Attention all DoD contractors and subcontractors!
DoD is proposing to amend the DFARS to incorporate solicitation and contractual requirements to implement CMMC 2.0, once finalized.
DoD plans to revise the existing DFARS language to, among other changes, establish solicitation provisions for contracting officers to incorporate in contracts and require increased subcontractor/vendor screening and evidence of compliance.
Why should you care?
The proposed rule will impact DoD contractors and subcontractors at all tiers, because the 3-year CMMC phase-in may start as early as summer of 2025! During the 3-year phase-in period, DFARS 252.204-7021 will be included in all solicitations, including those for commercial items and services (except COTS), where there is a requirement for CMMC security protections. DoD Contractors who fail to meet these requirements will be ineligible for award of a new contract or the exercise of an option under an existing contract.
Under the new DFARS clause, contractors will have to flow down these requirements to subcontractors and vendors at all tiers. This means that contractors should start now to modify internal compliance programs, include vendor screening for CMMC certifications, and change processes and procedures to accommodate the CMMC requirements.
Got Questions? Not sure if you’re ready for CMMC or compliance with any of the cybersecurity regulations?
Ward & Berry recently expanded its cybersecurity and technology bench of skilled professionals by adding Jennifer Morris as a new Partner to help companies like yours understand and comply with the new CMMC and DFARS requirements. Jennifer has over 24 years of experience working with defense contractors in technology and cybersecurity. She has served as counsel to multiple DoD CIO offices, including as a senior acquisition/procurement counsel to the Navy, acquisition/procurement counsel to the CIA, and as a US Army Reserves JAG Officer. More importantly, Jennifer has spent numerous years working in-house for technology and cybersecurity companies helping them implement and streamline compliance programs, win new government contracts, and achieve increased revenue/growth. Reach out to Jennifer Morris and the Ward & Berry team at large for any cybersecurity questions you may have!
And remember – if you have something to say about the proposed rule, SPEAK NOW – comments are due October 15, 2024! To make comments and read the proposed Rule, go to: https://lnkd.in/gS3T7cB2
and select "Public Comments." You can also email osd.dfars@mail.mil.
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Ryan Berry Daniel Ward Ryan Bradel Amanda Merced Jennifer Morris Tyson Marx Michael Hatch Brian Yu Chelsea Padgett Matthew Saliman Nicholas Perry