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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 | 5 min read | 12.12.25

Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality

On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument....

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