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Annual ISDC Reporting

Client Alert | less than 1 min read | 11.07.19

The annual Interagency Suspension and Debarment Committee recently issued its annual report to Congress. The report, found here, contains details of the state of the federal suspension and debarment program for Fiscal Year 2018 (note the significant timelag). The report notes a focus on cybersecurity contractor compliance issues, and proposals to modernize/streamline lead agency coordination. Otherwise, total numbers of suspensions, proposed debarments, and debarments continued to decline year-over-year, while pre-notice interactions with contractors continued to comprise a significant portion of SDO offices’ dockets.

Insights

Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....