News & Analysis as of

DFARS Subcontractors

Holland & Hart LLP

A Defense Contractor's Guide to CMMC, DFARS, and FAR Requirements

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Cyber-attacks against America’s defense industrial base are becoming more sophisticated and more frequent. To reduce the risk of sensitive national security information landing in the hands of bad actors, the Department of...more

McCarter & English Blog: Government Contracts...

The “Prestige”: DoD Unveils NIST SP 800-171 Revision 3, Organizationally Defined Parameters

On April 15, 2025, the Department of Defense (DoD) released official guidance on Organizationally Defined Parameters (ODPs) appearing in the newly published NIST SP 800-171 Revision 3. At the same time, the DoD reaffirmed...more

Holland & Knight LLP

DOD Proposed Rule Will Expand FOCI Requirements to Non-Classified Defense Contracts

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U.S. Department of Defense (DOD) contractors with foreign ownership, control, or influence (FOCI) soon will face new requirements. Though cleared DOD contractors have long been bound by FOCI obligations, the new rule will...more

Goodwin

Major Federal Procurement Changes Coming in Light of Recent Executive Orders

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The Trump administration has issued two Executive Orders very recently that will drive changes in federal procurement and defense procurement and impact federal contractors in the very near future. The Executive Orders are...more

Troutman Pepper Locke

The Federal Contractors’ Playbook: Managing Increased Costs From Tariffs and Domestic Material Demands

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Just two months into President Donald Trump’s second term, contractors have been whipsawed by a flurry of executive orders, Department of Government Efficiency (DOGE) directives, and agency actions. This has brought an era of...more

Morrison & Foerster LLP - Government...

Bid Protest Spotlight: Registration, Substantiation, Experience

To kick off the new year, this bid protest spotlight highlights two U.S. Government Accountability Office decisions involving System for Award Management (SAM) registration requirements when submitting an “offer” and an...more

Morrison & Foerster LLP - Government...

Proposed Regulation on Controlled Unclassified Information Standardizes Process for CUI Identification and Handling Across Federal...

The Federal Acquisition Regulation (FAR) Council issued its long awaited proposed rule on Controlled Unclassified Information (CUI) on January 15, 2025. The proposed rule establishes a common form to be used by all federal...more

PilieroMazza PLLC

Weekly Update for Government Contractors and Commercial Businesses – January 2025 #3

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SBA Update: New Rule Makes Major Changes to Eligibility and Certification Requirements for HUBZone Program - As PilieroMazza noted on December 17, 2024, the Small Business Administration (SBA or the Agency) published a...more

McCarter & English Blog: Government Contracts...

They Did It. They Really Did It! The Arrival of the FAR CUI Proposed Rule

After years of anticipation, the Federal Acquisition Regulation (FAR) Council has announced the arrival of its proposed rule to enhance the safeguarding of Controlled Unclassified Information (CUI) in federal contracts (the...more

Vinson & Elkins LLP

DoD Releases Final CMMC Program Rule, Formally Initiating Its Cybersecurity Program

Vinson & Elkins LLP on

On October 15, 2024, the Department of Defense (“DoD”) released its final rule (the “Final Rule”) formally establishing the Cybersecurity Maturity Model Certification (“CMMC”) program, nearly three years after first...more

Wiley Rein LLP

Updates on Cybersecurity Requirements for Government Contractors

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Part of the Biden Administration’s push to enhance U.S. cybersecurity capabilities has focused on imposing new requirements on government contractors. The 2023 National Cybersecurity Strategy suggested, for example, that...more

PilieroMazza PLLC

What DOD’s Proposed Changes to its Prototype OT (Other Transaction) Agreements Regulations Mean for Defense Contractors

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On September 4, 2024, the Department of Defense (DOD) issued a proposed rule to update regulations related to other transaction (OT) agreements[1] to implement congressional changes in the statutory authority for prototype...more

Paul Hastings LLP

U.S. Department of Defense Set to Implement Its Cybersecurity Maturity Model Certification Program With Publication of New Rule

