Sum IT Up: CMMC News Roundup

By Summit 7Technology Government

Sum IT Up: CMMC News Roundup episodes

November 05 FAR CUI Could Undo Years of Progress on CMMC Scoping
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
23 min
October 29 The FAR CUI Rule Could Put Contractors on Rev. 3 Before DoD Does
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
39 min
October 22 GAO's CMMC Decision Could Change How DoD Awards Contracts
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/
29 min
October 15 The DoD's CMMC Review Has a Scoping Problem
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
33 min
October 08 CIRCIA Final Rule Is Coming: What Defense Contractors Need to Know
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
21 min
October 01 Congress Changed Its CMMC Small Business Bill at the Last Minute
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
19 min
September 24 DoD Said 60 Days. So Where Is the CMMC Report?
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/
15 min
September 17 The Honeywell Cyber Whistleblower Tells Her Story
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
44 min
September 10 DoD Paused CMMC. Here Are 5 Cyber Rules Coming Anyway.
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
36 min
September 03 Defense Contractors Have a rev. 2 vs rev.3 Problem (again)
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
26 min

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