Sum IT Up: CMMC News Roundup

By Summit 7Technology Government

Sum IT Up: CMMC News Roundup episodes

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
August 27 DoD Paused CMMC Over Costs. Get Ready to Pay More.
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/
25 min
August 20 Are There Really Too Few CMMC Assessors?
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
23 min
August 13 DoD Already Told Contractors What’s Coming After CMMC
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/

28 min
August 06 The DoD's "Basic" Cybersecurity Isn't Basic at All
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/
25 min

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