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CMMC 2.0: DoD Unveils Sweeping Changes Streamlining CMMC Requirements

By Christopher Hebdon, Michael G. Gruden, CIPP/G & Kate Growley on November 5, 2021
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The Department of Defense (DoD) recently announced significant changes to its Cybersecurity Maturity Model Certification (CMMC) program intended to simplify the requirements and ease the compliance burden on contractors.  Unlike its predecessor, the new CMMC 2.0 moves to three compliance levels rather than five; aligns the required security controls (known as practices) with National Institute of Standards and Technology (NIST) Special Publications (SP) 800-171 and 800-172; and eliminates entirely previously required maturity processes.  The changes also include a shift to self-assessments for all but contractors supporting the most sensitive programs, as well as the return of Plans of Action and Milestones (POAMs) to demonstrate compliance and achieve certification.

The new requirements are summarized below:

  • CMMC Level 1, Foundational – Contractors must implement the 17 controls from NIST SP 800-171 enumerated in FAR 52.204-21 and submit an annual self-assessment to the DoD through the Supplier Performance Risk System (SPRS).
  • CMMC Level 2, Advanced – Contractors must implement the 110 controls in NIST SP 800-171 and submit an annual self-assessment or, if required to handle (as yet undefined) critical national security information, a triennial independent assessment performed by a CMMC Third Party Assessment Organization (C3PAO).
  • CMMC Level 3, Expert – Contractors must implement the 110 controls in NIST SP 800-171 and a subset of controls from NIST SP 800-172 before undergoing a triennial government-led assessment.  The DoD, however, is still in the process of developing the requirements for this Level.

CMMC 2.0 will be implemented through the rulemaking process, which the DoD estimates could take anywhere from nine months to two years.  Thereafter, the DoD will begin to incorporate CMMC 2.0 requirements into contracts.  In the meantime, the DoD has suspended its CMMC pilot program and will not approve the inclusion of CMMC requirements in any forthcoming DoD solicitations.

Photo of Christopher Hebdon Christopher Hebdon
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Photo of Michael G. Gruden, CIPP/G Michael G. Gruden, CIPP/G

Michael G. Gruden is a counsel in Crowell & Moring’s Washington, D.C. office, where he is a member of the firm’s Government Contracts and Privacy and Cybersecurity groups. He possesses real-world experience in the areas of federal procurement and data security, having worked…

Michael G. Gruden is a counsel in Crowell & Moring’s Washington, D.C. office, where he is a member of the firm’s Government Contracts and Privacy and Cybersecurity groups. He possesses real-world experience in the areas of federal procurement and data security, having worked as a Contracting Officer at both the U.S. Department of Defense (DoD) and the U.S. Department of Homeland Security (DHS) in the Information Technology, Research & Development, and Security sectors for nearly 15 years. Michael is a Certified Information Privacy Professional with a U.S. government concentration (CIPP/G). He is also a Registered Practitioner under the Cybersecurity Maturity Model Certification (CMMC) framework. Michael serves as vice-chair for the ABA Science & Technology Section’s Homeland Security Committee.

Michael’s legal practice covers a wide range of counseling and litigation engagements at the intersection of government contracts and cybersecurity. His government contracts endeavors include supply chain security counseling, contract disputes with federal entities, suspension and debarment proceedings, mandatory disclosures to the government, prime-subcontractor disputes, and False Claims Act investigations. His privacy and cybersecurity practice includes cybersecurity compliance reviews, risk assessments, data breaches, incident response, and regulatory investigations.

Read more about Michael G. Gruden, CIPP/GEmail
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Photo of Kate Growley Kate Growley

Businesses around the globe rely on Kate M. Growley to navigate their most challenging digital issues, particularly those involving cybersecurity, artificial intelligence, digital infrastructure, and their intersection with national security. Clients seek her guidance on proactive compliance, incident response, internal and government-facing investigations…

Businesses around the globe rely on Kate M. Growley to navigate their most challenging digital issues, particularly those involving cybersecurity, artificial intelligence, digital infrastructure, and their intersection with national security. Clients seek her guidance on proactive compliance, incident response, internal and government-facing investigations, and policy engagement. With a unique combination of legal, policy, and consulting experience, Kate excels in translating complex technical topics into advice that is practical and informed by risk and business needs.

Kate has extensive experience working with members of the U.S. government contracting community, especially those within the Defense Industrial Base. She has partnered with contractors from every major sector, including technology, manufacturing, health care, and professional services. Kate is an IAPP AI Governance Professional (AIGP) and a Certified Information Privacy Professional for both the U.S. private and government sectors (CIPP/G and CIPP/US). She is also a Registered Practitioner with the U.S. Cybersecurity Maturity Model Certification (CMMC) Cyber Accreditation Body (AB).

Having lived in Greater China for several years, Kate also brings an uncommon understanding of digital and national security requirements from across the Asia Pacific region. She has notable experience with the regulatory environments of Australia, Singapore, Japan, and Greater China—including the growing regulation of data flows between the latter and the United States.

Kate is a partner in the firm’s Washington, D.C., office, as well as a senior director in the firm’s consultancy Crowell Global Advisors, to which she was seconded for several years. She is a founding member of the firm’s Privacy & Cybersecurity Group and part of the firm’s AI Steering Committee. She has been internationally recognized by Chambers and named a “Rising Star” by both Law360 and the American Bar Association (ABA). She has held numerous leadership positions in the ABA’s Public Contract Law and Science & Technology Sections and has been inducted as a lifetime fellow in the American Bar Foundation.

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  • Posted in:
    Government Contracts, Privacy and Cybersecurity
  • Blog:
    Government Contracts Legal Forum
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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