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One week after the CMMC pause: shape what comes next

The short answer

Small-business voices drove the suspension, and comments will shape the reform Submit RFI responses by noon ET Aug 14, 2026 Keep meeting NIST 800-171/DFARS 7012; SPRS affirmations carry more legal weight

A pause symbol beside a comment bubble

One week ago I posted that CMMC Phase 2 is suspended, but NIST 800-171 is not.

A week of reaction later, that message matters more, not less.

The Defense Industrial Base has split into two camps. One camp is relieved, and that relief is hard-earned. The cost and the assessor shortage made the November timeline unworkable for small and mid-sized contractors. The other camp is sounding the alarm: a pause is not a repeal, the 60-day review could land anywhere, and DoW leadership has not ruled out ending the program entirely.

Both camps are right about the thing that matters most. None of us knows what is coming.

But notice how we got here, because it changes what you do next. This suspension did not fall out of the sky. The DoW CIO acted after the SBA raised the alarm, and the SBA raised it because small and mid-sized businesses said, plainly and repeatedly, that the process had become untenable. Voices moved policy.

Which is why the next 60 days are not a spectator sport. DoW has opened a public comment period through its RFI, and the reformed program will be shaped by whoever weighs in. The submission is simpler than most assume: you email your response, and the RFI lays out the format and the seven questions. Read it and follow the instructions in the DoW CIO Library: https://lnkd.in/eCj-uh8j. Responses go to wh****************************************@**il.mil and le******************@**il.mil by 12:00 PM ET on Friday, August 14, 2026.

So here is the balance. We cannot predict what the task force delivers, but we can influence it, and we can control our own readiness meanwhile. Two levers are within reach: send the comment, and keep meeting the law already on the books. NIST 800-171 still applies. DFARS 252.204-7012 still binds you. Your SPRS score and your annual affirmation are still on the record, and the legal weight behind that affirmation went up the moment the third-party assessor stepped away.

Shape what is coming. Build toward what already exists. That is the only posture that pays off no matter which way the review lands.

The record closes at noon on August 14. After that, the task force writes the future of this program from the comments before them. If your firm's name is not on one of them, you did not lose the argument. You forfeited it.

#CMMC #NIST800171 #GovCon #DFARS #DIB The Vizius Group

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