September 2, 2025

CMMC Implementation Rule Clears Final Review

Last Friday's edition of Open DFARS Cases broke the news that the 48 CFR rule, which will implement the CMMC program via contract clauses, cleared final review by OIRA on August 25.

What's the next step? The rule will be published within 1-3 weeks from the date it cleared review.

What does this mean? The rule will take effect between 1-60 days from the date of publication, marking the beginning of Phase One of the Phased Rollout of the CMMC Program. At that point, all DoD contracts will have these new CMMC clauses included by default.

What should you do? I've been saying it for five years, and seriously, there's no getting around it: The Time to Prepare is Now. Even self-assessment under CMMC is a rigorous process, requiring perfection and proof of perfection even for Level One. Most orgs require 4-6 months to prepare for Level One, 12-18 months to reach Level Two.

Don't panic, but do ask for help.

My Next Virtual Workshop Sep 9

You passed the readiness-pre-check, and the official assessment has been scheduled ...

Use code "CMMCUpdate" to get 20% off!

Hope to "see" you there!

Sincerely,

Glenda R. Snodgrass, CCP/CCA/Lead CCA
grs@theneteffect.com
The Net Effect, LLC
www.theneteffect.com
251-433-0196 x107