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CMMC Brief

Daily CMMC and defense industrial base compliance briefing. DoD policy and rulemaking, False Claims Act cyber enforcement, Cyber AB and C3PAO developments, NIST 800-171 updates, and contracting impact for DIB contractors, compliance managers, and the MSPs and consultants who support them. From Carolina Clear Tech.

Latest Episodes:

2026-09-21: Open-CMMC v2.0 tackles CUI-to-OT workflows over SMB Sep 21, 2026

Show notes

Show Notes - 2026-09-21

Stories Covered

Today:
Open-CMMC v2.0 extends CUI workflow protection to OT systems [Practitioner Pulse]
Contractor reports passing third-party Level 2 CMMC assessment [Practitioner Pulse]
FCI scoping question: do assessors check FCI environments during Level 2 assessments? [Practitioner Pulse]
CCP exam passed, practitioner seeks CCA prep recommendations [Practitioner Pulse]

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2026-09-19: DOJ announced a major False Claims Act enforcement policy revision that limits sub-regulatory Sep 19, 2026

Show notes

Show Notes - 2026-09-19

Stories Covered

Today:
DOJ revises Justice Manual to limit False Claims Act enforcement to binding legal obligations. [Enforcement & False Claims]
Illegal alien arrested for fraudulent U.S. citizenship claims to secure aerospace contractor employment. [Enforcement & False Claims]
OFCCP eliminates Section 503 disability compliance requirements effective September 21. [Contracting Impact]
CISA and Five Eyes partners release CI Fortify guidance on network isolation for critical infrastructure. [NIST & Standards]
AAFES investigating suspicious messages sent via email and official mobile app. [Practitioner Pulse]

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2026-09-18: The Ninth Circuit ruled that federal agencies cannot unilaterally define what is "material" under Sep 18, 2026

Show notes

Show Notes - 2026-09-18

Stories Covered

Today:
ISOO Releases CUI Notices 2026-07 and 2026-08: Agencies Must Give Contractors Explicit CUI Handling Guidance [Policy & Rulemaking]
Action: [Policy & Rulemaking]
Army Directive 2026-19: Commercial Software First [Policy & Rulemaking]
Action: [Policy & Rulemaking]
SBA Prioritizing Defense-Critical 8(a) Applicants [Policy & Rulemaking]
Action: [Policy & Rulemaking]
Ninth Circuit: Agencies Cannot Define FCA "Materiality" by Fiat (County of King v. Turner) [Enforcement & False Claims]
Action: [Enforcement & False Claims]
New FCA Cybersecurity Settlement Reported [Enforcement & False Claims]
Action: [Enforcement & False Claims]
CUI Scoping Gets Clearer (Ties to ISOO 2026-07) [NIST & Standards]
Action: [NIST & Standards]
CCP Exam Pass Report [Practitioner Pulse]
3.8.2 Media Access: USB Tracking Question [Practitioner Pulse]
Funding Level 2 Compliance: The Cost Question [Practitioner Pulse]

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2026-09-17: A new FCA cybersecurity settlement reinforces that DOJ is actively enforcing self-attestation Sep 17, 2026

Show notes

Show Notes - 2026-09-17

Stories Covered

Today:
CIRCIA Final Rule Expected This Month; DIB Contractors Face Overlapping Reporting Obligations [Policy & Rulemaking]
New FCA Cybersecurity Settlement Signals DOJ Keeps Foot on the Gas [Enforcement & False Claims]
Former Army Soldier Pleads Guilty to Transmitting National Defense Information [Enforcement & False Claims]
Air Force Stands Up 'Megatron' IDIQ for Battle Network Acquisitions [Contracting Impact]
U.S.-India RDPA Negotiations Advancing; OCI Risks in GovCon M&A [Contracting Impact]
CCA Exam Candidates Frustrated with Training Quality [Practitioner Pulse]

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2026-09-16: DoD's new class deviation confirms baseline DFARS 7012 and NIST 800-171 Rev 2 compliance remain Sep 16, 2026

Show notes

Show Notes - 2026-09-16

Stories Covered

Today:
What remains mandatory: [Policy & Rulemaking]
What is suspended: [Policy & Rulemaking]
Action: [Policy & Rulemaking]
Watch: [Policy & Rulemaking]
C3PAO demand during the pause: [Practitioner Pulse]
Post-assessment Rev 3 migration: [Practitioner Pulse]
FIPS mode implementation pain: [Practitioner Pulse]
Physical security (employee badges): [Practitioner Pulse]
Bottom line: [Practitioner Pulse]

