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DoD Issues Final CMMC Framework for Defense Contractors

By Edwin O. Childs, Abram J. Pafford, Andrew Konia, Jack White, Jason M. Vespoli, Maura Naehr & John Sullivan on October 23, 2024
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After a nearly five-year rulemaking process, the U.S. Department of Defense (DoD) published the Final Cybersecurity Maturity Model Certification 2.0 (CMMC) program rule in the Federal Register on Oct. 15, 2024, codified at 32 CFR Part 170. Contract clauses implementing the CMMC program rule will be issued as part of the Defense Federal Acquisition Supplement, and DoD expects to require CMMC certifications as a condition of award beginning in 2025 as part of a phased-in approach.

The final CMMC program rule is the culmination of a lengthy rulemaking process to implement third-party certified cybersecurity program standards for the Defense Industrial Base. The DoD significantly revised CMMC program requirements since the inception of CMMC 1.0 in 2020. At its most basic level, the CMMC program is a transition from a self-certification model for cybersecurity compliance, to a third-party verification process contemplated by the CMMC program rule.

Read on to learn more about the final rule and its implications for contractors and subcontractors.

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Photo of Edwin O. Childs Edwin O. Childs

As a leader of the firm’s Defense, National Security and Government Contracting industry team, Ned Childs is a government contract and investigations and enforcement attorney who represents companies across a wide range of sectors, including the defense, services, technology, and aerospace industries.

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Photo of Abram J. Pafford Abram J. Pafford

Abe is an experienced litigator who represents government contractors across the full spectrum of government contract matters, including litigation, appeals, administrative proceedings and investigations. As a member of the firm’s nationally recognized Government Investigations and White Collar department, Abe prosecutes claims arising under…

Abe is an experienced litigator who represents government contractors across the full spectrum of government contract matters, including litigation, appeals, administrative proceedings and investigations. As a member of the firm’s nationally recognized Government Investigations and White Collar department, Abe prosecutes claims arising under the Contract Disputes Act, defends against False Claims Act lawsuits initiated by the Department of Justice, and represents protestors and intervenors in pre-award and post-award bid protests before the United States Court of Federal Claims and the GAO.

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Photo of Andrew Konia Andrew Konia

Andrew’s practice is singularly focused on protecting clients’ businesses and data, anticipating disputes, and strengthening their competitive position in the marketplace.

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Photo of Jack White Jack White

Jack is a partner in the firm’s nationally ranked Government Investigations and White Collar Litigation practice, focusing his practice on civil litigation, regulatory enforcement, and congressional investigations for clients in the defense, technology, federal contracting, and other business sectors.

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Photo of Jason M. Vespoli Jason M. Vespoli

Jason focuses his practice on federal and state procurement, government technology, bid protests and government contract disputes, and regulatory compliance. He utilizes experience in state government, government technology, and complex procurement to solve problems in innovative and efficient ways.

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Photo of Maura Naehr Maura Naehr

Maura focuses her practice on government contracts and government investigation matters.

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Photo of John Sullivan John Sullivan

John is an associate within the Government Investigations and White Collar Litigation group.

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  • Posted in:
    Privacy & Data Security
  • Blog:
    Password Protected
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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