Countdown to CMMC: What Defense Contractors Need to Know Before the Rule Is Finalized

Christopher Souza | CEO

Summer might be right around the corner, but defense contractors can’t afford to put compliance on the back burner. The Department of Defense (DoD) is in the final stages of releasing the long-anticipated Cybersecurity Maturity Model Certification (CMMC) rule under 48 CFR, and according to Deputy DoD CIO David McKeown, the rule is now under review by the DFARS Regulatory Control Officer (RCO)—the final internal DoD checkpoint before advancing to the Office of Management and Budget (OMB) for final review and publication.

Considering the average organization takes 12–18 months to fully implement the controls outlined in NIST SP 800-171 and become CMMC-ready, waiting for the final rule to drop is no longer a viable strategy. Defense contractors must act now to finalize and execute their compliance implementation plans if they want to stay competitive—and contract-eligible.

Anticipated CMMC Rulemaking Timeline:

• DFARS RCO Review: 2-4 Weeks
• OMB Review: 60-120 Days
• Expected Rule Publication: Fall 2025

While these are estimates, it’s important to note that once the rule is published, there will be no lengthy grace period—CMMC requirements will begin appearing in solicitations shortly after publication. The clock is ticking.

Why Delaying Puts You at Risk

Once CMMC becomes a contractual requirement, organizations that delay are at serious risk of:

• Being caught in the inevitable C3PAO backlog
• Missing out on revenue-driving federal contracts
• Facing pressure to implement controls rapidly—and inefficiently
• Incurring legal liability under the False Claims Act for misrepresenting compliance

There are currently only a limited number of certified C3PAOs and registered RPOs, and demand will surge dramatically once the rule is finalized. Late adopters will likely find themselves scrambling for help—and paying more for it.

What We’re Seeing in the Field

Recent CMMC-focused events and DoD updates have spotlighted emerging compliance trends and risks:

• SPRS Score Screening Is Already Happening: Contracting officers are informally using ~80-point SPRS score thresholds to screen out vendors lacking basic compliance readiness.
• Perfect Scores Invite Scrutiny: A perfect 110 SPRS score submitted without a formal third-party assessment or POA&Ms can trigger audits and investigations.
• False Claims Act Enforcement Is Increasing: The DoD has signaled it will use the False Claims Act to hold contractors accountable for falsely attesting to NIST 800-171 compliance—even retroactively. Whistleblowers have financial incentives to report noncompliance.
• POA&Ms Will Be Time-Bound: The upcoming rule is expected to place strict time limits on open POA&M items and may require certain high-priority controls to be fully implemented before a contract is awarded.

How TSI Can Help

Don’t wait to act. TSI is a CMMC-AB Registered Provider Organization (RPO) and a C3PAO-assessed MSP/MSSP, uniquely positioned to help your organization become CMMC-ready—before the rush. We support defense contractors by providing:

• CMMC gap assessments
• Implementation of all 110 NIST 800-171 control requirements
• Audit-ready documentation (SSP, POA&M, policies)
• Accurate SPRS score calculation and submission
• Strategic support to close compliance gaps cost-effectively and on time

The Window to Prepare is Closing

Whether you’re starting from scratch or need support refining your current security posture, TSI is ready to help you navigate CMMC with clarity, urgency, and confidence. Contact us today or visit our CMMC services page to learn more about how we can help your organization.

About Technical Support International

TSI is 36-year old cybersecurity (MSSP) and IT support (MSP) company specializing in helping DIB organizations address their NIST 800-171 and CMMC compliance obligations. As a CMMC-AB Registered Provider Organization (RPO), TSI offers a complete NIST 800-171 and CMMC support solution to help guide our clients toward a successful certification audit and provide the assurance that they’re adhering to these expansive compliance requirements.