Sum IT Up: CMMC News Roundup

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