Pentagon's Own Survey Undercuts Its Reasons for Pausing CMMC
Most of the cost of defense cybersecurity compliance sits in the security controls, not in the audit that checks them.
Federal News Network reported internal Defense Department documents on Monday, October 26th. They summarize 997 responses to the department’s request for information on the Cybersecurity Maturity Model Certification program. Respondents said the main cost was meeting the NIST SP 800-171 controls, not the CMMC assessment. They pointed to Microsoft 365 GCC High licensing, dedicated enclaves, and inconsistent guidance on what counts as controlled unclassified information. Based on figures from some respondents, the department put the average CMMC assessment cost at $47,000. Small Business Administration head Kelly Loeffler said in July that complying with CMMC could cost as much as $600,000.
The department suspended Phase 2 on July 13th. That phase would have required third-party assessments starting November 10th. The department gave a review team 75 days to report, and the review has now run past 100 days. A September 3rd memo told contracting officers to remove third-party assessment requirements from contracts. Federal News Network reports that 2,433 companies held Level 2 third-party certifications as of September. The department declined to comment.
The pause removed the audit, not the obligation. Contracts that handle controlled unclassified information still require Phase 1 self-assessments and DFARS 252.204-7012. A self-attested score that overstates what’s in place still carries enforcement risk. Contractors that slowed their 800-171 work during the pause should start with the cost items respondents named: GCC High licensing, enclave scope, and what their managed service and cloud providers actually cover.
Should the Defense Department restart third-party CMMC assessments now that its own survey puts most compliance cost in the NIST controls?