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Immaturity of the Cybersecurity Maturity Model: Revisions Omit Higher-Level Updates

Client Alert | 1 min read | 11.13.19

Last week, the Defense Department (DoD) released Revision 0.6 to the Cybersecurity Maturity Model Certification (CMMC). Notably absent were revisions to Levels 4 – 5, which DoD promises in the next public release. While the final version of the CMMC is due in late January, Revision 0.6 updated CMMC Levels 1 – 3 by:

  • Condensing the CMMC requirements;
  • Modifying the practices and processes; and
  • Providing clarifications and examples for CMMC Level 1 requirements.

Revision 0.6 also distilled the core requirements for Levels 1 – 3 into the following categories:

  • Level 1 -- Basic cyber hygiene: Implementation of security controls in FAR 52.204-21, Basic Safeguarding of Covered Contractor Information Systems;
  • Level 2 -- Intermediate cyber hygiene: Implementation of select NIST SP 800-171 controls; and
  • Level 3 -- Good cyber hygiene: Full implementation of NIST SP 800-171 controls.

Industry will benefit from reviewing this latest draft and preparing for DoD’s pending implementation of the CMMC.

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Client Alert | 4 min read | 07.06.26

House Advances Bipartisan Kids' Online Safety Bill, But Senate Showdown Looms

On June 22, 2026, House Energy and Commerce Committee Chairman Brett Guthrie (R-Ky.) and Ranking Member Frank Pallone (D-N.J.) announced a bipartisan agreement on a revised version of the KIDS Act (H.R. 7757), marking the most significant congressional advance on children's online safety legislation in years. The House passed H.R. 7757, as amended, on June 29, 2026, setting up a potential showdown with the Senate. The revised KIDS Act consolidates elements of 14 pending legislative proposals — including KOSA and COPPA 2.0, both of which have previously passed the Senate and cleared the House Energy and Commerce Committee — into a single, comprehensive framework. The announcement, however, was met immediately with objections from Senate sponsors and civil liberties groups, underscoring the difficult legislative road ahead....