Why the 48 CFR Update Matters for Defense Contractors
After the Department of War (DoW) (formerly the Department of Defense) officially published the Cybersecurity Maturity Model Certification (CMMC) clause in 48 CFR, it marked a turning point for defense contractors and subcontractors across the supply chain. Now that this clause is in effect, compliance isn’t optional—it’s a contractual requirement under the Federal Acquisition Regulation (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS).
If your organization handles Controlled Unclassified Information (CUI), you must now demonstrate verified cybersecurity maturity—not just promise it. That means your systems, documentation, and security practices must hold up to outside audit.
For small and midsize contractors, this transition can feel daunting. That’s where proactive managed IT security services make all the difference—providing continuous protection, monitoring, and documentation that align with CMMC compliance requirements.
Understanding 48 CFR and the CMMC Clause
48 CFR, or Title 48 of the Code of Federal Regulations, contains the Federal Acquisition Regulations (FAR) and its agency supplements, including DFARS. These regulations govern how the U.S. government acquires goods and services and define what contractors must do to remain compliant.
The new CMMC clause integrates the Cybersecurity Maturity Model Certification framework directly into 48 CFR. It now requires contractors to:
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Demonstrate cybersecurity compliance at a defined CMMC level before contract award.
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Align with either NIST SP 800-171 (for CMMC Level 2) or FAR 52.204-21 (for Level 1).
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Undergo third-party certification or complete annual self-assessments, depending on data sensitivity.
In short, this rule transforms cybersecurity from a best practice into a binding condition of eligibility for defense contracts. It also empowers the DoW to enforce compliance through certified third-party audits rather than self-attestation.
For defense contractors—especially SMBs—now is the time to align systems and policies with these mandates. Partnering with a managed IT security services provider experienced in CMMC and DFARS compliance, like Tower 23 IT, helps you build readiness and maintain audit-proof documentation.
Step 1: Conduct a Comprehensive Gap Analysis
Now that the CMMC rule is in effect, your first step is a full assessment of your current cybersecurity program. Start by benchmarking your current security posture against CMMC 2.0 and NIST SP 800-171. A structured gap analysis identifies weaknesses before they become compliance failures.
Key tasks:
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Review MFA, least-privilege access, and configuration management. Confirm that user authentication, access permissions, and system settings align with current security best practices. Enforce multi-factor authentication (MFA) across privileged and remote accounts to prevent unauthorized access.
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Document system boundaries and data flows. Map how CUI moves through your environment—from creation to storage and transmission. This documentation defines which systems fall within CMMC scope and where additional safeguards are needed.
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Identify and prioritize remediation items. Classify findings by risk and impact. Address critical vulnerabilities first—especially those involving unpatched systems, weak access controls, or insufficient encryption—and establish measurable remediation milestones.
Tower 23 IT’s managed IT security services include detailed readiness assessments and corrective-action roadmaps aligned with CMMC audit standards, giving your organization a clear compliance baseline.
Step 2: Implement or Strengthen NIST 800-171 Controls
Once gaps are identified, begin implementing the technical and procedural safeguards defined in NIST SP 800-171. These controls form the foundation of CMMC Level 2 compliance.
Action items:
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Enforce MFA across all systems. Multi-factor authentication adds an essential layer of identity protection.
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Encrypt CUI in transit and at rest. Use AES-256 for stored data and TLS 1.2 or higher for transmissions.
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Segment networks and apply least-privilege access. Isolate systems containing CUI from general IT environments and restrict access by role.
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Enable centralized logging and change monitoring. Aggregate logs from all critical systems to detect unauthorized activity and deviations from baseline security.
If internal expertise or bandwidth is limited, managed IT security services from Tower 23 IT can configure, monitor, and maintain these controls while providing documentation that satisfies both NIST and DoW auditors.
Step 3: Prepare for Assessment and Documentation Requirements
Under the 48 CFR CMMC clause, contractors must either complete a self-assessment (Level 1) or a third-party assessment (Level 2) before contract award. Documentation is key—if it’s not written, it doesn’t count.
Understanding CMMC Levels:
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Level 1 (Foundational): Applies to contractors handling Federal Contract Information (FCI) and covers 17 basic cyber hygiene practices verified through an annual self-assessment.
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Level 2 (Advanced): Applies to contractors handling Controlled Unclassified Information (CUI) and requires 110 NIST SP 800-171 controls verified by a third-party assessment every three years.
Documentation checklist:
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System Security Plan (SSP)
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Plan of Action and Milestones (POA&M)
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Evidence of continuous monitoring and incident response
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Assessment history and ongoing updates
Tower 23 IT’s managed IT security services team maintains, updates, and audits these documents to ensure compliance with The Cyber Accreditation Body (Cyber-AB) and DoW expectations—saving contractors valuable time during certification.
Step 4: Strengthen Vendor and Supply Chain Security
Your organization’s compliance is only as strong as your weakest partner. CMMC extends responsibility to subcontractors and service providers that handle or store CUI on your behalf.
Best practices:
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Verify DFARS 252.204-7012 compliance for all partners.
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Require CMMC readiness documentation before onboarding vendors.
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Embed cybersecurity requirements in contracts and BAAs.
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Continuously monitor vendor risk and require documentation updates.
Tower 23 IT’s managed IT security services include vendor risk management programs that help defense contractors verify and monitor third-party compliance across the supply chain.
Step 5: Continuous Monitoring and Incident Response with Managed IT Security Services
CMMC certification is not a one-time event—it requires ongoing verification that your controls are effective and up to date.
Key elements:
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24/7 security monitoring with Managed Detection and Response (MDR). Implement continuous threat detection and automated alerting across networks and endpoints.
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Regular log reviews and anomaly detection. Establish consistent review cycles to catch unauthorized access attempts or unusual behavior early.
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Documented incident-response procedures. Define how to detect, contain, and report incidents to the DoD per DFARS 252.204-7012.
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Annual employee training. Keep staff informed about phishing threats, data handling, and emerging attack trends to reduce risk.
Through managed IT security services, Tower 23 IT provides real-time monitoring, incident response, and compliance reporting—ensuring contractors maintain the cybersecurity maturity expected under the new 48 CFR clause.
Turning Compliance Requirements Into a Competitive Advantage
Now that the CMMC rule is active, compliance isn’t a differentiator—it’s the entry point. However, contractors that demonstrate mature cybersecurity programs early gain a measurable competitive edge.
By investing in readiness now, defense contractors can:
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Secure contract eligibility and prevent disqualification under 48 CFR.
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Accelerate certification timelines through audit-ready documentation.
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Reduce cyber risk through continuously monitored environments.
Tower 23 IT supports defense contractors across San Diego, Phoenix, and Tucson with compliance-driven managed IT security services that simplify frameworks like CMMC, DFARS, and NIST 800-171.
Be Prepared for the CMMC Clause
The publication of the CMMC clause in 48 CFR makes verified cybersecurity a contractual requirement. Contractors who act now by assessing, remediating, and documenting their security posture will be ready when auditors arrive.
If your organization handles CUI or works within the defense supply chain, Tower 23 IT’s managed IT security services can help you prepare for certification, maintain compliance, and strengthen cybersecurity across every layer of your business.
