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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 | 3 min read | 11.21.25

A Sign of What’s to Come? Court Dismisses FCA Retaliation Complaint Based on Alleged Discriminatory Use of Federal Funding

On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future....

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