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Contractor Business Systems: Out With the Old, In With the New (Terminology)

Client Alert | 1 min read | 01.21.25

On January 17, 2025, the Department of Defense (DoD) issued a final rule replacing the term “significant deficiency” in the Defense Federal Acquisition Regulation Supplement (DFARS) with the term “material weakness” for use in reviews of contractor business systems.  Effective immediately, a material weakness is defined as “a deficiency or combination of deficiencies in the internal control over information in contractor business systems, such that there is a reasonable possibility that a material misstatement of such information will not be prevented, or detected and corrected, on a timely basis.  A reasonable possibility exists when the likelihood of an event occurring is probable or more than remote but less than likely.” 

This new term aligns with generally accepted auditing standards and clarifies the seriousness of assessed deficiencies in a contractor’s business systems, which include a contractor’s accounting, estimating, purchasing, material management & accounting, earned value management, and property management systems.  We previously reported on the proposed rule here

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Client Alert | 4 min read | 02.21.25

An Un[waiver]ing Commitment to CMMC: The Department of Defense Issues Guidance for Determining Assessment Levels

Amidst a flurry of executive cost-cutting, the Department of Defense’s (DoD) Cybersecurity Maturity Model Certification program—often known just as “CMMC”— appears to be defying the odds and only picking up steam. Marking the first CMMC developments under the new administration, the DoD has published guidance that previews what to expect once CMMC is finalized. These developments suggest that the current administration intends to pick up where it left off, having first introduced the CMMC program during President Trump’s first term....