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