AB Town Halls: https://cyberab.org/News-Events/Town-Halls/Details/march-town-hall

CMMC officially goes into effect on November 10th, 2025, at which point all new DoD solicitations and contracts will include at least CMMC Level 1 status requirements. While the government shutdown might affect the pace of new contract awards, it doesn't change anything about the effective date of CMMC specifically. This week we're looking at the trickle of contract notices that are letting people know CMMC is very real and will absolutely be required (including level 2). Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo NAVSEA (Level 2): https://sam.gov/workspace/contract/opp/0a92f866231546828b3fd11cf1146a8a/view USSOCOM (Level 1): https://sam.gov/workspace/contract/opp/eb3d38dd00e845579212f724b6dedd37/view USACE (Level 2): https://sam.gov/workspace/contract/opp/e0a817b5b7c74c319ebaa2df9cd3d637/view

The Senate has passed their version of the FY26 NDAA and they want annual contractor performance measurements to focus exclusively on “negative performance events”. Per the Senate Armed Services Committee that includes failing to meet cyber requirements, failing to flow down requirements to subcontractors, and submission of false claims (cyber). Add this one to the growing pile of evidence that the government really, really wants contractors to take cybersecurity seriously. Pathfinder 101: https://www.summit7.us/pathfinder Pathfinder Demo: https://youtu.be/JiDTCchfCa0?si=JJFplxSfvkaRVhRo Memo: https://dodcio.defense.gov/cmmc/Resources-Documentation/ Senate NDAA: https://www.congress.gov/bill/119th-congress/senate-bill/2296/text

Watch full webinar here: https://www.summit7.us/webinars/cmmc-phase-1-the-final-rule-is-here The start of CMMC phase 1 is just around the corner. Starting on November 10th, 2025, DoD contracting officers will begin inserting CMMC status requirements in new solicitations and contracts. We recently held a webinar on the CMMC final rule to get people up to speed so this week we're bringing you our key takeaways. If you want all the details, the webinar is available on demand (registration link is in the show notes). Find out where you are on your CMMC journey here: https://www.summit7.us/pathfinder