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2026-09-15: Cyber AB CEO Matthew Travis outlined reform proposals including continuous monitoring and smaller Sep 15, 2026

Show notes

Show Notes - 2026-09-15

Stories Covered

Today:
Cyber AB submits reform recommendations to DoW Reform Task Force [Policy & Rulemaking]
DoW Class Deviation Revision 3 retains Phase 2 suspension, adds new clauses [Policy & Rulemaking]
Pentagon issues AI-assisted software development procedures [Policy & Rulemaking]
Standing reminder: [Enforcement & False Claims]
Travis confirms assessor supply bottleneck is a cost driver. [Cyber AB & Ecosystem]
Army Directive 2026-19: commercial-first software acquisition [Contracting Impact]
PreVeil survey: the affordability gap is widening [Practitioner Pulse]
PIEE access delays blocking self-assessments. [Practitioner Pulse]
Cloud enclave vendor comparison. [Practitioner Pulse]

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2026-09-12: Honeywell settled a $2M False Claims Act case for failing to implement NIST 800-171 controls on a Sep 12, 2026

Show notes

Show Notes - 2026-09-12

Stories Covered

Today:
60-Day Suspension Review Period Ends, No Public Guidance Yet [Policy & Rulemaking]
White House Quantum Executive Orders Set PQC Migration Deadlines [Policy & Rulemaking]
Honeywell Pays $2M to Settle NIST 800-171 Noncompliance Allegations [Enforcement & False Claims]
Action: [Enforcement & False Claims]
DoD Multi-Model AI Migration Signals Vendor Diversification Expectations [Contracting Impact]
Browser FIPS Validation for CUI Access: No Easy Answer [Practitioner Pulse]
60-Day Pause Thread: Practitioners Watching, Not Expecting [Practitioner Pulse]

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2026-09-05: No CMMC-specific policy, enforcement, or rulemaking developments today Sep 05, 2026

Show notes

Show Notes - 2026-09-05

Stories Covered

Today:
Executive Order 14421: Bulk-Power System Supply Chain Security (Signed, Aug. 26, 2026) [Policy & Rulemaking]
Standing reminder: [Enforcement & False Claims]
National Security Tech Strategy Highlights Embedded-Systems Patching Gap [NIST & Standards]
DISA DoDNet Migration: 231,000 Users, 11 Combatant Commands by FY2028 [Contracting Impact]
Context: [Cyber AB & Ecosystem]
Standing guidance for a quiet day: [Practitioner Pulse]

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2026-08-26: No policy, rulemaking, or enforcement developments Aug 26, 2026

Show notes

Show Notes - 2026-08-26

Stories Covered

Today:
Compliance cost benchmarks now public. [Practitioner Pulse]
What to do: [Practitioner Pulse]
CMMC jargon guide published. [Practitioner Pulse]
Context note: [Practitioner Pulse]
Federal cyber context (not DIB-specific): [No developments today in:]
About this brief: [No developments today in:]
Reminder: [No developments today in:]

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2026-08-25: The Navy stood up a new Office of the Defense Industrial Base to revitalize maritime supply chains Aug 25, 2026

Show notes

Show Notes - 2026-08-25

Stories Covered

Today:
Navy creates Office of the Defense Industrial Base to accelerate dual-use tech and supply chain resilience. [Policy & Rulemaking]
What to do: [Policy & Rulemaking]
GSA updates FICAM architecture and Treasury launches Quantum-Readiness Task Force ahead of 2030/2031 post-quantum crypto deadlines. [Policy & Rulemaking]
What to do: [Policy & Rulemaking]
Tetra Tech pays $57M to settle FCA allegations for falsifying soil radiation tests at Hunters Point Naval Shipyard. [Enforcement & False Claims]
Air Force member indicted for lying on background investigation forms to get NASA/IRS/NOAA contract work while on active duty. [Enforcement & False Claims]
What to do: [Enforcement & False Claims]
DoD's Drone OTA Consortium opens Joint UGV demo for October. [Cyber AB & Ecosystem]
What to do: [Cyber AB & Ecosystem]
SBA tightens 7(a) lending rules effective October 1, making acquisitions harder to finance. [Contracting Impact]
What to do: [Contracting Impact]
M&A buyers need to understand which GovCon assets survive closing and which do not. [Contracting Impact]
What to do: [Contracting Impact]
No new NIST SP 800-171 or 800-172 guidance this cycle. [NIST & Standards]
Secure communications remain a human problem, and approved tools still lose to convenience. [Practitioner Pulse]
What to do: [Practitioner Pulse]

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