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 DFARS 7019 and 7020 have been replaced by DFARS clause 252.240-7997.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