CMMC Phase 2 is paused. False Claims Act exposure isn't.
On July 13, 2026, the Department of War suspended CMMC Phase 2, and a revised class deviation on September 3 moved contracting officers to self-assessments. DFARS 252.204-7012, your SPRS score and NIST SP 800-171 still bind you. On September 1, 2026, Honeywell Aerospace agreed to pay $2,042,518 to resolve allegations of NIST SP 800-171 noncompliance. We review whether your self-attestation would hold up.
CMMC L2 Defensibility Review
- Evidence sampling across the 110 NIST SP 800-171 Rev 2 controls, against your SSP and POA&M
- SPRS score substantiation: can each point you claimed be shown to an assessor, or to a whistleblower's lawyer?
- DFARS 252.204-7012 incident readiness: 72-hour reporting, media preservation, FedRAMP Moderate equivalency for cloud services
- A False Claims Act risk memo written for outside counsel, under privilege where counsel directs
- Active U.S. security clearance
- DoD Defense Innovation Unit program work
- CMMC Level 2 and NIST SP 800-171 readiness delivered for defense-sector clients
RedOps prepares you and produces evidence; a C3PAO issues any certification.
What changed in 2026.
LOGZONE Inc. settles False Claims Act allegations for $507,144. A DIBCAC (DCMA) assessment had scored it −170 against a self-reported 110.
Department of War CIO suspends CMMC Phase 2 and stands up a 60-day Reform Task Force.
Honeywell Aerospace False Claims Act settlement, $2,042,518, over NIST SP 800-171 noncompliance.
Class Deviation 2026-O0025, Revision 3: contracting officers accept Level 1 and Level 2 self-assessments and remove third-party requirements at the next option or modification.
Reform Task Force report to the DoW CIO and USD(A&S). The 60-day review ended Sept 11; the report is not yet public.
Last reviewed 2026-10-13
Get a straight answer in 20 minutes.
Tell us about the contract: your SPRS score, a prime's flowdown, a DFARS 7012 question, or a self-attestation you'd like checked before someone else does. You'll leave the call with a recommended scope, and a written proposal follows within two business days.