Comments on CMMC Contract Clause must be submitted by October 15, 2024.

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Key Information on CMMC Contract Clauses and Comment Period

The Department of Defense (DoD) is set to implement new contract clauses under the Cybersecurity Maturity Model Certification (CMMC) Program, with the comment period closing on October 15, 2024. Contractors will be required to maintain compliance with applicable controls throughout contract performance and notify contracting officers of any system changes. The DoD may issue final rules relating to both the CMMC program and contract clauses later this year or in early 2025.

The proposed contract clauses include requirements such as entering CMMC certificate or self-assessment results into the Supplier Performance Risk System (SPRS) at the specified CMMC level, affirming continuous compliance for contractor information systems handling federal contract information (FCI) or controlled unclassified information (CUI), and notifying contracting officers of any changes in these systems during contract performance.

Interested contractors are encouraged to submit their comments on the Proposed Rule by the deadline. DoD will review and adjudicate each comment before issuing the final rule. The final rules may be released later this year or in early 2025, marking the beginning of the CMMC program rollout.

Stay tuned for updates on the implementation of the CMMC Program and its impact on contractors in the defense industry.

Dr. Rafael Marrero
A nationally recognized expert in federal contracting, small business entrepreneurship, vendor, and project/program management. A graduate of the prestigious Stanford and Cornell Universities, Dr. Rafael Marrero is a former Fortune 500 procurement executive, two-time Inc. 500 honoree, network news commentator, and Amazon best-selling author.

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