The Office of the Under Secretary of Defense for Acquisition and sustainment (OUSD(A&S)) does not intent to approve inclusion of a CMMC requirement in any contract prior to completion of the CMMC 2.0 rulemaking process.
Once CMMC 2.0 is codified through rulemaking, the department will require companies to adhere to the revised CMMC framework according to requirements set fourth in regulation.
If contractors and subcontractors are handling the same type of FCI and CUI, then the same CMMC level will apply. In cases where the prime only flows down select information, a lower CMMC level may apply to the subcontractor.
Any organization in the DoD supply chain that contains federal contract information (FCI) or CUI controlled unclassified information (CUI) will have to comply with CMMC standards. Organizations that only have access to FCI will need to comply at Level 1, whereas organizations with access to CUI will have to comply at Level 2 or 3.
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