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No More "Wait & See" for CMMC: DoD Releases Final Cybersecurity Maturity Model Certification

Feb.03.2020

The Department of Defense (DoD) has released Version 1.0 of the Cybersecurity Maturity Model Certification (CMMC), Appendices A-F, and an Overview Briefing. While Version 1.0 largely mirrors the draft Version 0.7, the final version includes notable revisions, such as:

  • Process and Practice Descriptions in Appendix B, which include discussions and clarifications for every “practice” within each CMMC Level, including the long-awaited examples for Levels 4 and 5; and
  • Source Mapping in Appendix E, which maps each “practice” across all five Levels –171 in total – to other pre-existing cybersecurity frameworks.

Much, however, remains to be done. In anticipation of the DoD adopting “go/no-go” CMMC certification requirements later this year, a privately-run Accreditation Body is expected to begin training third-party assessors (3PAOs) this spring in conducting those certifications for contractors. Simultaneously, the DoD is expected to issue a proposed rule incorporating the CMMC into DFARS 252.204-7012, to be finalized this fall. 

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Evan D. Wolff
Partner – Washington, D.C.
Phone: +1 202.624.2615
Email: ewolff@crowell.com
Kate M. Growley, CIPP/G, CIPP/US
Partner – Washington, D.C.
Phone: +1 202.624.2698
Email: kgrowley@crowell.com
Maida Oringher Lerner
Senior Counsel – Washington, D.C.
Phone: +1 202.624.2596
Email: mlerner@crowell.com
Michael G. Gruden, CIPP/G
Associate – Washington, D.C.
Phone: +1 202.624.2545
Email: mgruden@crowell.com
Christopher R. Hebdon
Associate – Washington, D.C.
Phone: +1 202.624.2645
Email: chebdon@crowell.com