Defense contractors must immediately prioritize proactive cybersecurity measures as the regulatory environment tightens. Payam Pourkhomami, a leading expert in government contracting, confirms that firms must achieve and maintain stringent DFARS CMMC compliance to remain eligible for Department of Defense (DOD) contract awards.
Contractors often focus on compliance during performance, but the specific provision DFARS 252.204-7025 makes clear that eligibility is determined before the award process concludes. This clause dictates that a potential awardee is ineligible unless they maintain a current Cybersecurity Maturity Model Certification (CMMC) status for all relevant information systems. The clause effectively transforms CMMC from a contractual requirement into a mandatory pre-award gate.
Achieving and Maintaining CMMC Status
To satisfy the stringent requirements of DFARS 252.204-7025, contractors must actively manage two non-negotiable compliance items. First, they must enter their current CMMC status into the Supplier Performance Risk System (SPRS). Depending on the level of sensitive data handled—either Federal Contract Information (FCI) or Controlled Unclassified Information (CUI)—this status reflects successful completion of either a self-assessment (Level 1 and certain Level 2 contracts) or a third-party assessment by a CMMC Third-Party Assessment Organization (C3PAO).
While a certification is valid for three years, a senior company official must file an annual affirmation in SPRS, confirming the organization’s continuous adherence to the security controls defined by the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171.
Second, contractors must submit CMMC Unique Identifiers (UIDs) in their proposals. The DOD requires these 10-character alphanumeric codes, issued through SPRS, for every information system that will process or store CUI or FCI during contract performance. A contractor risks a non-responsive proposal simply by omitting or incorrectly listing these UIDs.
Furthermore, companies must flow down the exact CMMC requirements to subcontractors, ensuring every link in the defense industrial base protects sensitive information. Firms must not rely on the allowance for conditional status (which allows 180 days to close deficiencies) but instead implement robust security controls from the start, recognizing that proactive DFARS CMMC compliance guarantees long-term competitive viability.
