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March 2, 2022

The CMMC 2.0 Paradigm and Contractor Supply Chain Risk Management Obligations

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The CMMC 2.0 Paradigm and Contractor Supply Chain Risk Management Obligations


Since January 2018, the Defense Department (and now other agencies) has required prime contractors and subcontractors at all tiers to implement NIST SP 800-171, “Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations.” Between January 2018 and November 2021, the Defense Department issued numerous guidance memoranda regarding NIST-171 and set up an arrangement with the Cybersecurity Maturity Model Certification – Accreditation Board. In turn, the CMMC-AB developed a “CMMC ecosystem” based on NIST-171 and related NIST guidance in order to identify NIST-171 cybersecurity objectives intended for contractors and subcontractors who handle, create or store “controlled unclassified information” or CUI. A significant element of this ecosystem was the creation of an infrastructure which facilitates education, training and third-party assessment leading to the certification of a DIB company’s implementation of CMMC 1.0 compliance.

The Defense Department paused implementation of the CMMC 1.0 program by introducing CMMC 2.0 through an Advanced Notice of Proposed Rulemaking published November 4, 2021. DoD did not pause compliance with FAR 52.204-2 or DFARS 252.204-7012.

Your company’s level of CMMC 2.0 “cyber hygiene” will directly impact your eligibility to contract or subcontract with the Defense Department (and likely non-DoD agencies such as the GSA and the DHS) as well as impact your competitive posture anywhere in the DoD supply or service chain.

In this Program, you will learn about:

  • The prospective CMMC 2.0 schedule;
  • Federal cybersecurity vocabulary: CUI, FCI, CDI, CTI;
  • CUI marking obligations by government personnel and contractor personnel
  • How CMMC 2.0 “Level 1” (the foundational level) effectively applies to all federal agencies;
  • The requirements of FAR 52.204-21 and DFARS 252.204-7012 and the current DFARS 252.204-7019, 7020, and 7021 clauses;
  • DoD’s Assessment Methodology;
  • The Supplier Performance Risk System (SPRS);
  • The DoD guidance available to achieve CMMC 2.0 Level 1 and Level 2 (the advanced level);
  • The available self-assessment programs;
  • The requirements under [Draft] NIST SP 800-172 contained in CMMC Level 3 to address Advance Persistent Threats;
  • The quality of a System Security Plan and the CMMC 2.0 emphasis of a Plan of Action & Milestones)
  • CMMC 2.0, the Cloud and FedRAMP;
  • The government-wide supply chain obligations regarding Chinese sources
    • DoD guidance
    • GSA guidance
  • DoD supply chain obligations regarding Chinese and Russian sources
    • DoD guidance

Event Details

Date & Time

March 2, 2022 @ 12:30 pm - 2:00 pm


Virginia PTAC