Common Misconceptions Around the CMMC Pause
The Question Every Defense Contractor Should Be Asking Right Now
The CMMC Phase 2 Pause has led to companies in the Defense Industrial Base (DIB) asking a multitude of questions around cost concerns, assessment readiness, and the potential of changes to the current requirements. LCE continues to take the stance we have taken for decades in times of regulatory changes and uncertainty to ensure we are prepared to continue serving the DIB through our expertise, keeping our clients informed of current and evolving standards, and providing services to best position our clients for success. With this topic revolving primarily around DFARS 252.204-7012, LCE’s internal team of CMMC Assessors, GRC professionals, and cybersecurity experts are asking, “What cybersecurity obligations exist today, regardless of what happens to CMMC?” Organizations answering this question are building resilient cybersecurity programs.
The recent pause in CMMC implementation has created uncertainty about the future verification model. It has not erased the contractual and operational realities that defense contractors have been living under for years.
The obligations that existed before CMMC and continue independently of how future verification is structured are compliance with the following:
- DFARS 252.204-7012
- NIST SP 800-171 implementation where contractually required
- Cyber incident reporting
- Protection of Covered Defense Information
- Subcontractor/Supply Chain flow-down
These remain foundational responsibilities.
We believe this pause in CMMC Phase 2 is an opportunity for companies in the DIB to strengthen their cybersecurity by implementing a demonstrable, repeatable cybersecurity program that protects CUI and complies with DFARS 252.204-7012. This requires the DIB to understand their system boundaries, maintain accurate asset inventories, document their environments through a living System Security Plan, validate implementation of security requirements, and ensure that evidence supports the reality of operations. That is the very core of mature cybersecurity programs no matter what framework or standard they are being assessed against. That is what will be crucial no matter what the outcome of the pause or the government’s findings of the CMMC program. Focusing on these foundational essentials of cybersecurity will produce programs that remain secure and valuable regardless of future regulatory changes and will position a company to meet the requirements set forth in their contracts by DFARS 252.204-7012 no matter what the outcome of this pause will bring. Over the coming weeks, LCE will publish a series of articles and short videos that explain the Defense Industrial Base cybersecurity ecosystem from first principles. We’ll discuss DFARS 252.204-7012, NIST SP 800-171, assessment readiness, governance, and practical implementation, not as isolated regulations, but as parts of a connected system.
Our goal is simple: help organizations build cybersecurity programs that satisfy today’s obligations while preparing for tomorrow’s requirements.
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