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On October 15, 2024, the Department of Defense (“DoD”) published the final version of its rule implementing the Cybersecurity Maturity Model Certification (“CMMC”) Program under Title 32 of the Code of Federal Regulations...more

Snell & Wilmer

Department of Defense Finalizes Rule Adding New Cybersecurity Requirements for Defense Contractors and Subcontractors

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The U.S. Department of Defense (DOD) has published a Final Rule to implement the Cybersecurity Maturity Model Certification (CMMC) program, which establishes minimum cybersecurity requirements for nearly all DOD contracts....more

Wiley Rein LLP

DOD Launches Pilot Program for Sole Source Follow-on Awards to ESOPs

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On October 10, 2024, the U.S. Department of Defense (DOD) issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to establish a pilot program allowing for sole source follow-on contract...more

Wiley Rein LLP

DOD Crystalizes CMMC 2.0 Program Rule

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WHAT: On October 15, 2024, the U.S. Department of Defense (DOD) will publish the final CMMC 2.0 Program rule. DOD’s final rule outlines the mechanisms that DOD will use to prescribe cybersecurity standards for safeguarding...more

BakerHostetler

CMMC Barrels Closer to Implementation with Latest Proposed Rule Establishing DFARS Contract Clauses

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Cybersecurity Maturity Model Certification (CMMC) is coming — and now appears to be coming faster than many defense contractors believed. In the latest signal of CMMC’s forward momentum, the Department of Defense (DoD) issued...more

McCarter & English Blog: Government Contracts...

CMMC and DFARS 252.204-7021—Is the Sequel Better than the Original?

Sequels are rarely better than the films that precede them, and yet, sometimes a story is just too compelling to be limited to just one film. At the tail end of a summer full of Hollywood sequels, the Department of Defense...more

Morris, Manning & Martin, LLP

The Race to Full Implementation Continues: CMMC 2.0 Gains Even More Traction

As the presidential race rages on, so too does the race to fully implement the Cybersecurity Maturity Model Certification (CMMC) 2.0 program. The CMMC 2.0 program impacts Defense Industrial Base (DIB) contractors and...more

Holland & Knight LLP

The Pentagon's CMMC Program Takes a Big Step Forward

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The U.S. Department of Defense (DOD) issued the proposed Defense Federal Acquisition Regulation Supplement (DFARS) rules that will implement the Cybersecurity Maturity Model Certification (CMMC) program. These rules, which...more

Woods Rogers

DOD’s CMMC 2.0 Program Takes Step Forward with Release of Contract Rule Proposal

Woods Rogers on

The United States Department of Defense (DoD) took another big step on the path to instituting its highly anticipated Cybersecurity Maturity Model Certification 2.0 program (CMMC 2.0). Once finalized, CMMC 2.0 will establish...more

Venable LLP

The Subcontractor Performed. The Prime Contractor Paid. But a Hacker Ended Up with the Money. Who Is Responsible?

Venable LLP on

When hackers gain access to a subcontractor’s information systems and divert the prime contractor’s payment to themselves instead of to the subcontractor, does the prime contractor still have to pay the subcontractor?...more

PilieroMazza PLLC

What DOD’s Final DFARS Rule Means for Defense Contractors, American Manufacturing, and Protecting the Nation’s Supply Chain

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On February 15, 2024, the Department of Defense (DOD) issued a final rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement Executive Order (EO) 14005, Ensuring the Future Is Made in All of...more

Blindauer Law PLLC - Government Contracts...

Government Contracts Issues for a Recession

The bond yield curve inverted in October 2022. When that occurred, it started a countdown to recession. At least it has every time since 1968. Specifically, for the last eight recessions since 1968, every single recession was...more

McCarter & English Blog: Government Contracts...

DoD’s Proposed CMMC Rule: Groundhog Day… or a Final Rule in the Works?

On December 26, 2023, the Department of Defense (“DoD”) belatedly gifted defense contractors and subcontractors a Proposed Rule on the Cybersecurity Maturity Model Certification (“CMMC”) Program. DoD also released eight CMMC...more

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