Buy 1 Get 2 Free Special on Cyber Regulations: DoD Interim Rule Unveils 3 New Clauses Geared at Cybersecurity Assessments
Client Alert | 1 min read | 09.29.20
The Department of Defense (DoD) has released its eagerly anticipated Interim Rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement two major initiatives: the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 DoD Assessment Methodology and the Cybersecurity Maturity Model Certification (CMMC). The Interim Rule introduces the related clauses DFARS 252.204-7019, Notice of NIST SP 800-171 DoD Assessment Requirements and DFARS 252.204-7020, NIST SP 800-171 DoD Assessment Requirements; as well as the separate clause DFARS 252.204-7021, Cybersecurity Maturity Model Certification Requirements.
-7019 requires contractors to have a current NIST SP 800-171 DoD Assessment in order to be considered for award, which may have been met where contractors have had a recent Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) Assessment. Relatedly, -7020 requires contractors to provide the Government with access to their facilities and systems for higher-level Assessments, in addition to ensuring that subcontractors handling Covered Defense Information (CDI) have made their Assessments available to the Government.
-7021 implements the long-expected CMMC framework, where contractors must receive a third-party certification that they have met one of five specified cybersecurity levels – and maintain that certification for the duration of their contracts. The CMMC clause will begin appearing in select solicitations later this year, and eventually in all solicitations above the micro-purchase threshold by October 1, 2025, excluding those exclusively for commercially available off-the-shelf (COTS) items.
The Interim Rule goes into effect on November 30, 2020, with comments due the same day.
Contacts
Partner and Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 2 min read | 09.08.26
IRS Takes Aim: Proposed Rule Threatens Tax-Exempt Status of Private Schools
On September 4, 2026, the IRS published a notice of proposed rulemaking (NPRM) titled “Racial Nondiscrimination in Private Schools” (REG-119986-25). The proposed rule would extend the prohibition against racial discrimination in private schools to policies and practices that are intended to serve “remedial or diversity-related objectives,” such as those commonly associated with diversity, equity, and inclusion (DEI) initiatives. Under the proposed rule, any private primary or secondary school, college, professional or trade school, or university, would lose its tax-exempt status if it adopts, maintains, or enforces any policy or practice that considers race, color, or national or ethnic origin in the administration of any admissions policy, scholarship or loan program, athletic program, or other school-administered program. Comments are due November 3, 2026, and, if finalized, the proposed rule would go into effect on May 31, 2027.
Client Alert | 5 min read | 09.03.26
Client Alert | 6 min read | 09.03.26
FDA Seeks Input for Regulating GenAI-Powered Medical Devices
Client Alert | less than 1 min read | 09.03.26
SBA Proposal to Overhaul Size Standards Would Transform Federal Government Contracting
