Advertise on podcast: Sum IT Up: CMMC News Roundup

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

Speak With Our Team: https://summit7.us/contact DoD already solved the problem of CMMC requiring NIST SP 800-171 Rev. 2 while other cybersecurity requirements moved to Rev. 3. Then it suspended CMMC Phase 2. Now the FAR CUI rule is approaching with Rev. 3, CMMC remains tied to Rev. 2, and defense contractors could once again find themselves juggling different cybersecurity baselines for the same data. We break down how DoD got here, the options for fixing it, and why CMMC reform could make the problem even more complicated. Crisis Averted (2024): https://youtu.be/voziZRAMvv4?si=LLlm4VUmBR-G3hno Phase 2 Suspension: https://www.war.gov/News/Releases/Release/Article/4542329/forging-the-arsenal-of-freedom-department-of-war-suspends-cmmc-phase-ii-require/ Unified Agenda: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=0790-AM01 DoD CIO (Feb 2026): https://www.linkedin.com/posts/dow-cio_ot-cyber-cybersecurity-activity-7433151492745879552-b_It

Speak With Our Team: https://summit7.us/contact DoD suspended CMMC Phase 2 amid concerns about cost and burden on small businesses. Now it is hoping those same contractors will embrace cybersecurity practices that are broader, more complex, and potentially more expensive than their existing requirements. We break down DoD's remarkable explanation for its “Brilliant at the Basics” campaign, the push toward phishing-resistant MFA and broader operational technology security, and NDIA survey data showing what defense contractors already spend implementing and maintaining NIST SP 800-171 and how many lack the resources to manage those requirements. Will the result of the CMMC Review be a more expensive cybersecurity baseline with less assurance that it is actually being implemented? Register for Summit 7 Live: https://www.summit7.us/s7live National Defense Magazine: https://www.nationaldefensemagazine.org/articles/2026/8/25/new-cyber-campaign-contradicts-cmmc-pause-expert-says Brilliant at the Basics: https://dowcio.war.gov/BrilliantBasics/ Phishing resistant MFA: https://youtu.be/7aMxKNNlOxo?si=zX7Iri6uV0uVBJLJ DIBCAC Top 10: https://summit7.us/blog/tools-to-take-on-nist-800-171 2019 DoD IG Report: https://www.dodig.mil/reports.html/Article/1916036/audit-of-protection-of-dod-controlled-unclassified-information-on-contractor-ow/

Speak With Our Team: https://summit7.us/contact Everyone says CMMC has an assessor shortage. The July numbers tell a different story. We break down the latest CMMC ecosystem data, DoD's own demand estimates, and why the real bottleneck is contractor readiness, not assessment capacity. Register for Summit 7 Live: https://www.summit7.us/s7live Cyber AB Town Hall: https://cyberab.org/News-Events/Town-Hall DoD Capacity Estimates: https://www.federalregister.gov/d/2024-22905/p-1240

Speak With Our Team: https://summit7.us/contact DoD is reconsidering CMMC assessments and talking about reducing costs for defense contractors. But months before the Phase 2 suspension, the DoD CIO published a strategy saying the Defense Industrial Base will migrate to post-quantum cryptography, CMMC will be updated to include PQC requirements, and “costs will be incurred.” We break down why quantum computing threatens modern encryption, the federal government's 2030/2031 migration timeline, what DoD has already said about CMMC, and what the transition could eventually cost defense contractors. Register for Summit 7 Live: https://www.summit7.us/s7live DoD PQC Strategy: https://dowcio.war.gov/Portals/0/Documents/Library/DoW-PQC-Strategy.pdf NFO Controls: https://youtu.be/YEQd--RIUkU?si=iQpR2sZY7taAbi9k NIST PQC 101: https://www.nist.gov/cybersecurity-and-privacy/what-post-quantum-cryptography Congress (2022): https://www.congress.gov/bill/117th-congress/house-bill/7535 PQC Report (2024): https://bidenwhitehouse.archives.gov/wp-content/uploads/2024/07/REF_PQC-Report_FINAL_Send.pdf PQC Executive Order: https://www.whitehouse.gov/presidential-actions/2026/06/securing-the-nation-against-advanced-cryptographic-attacks/

The DoD says it's reducing cybersecurity burden on the Defense Industrial Base. At the same time, the first recommendation in the new "Brilliant at the Basics" campaign calls for phishing-resistant multi-factor authentication, a capability that goes well beyond today's NIST SP 800-171 requirements. In this episode we break down replay resistance vs. phishing resistance, explain why they are different security properties, and explore where phishing-resistant authentication fits into the NIST standards lifecycle. We also ask a simple question: If this is now considered "basic," why isn't it in the NIST control catalog yet? 800-63: https://csrc.nist.gov/pubs/sp/800/63/b/4/final Brilliant at the Basics: https://dowcio.war.gov/BrilliantBasics/