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Cybersecurity Maturity Model Matures: DoD Adds New Requirements to Draft Cybersecurity Certification

Client Alert | 1 min read | 09.10.19

The Defense Department has released Revision 0.4 of its Cybersecurity Maturity Model Certification (CMMC) that, starting next year, independent auditors are to use to certify contractor compliance with DoD cybersecurity requirements.  Revision 0.4 more than doubles the number of cybersecurity controls across the CMMC’s five maturity “Levels.”  But the DoD emphasizes that it will further down-select these controls and that mature contractor processes may counteract gaps in the final controls’ implementation.  In addition to NIST SP 800-171 (the default standard under DFARS 252.204-7012), Revision 0.4 now incorporates requirements from the NIST Cybersecurity Framework, ISO 27001, and CIS Critical Security Controls, as well as from “additional DIB inputs.”  Notably missing is NIST SP 800-171B, which remains under review.

The DoD is requesting feedback on Revision 0.4 through September 25, 2019, and plans on releasing Revision 0.6 for comment in November 2019.   The final CMMC is expected in January 2020. 

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Client Alert | 2 min read | 07.31.25

A Greater Sum of Certainty: ASBCA Weighs in on when Sum Certain Defense Is Not Waived

A recent Armed Services Board of Contract Appeals decision provides useful guidance on when the government may (or may not) waive its defense that a contractor’s claim failed to state a sum certain. In GE Renewables US, LLC, the contractor had submitted a claim to the contracting officer for a determination that the contractor had the right to an economic price adjustment (EPA) due to an inflation-related price increase. Notably, the contractor did not provide the value of its requested adjustment in its claim. The contracting officer denied the claim, and the contractor appealed to the Board....