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The DoD's Own Cyber Monday: Defense Department Releases CMMC Assessment Guides

Client Alert | 1 min read | 12.09.20

Fresh off the heels of the DFARS Interim Rule, the Department of Defense (DoD) released Assessment Guides for Levels 1 - 3 of the Cybersecurity Maturity Model Certification (CMMC). These Guides will be used by Certified Assessors to determine whether contractors have satisfied the practices and processes required to attain CMMC certifications at the level needed to be awarded future DoD contracts. These new assessment procedures, which DoD calls “authoritative,” are leveraged from NIST SP 800-171A, the NIST guidance used to assess compliance with NIST SP 800-171. 

A notable inclusion in the Levels 2 – 3 Guide is the assessment criteria used to evaluate a contractor’s implementation of processes for each of the 17 CMMC Domains. Under the CMMC, the DoD has stated that contractors will not be certified at CMMC Levels 2 and above if the contractor has not satisfied both the technical practices and process maturity for the desired level.

These Guides will provide useful insights as contractors prepare for the DoD’s phased implementation of CMMC requirements into all DoD contracts over the next 5 years. 

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Client Alert | 14 min read | 03.13.26

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On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities.  The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards.  The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed.  GSA requests comments by March 20, 2026....