The CMMC Pause Leaves Contractors With Hidden Exposure

The Pentagon’s suspension of CMMC Phase II third-party assessment requirements isn’t a pass to relax. Rather, it’s an exposure shift. While mandatory C3PAO certifications are still on hold following the Department of War’s class deviation, Phase I self-attestation requirements remain fully active.

Without third-party assessors acting as a buffer, the legal weight of your internal self-assessment just multiplied. The CMMC pause removed an audit bottleneck, not your legal obligation to secure controlled unclassified information (CUI).

What hasn’t changed with CMMC

First, a quick summary of what hasn’t changed:

• CMMC Phase I remains: Self‑attestation of compliance with NIST SP 800‑171 Rev. 2 continues to be required where DFARS 252.204‑7012 applies. The 110 controls outlined in NIST SP 800-171 remain the definitive legal baseline for any organization that processes or stores CUI.
• Prime contractor enforcement continues: Independent of the DoW’s action, primes can still require CMMC Level 2 C3PAO assessments via supply chain clauses. You still have to comply with flow-down contracting requirements and submit SPRS scores or risk losing your contracts.
• Supplier Performance Risk System (SPRS) scores carry increased accountability: Without a third-party check behind your submittal, internal representations entered into federal databases carry greater legal weight. Misreported postures increase exposure under the False Claims Act if a contractor claims compliance without real control validation.

The hidden threat: increased False Claims Act (FCA) exposure

The Department of Justice doesn’t distinguish between a false third-party certification and a false self-attestation. Misreporting compliance posture — even unintentionally — opens contractors to severe FCA enforcement, whistleblower suits, and contract forfeiture. In a self-attestation world, your FCA exposure has gone up, not down.

Three steps defense contractors should take now

During our webinar, Beyond the Pause: How Defense Contractors Can Master CMMC Readiness, industry experts shared actionable steps to maintain a defensible posture: 

• Prepare for NIST SP 800-171 Rev 3: Begin incorporating the newly introduced organization-defined parameters (ODPs) from Rev 3 into your Rev 2 implementation to tailor controls to specific operational technology (OT) and information security needs. 
• Execute a mock assessment: Similar to a third-party assessment, a mock assessment will tell you what failed and why. Mock assessments are less expensive as they do not require certification costs, such as eMASS submission. Prime contractors are increasingly accepting mock assessment documentation in lieu of formal third-party audits.
• Build an audit-ready trail: Document assessment methodology, continuously validate operational evidence, and verify that written policies reflect day-to-day operations.

Hyperproof: a protected cloud environment and a solution for CMMC readiness

Under DFARS 252.204-7012, cloud platforms used to store or process CUI — including your GRC software — must meet FedRAMP Moderate/Class C standards.

Hyperproof Gov operates on a FedRAMP Certified Class C (Rev5) infrastructure, giving defense contractors a secure environment to centralize compliance. Hyperproof streamlines your entire CMMC workflow by providing:

• Automated SPRS scoring: Calculate and update scores dynamically based on real-time control health.
• System Security Plan (SSP) management: Automatically generate and update required compliance documentation.
• Continuous evidence mapping: Map controls across multiple frameworks to eliminate duplicative evidence collection.

To learn more from experts at Aprio, Choice Cyber Solutions, and Hyperproof about how you can navigate the CMMC pause, watch the webinar replay.