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The “Prestige”: DoD Unveils NIST SP 800-171 Revision 3, Organizationally Defined Parameters

On April 15, 2025, the Department of Defense (DoD) released official guidance on Organizationally Defined Parameters (ODPs) appearing in the newly published NIST SP 800-171 Revision 3. At the same time, the DoD reaffirmed...more

Tariffs, Leprechauns, and Contract Gold: Navigating the Hidden Costs of Trade Policies

As St. Patrick’s Day approaches, many of us are on the lookout for four-leaf clovers, a pot of gold, or perhaps even a mischievous leprechaun guarding his treasure. But in the world of government contracting, the real...more

Whisper Through the Screams: DOJ Commits to False Claims Act Enforcement in 2025

Amid the chaos of the past few weeks—sweeping executive orders, relentless cost-cutting, and an air of uncertainty that lingers like smoke after a fire—federal contractors have been left reeling, straining to hear what comes...more

They Did It. They Really Did It! The Arrival of the FAR CUI Proposed Rule

After years of anticipation, the Federal Acquisition Regulation (FAR) Council has announced the arrival of its proposed rule to enhance the safeguarding of Controlled Unclassified Information (CUI) in federal contracts (the...more

A Standard on Many Levels: A Look at CMMC 2.0 in Final

Over the course of the past few years, gallons of ink have been spilled addressing the seemingly ever-pending US Department of Defense’s (DoD) Cybersecurity Maturity Model Certification (CMMC) Program. After keeping us...more

DOJ Went Down to Georgia: Lessons Learned from Recent Cybersecurity Enforcement Actions

Some might say there’s little difference between dealing with the devil and being a federal contractor. And for the unwary or unprepared, that may not be far off. Federal contracting comes with a litany of “fine print” that...more

NIST SP 800-171 Revision 3 Goes Final: Who’s Down with ODP?

On May 14, 2024, the National Institute of Standards and Technology (NIST) dropped the third remix…er, revision…of its Special Publication (SP) 800-171, “Protecting Controlled Unclassified Information in Nonfederal Systems...more

DoD’s Proposed CMMC Rule: Groundhog Day… or a Final Rule in the Works?

On December 26, 2023, the Department of Defense (“DoD”) belatedly gifted defense contractors and subcontractors a Proposed Rule on the Cybersecurity Maturity Model Certification (“CMMC”) Program. DoD also released eight CMMC...more

DoD Mentor-Protégé Program Solidified under Proposed Rule

On October 25, 2023, the Department of Defense (DoD) published a Proposed Rule amending the Department of Defense Federal Acquisition Regulation Supplement (DFARS) and permanently authorizing the DoD Mentor-Protégé Program...more

CMMC 2.0: Throwback Cybersecurity — Everything Old Is New Again

After months of review, on November 4, 2021, the Department of Defense (DoD) finally unveiled its new version of the Cybersecurity Maturity Model Certification (CMMC 2.0). Well, almost. In a blink-and-you’ll-miss-it moment,...more

The Clauses Implementing Vaccination Mandate for Federal Contractors Are Out—Key Considerations for Contractors

Four memoranda, released in the last several business days, provide federal contracting officers guidance and suggested clauses to implement President Biden’s Executive Order 14042 (the Executive Order) in federal contracts...more

Enough’s Enough: A New Executive Order Signals Sweeping Changes To Federal Cybersecurity Requirements

Akin to the exasperations of the newly minted “homeschool teachers” the pandemic has created, the Biden administration’s recent Executive Order on Improving the Nation’s Cybersecurity (Order) is a mix of sound logic and utter...more

The FAR Council’s Second Interim Rule Implementing NDAA Section 889(a)(1)(B): And The Hits Keep Coming!

Like the hits produced by DJ Khaled, the FAR Council offers “another one.” As covered extensively in this blog, federal contractors have been—or should have been (you have been working toward compliance, haven’t...more

The Perils Of Section 889 Part B Execution: The DoD Waiver

When last we left the Federal Government, agency buyers were staring down the Interim Rule prohibiting them from contracting with entities that use “covered telecommunications equipment” under Section 889(a)(1)(B) (“Section...more

DoD CARES After All – New Cost Principle and DFARS Clause Implements CARES Act For Certain COVID-19 Costs

On April 8, 2020, the Department of Defense (“DoD”) issued a Class Deviation authorizing contracting officers to use a new cost principle – DFARS 231.205-79, CARES Act Section 3610 Implementation – to permit the reimbursement...more

Cybersecurity Maturity Model Certification (CMMC) Version .6: Another Step On The Department Of Defense’s Long And Winding...

There’s an often mistranslated Taoist adage that counsels “A journey of a thousand miles begins with a single step.” So it is presently with the Department of Defense’s (DoD’s) Cybersecurity Maturity Model Certification...more

Integrating Cybersecurity Into M&A Compliance Reviews: Avoiding Hidden Cyber Risks In The Acquisition Of Government Contractors

So you want to acquire a government contractor? Makes sense, and you’re not alone. Over the past few years, the federal contracting landscape continues to evolve as a result of mergers and acquisitions (M&A), primarily...more

Never Stop Never Stopping: Defense Department Quietly Unveils Proposed Cybersecurity Capability Model Certification Standards And...

Cybersecurity. It’s never over, is it? In what can only be described as a “soft” release, the Department of Defense (DoD) has slowly and quietly begun to reveal its intent to provide federal contractors with formal...more

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