Client Alerts & Newsletters

CMMC 2.0: DoD Unveils Sweeping Changes Streamlining CMMC Requirements

November 5, 2021

The Department of Defense (DoD) recently announced significant changes to its Cybersecurity Maturity Model Certification (CMMC) program intended to simplify the requirements and ease the compliance burden on contractors.  Unlike its predecessor, the new CMMC 2.0 moves to three compliance levels rather than five; aligns the required security controls (known as practices) with National Institute of Standards and Technology (NIST) Special Publications (SP) 800-171 and 800-172; and eliminates entirely previously required maturity processes.  The changes also include a shift to self-assessments for all but contractors supporting the most sensitive programs, as well as the return of Plans of Action and Milestones (POAMs) to demonstrate compliance and achieve certification. 

The new requirements are summarized below:

  • CMMC Level 1, Foundational – Contractors must implement the 17 controls from NIST SP 800-171 enumerated in FAR 52.204-21 and submit an annual self-assessment to the DoD through the Supplier Performance Risk System (SPRS).  
  • CMMC Level 2, Advanced – Contractors must implement the 110 controls in NIST SP 800-171 and submit an annual self-assessment or, if required to handle (as yet undefined) critical national security information, a triennial independent assessment performed by a CMMC Third Party Assessment Organization (C3PAO). 
  • CMMC Level 3, Expert – Contractors must implement the 110 controls in NIST SP 800-171 and a subset of controls from NIST SP 800-172 before undergoing a triennial government-led assessment.  The DoD, however, is still in the process of developing the requirements for this Level.

CMMC 2.0 will be implemented through the rulemaking process, which the DoD estimates could take anywhere from nine months to two years.  Thereafter, the DoD will begin to incorporate CMMC 2.0 requirements into contracts.  In the meantime, the DoD has suspended its CMMC pilot program and will not approve the inclusion of CMMC requirements in any forthcoming DoD solicitations.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Michael G. Gruden, CIPP/G
Counsel – Washington, D.C.
Phone: +1.202.624.2545

Maida Oringher Lerner
Senior Counsel – Washington, D.C.
Phone: +1.202.624.2596

Evan D. Wolff
Partner – Washington, D.C.
Phone: +1.202.624.2615

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