Episode Details
Back to EpisodesCMMC Phase 2 Paused: Why the DoD's Reasoning Doesn't Add Up, and What to Expect After the 60-Day Review
Description
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The Department of War's pause on CMMC Phase 2 sparked a wave of panic, and a wave of misinformation right behind it. In this episode, Stacey and Brooke go deeper than the headline: what the pause actually changes, why the stated justification (cost, assessor capacity) doesn't hold up against the numbers, and what's realistically likely to come out of the 60-day review.
In this episode:
- What "Phase 2 is paused" actually means (it's the third-party certification requirement on new contracts, not your obligation to be compliant)
- The biggest misconception floating around: "CMMC is suspended" vs. what's actually true
- Why the capacity argument (claims of "only 100 assessors") doesn't match reality (there are over 1,000 CCAs)
- Why the cost argument conflates "cost of certification" with "cost of actually being compliant," which have always been expensive
- Why self-assessments may face MORE scrutiny, not less, while third-party validation is paused
- Historical precedent: every incoming DoD/DoW CIO has paused and retooled this program since 2021, and it's never been canceled
- What to actually do this week if you're mid-remediation, mid-contract, or have a mock or certification assessment already scheduled
- The open RFI (Request for Information) the DoD posted, and why submitting a response matters
- Justice IT Consulting's own CMMC Level 2 certification news
The mark-your-calendar date: September 14th is when the 60-day window closes and we should learn more about what comes next.
Read the actual DoD memo here: https://federalnewsnetwork.com/wp-content/uploads/2026/07/CIO-CMMC-Reform-Memo_26-P-1023.pdf?hss_channel=lcp-348902
Submit your own response to the DoD's RFI here: https://sam.gov/workspace/contract/opp/89ef9bfb0834473791e991c712698d94/view