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CMMC Phase II Suspension and Reform Task Force

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The Department of War (DoW) is pausing the rollout of the Phase 2 implementation of CMMC while allowing Level 1 or Level 2 self-assessments to continue to be included in procurement requests. The cybersecurity NIST SP 800-171 Rev 2* requirements outlined in DFARS 252.204-7012 remain in effect. Cybersecurity compliance will continue to be enforced through self-assessments and select government-led assessments. See the press release here: https://www.war.gov/News/Releases/Release/Article/4542329/forging-the-arsenal-of-freedom-department-of-war-suspends-cmmc-phase-ii-require/ and news coverage: https://defensescoop.com/2026/07/13/dod-halts-cmmc-cybersecurity-requirements-phase-2/ 

DoW is seeking feedback from industry by establishing a Cybersecurity Maturity Model Certification (CMMC) Reform Task Force to gather feedback about reducing compliance costs and administrative burdens while protecting federal data and strengthening operational resilience. A Request for Information (RFI), distributed on July 13th, seeks responses before August 14th to help shape the future of cybersecurity and the operational resilience of the Defense Industrial Base (DIB). To see more about how to respond to the RFI, view the announcement on SAM.gov: https://sam.gov/workspace/contract/opp/89ef9bfb0834473791e991c712698d94/view

For more information on how to comply with CMMC and upload your SPRS Score (which still matters), leverage Project Spectrum training at https://www.projectspectrum.io/ and check out the DoW Chief Information Officer website for additional resources: https://dowcio.war.gov/

 

Footnote:

*NIST SP 800-171 Rev 3 will eventually be adopted into DFARS – learn more here: https://www.governmentcontractslaw.com/2025/04/the-prestige-dod-unveils-nist-sp-800-171-revision-3-organizationally-defined-parameters/

 

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CLIENT ALERT: EDWOSB DATA CALL WITH DEADLINE

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EDWOSBs PAY ATTENTION! Check your email for a data call. SBA is reviewing EDWOSB Program participants for eligibility. Please note you must reply by the 20 day deadline by filling out a survey and uploading copies of your personal and business tax returns for the last three years by replying to the message SBA sent in MySBA Certifications. Here’s a copy of a recent notice that some of our clients received:


 

Dear EDWOSB Participant,

Pursuant to 13 C.F.R. § 127.400, SBA is conducting a program examination to verify that your firm continues to meet the requirements of the Economically Disadvantaged Women-Owned Small Business (EDWOSB) program. Specifically, SBA will be verifying that your firm continues to meet the requirement that the woman or women that own at least 51% of the firm are economically disadvantaged, as set forth in 13 CFR 127.203. In order for SBA to conduct this review, you will need to provide personal financial information and copies of your personal and business tax returns for the last three years.

What is a Program Examination?
A program examination is an investigation by SBA officials or authorized third-party certifiers that verifies the accuracy of any certification of a concern issued in connection with the concern’s WOSB or EDWOSB status, as set forth in 13 CFR 127.402.

How do I respond?
You must submit your response within 20 calendar days of receipt of this notice, July 1, 2026.
To respond, complete these two steps:
1. Respond to the economic disadvantage questionnaire available at https://www.surveymonkey.com/r/ProgramExamination.

2. Securely transfer copies of your personal and business tax returns for the last three years by replying to the message SBA sent you today in MySBA Certifications. For instructions on locating the message, see How do I Check Messages in MySBA Certifications?

3. Please ensure that all personal and business tax documents you transfer are not password protected.

4. Please include a brief text description of the documents you have included in your response message in MySBA Certifications.

Alternatively, you may choose to voluntarily withdraw from the EDWOSB program. Refer to this user guide: User Guide: Voluntary Certification Withdrawal.

New to MySBA Certifications?
Before you’re able to respond to the Program Examination RFI, you’ll need to create an account, claim your business and complete your ownership and control application in MySBA Certifications. For step-by-step instructions, refer to these user guides: MySBA Certifications Knowledge Base.

What Are the Possible Outcomes of a Program Examination?
There are two possible outcomes of a program examination:
1. If SBA determines that the firm continues to meet program eligibility requirements, SBA will provide a written notice of continued certification in your firm’s record within MySBA Certifications, and the firm will maintain its certified EDWOSB status in SBS.

2. If you fail to submit your program examination response within the required timeframe or SBA determines the firm no longer meets program eligibility requirements, SBA will notify you that your firm has been proposed for decertification from the EDWOSB program in accordance with 13 CFR 127.405. This notice will state the reasons why SBA has proposed decertification, and that the firm must respond to each of the reasons set forth. The firm must respond in writing to a proposed decertification within 20 calendar days from the date of the proposed decertification. SBA may draw an adverse inference from the failure of a firm to cooperate with a program examination or provide requested information.

Support
• For any technical support questions in using the MySBA Certifications system, contact Small Business Certifications Service Desk.
• For any program examination questions, contact the Office of Government Contracting & Business Development Help Desk at certifications@sba.gov or 866-SBA-HELP (866-722-4357) mailto:certifications@sba.gov

Sincerely,

Compliance Division
Office of Government Contracting and Business Development
U.S. Small Business Administration

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Boosting Small Manufacturers

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May 12, 2026 update from our friends at the DoW OSBP:

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SBA Launches Enhanced Loan Guarantee Program for Eligible Manufacturers

Small business manufacturers have a new opportunity to access capital and scale their operations through the U.S. Small Business Association’s (SBA) “Made in America Loan Guarantee” program. This initiative is designed to help small businesses expand facilities, hire workers, and increase production—key steps in strengthening both domestic manufacturing and national security. Starting May 1, 2026, eligible manufacturers across NAICS Sectors 31–33 may use the funds to:

  • Upgrade or replace equipment to improve productivity and reduce unit costs.
  • Modernize facilities and production lines to meet customer and national security requirements.
  • Diversify supply chains away from foreign adversaries and bring critical production back to the United States.
  • Build more resilient inventory positions.
  • Expand operations and capacity through strategic acquisitions.

By reducing lender risk, the loan guarantee can improve access to financing for small manufacturers looking to modernize operations, invest in equipment, or meet increasing demand tied to government and defense needs. When paired with efforts like the Civil Reserve Manufacturing Network, this loan guarantee creates real pathways for small manufacturers to scale, compete, and deliver for the warfighter.

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Note from your local APEX Accelerator: We recommend working with your local SBDC counselor to answer your small business loan and finance questions as APEX Accelerators do not handle loan questions but we thought this was relevant to our manufacturer clients. If you don’t have an SBDC counselor you can find yours here: https://www.sba.gov/local-assistance/resource-partners/small-business-development-centers-sbdc

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Share Your Story: DoW Industry Insights Series Invitation (deadline 3/31/2026)

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A message from the U.S. Department of War:

Greetings,

The Department of War Office of Industrial Base Growth is inviting small businesses, new entrants, and nontraditional suppliers to share how they are supporting mission success.

If your company provides innovative technology, strengthens supply chains, or delivers specialized services that support Department or national security priorities, we encourage you to participate in the DoW Industry Insights Series: Seeking Small Businesses and Nontraditional Supplier Stories.

This is an opportunity to share the real-world impact of your work and ensure decision-makers understand the vital role small and emerging businesses play in supporting the warfighter.

The form requests basic company information along with a brief description of how your product or service supports the Department. Responses should be clear and concise.

You can access the form here:
https://forms.osi.apps.mil/r/Z07nrmRsEX

Deadline to participate: March 31, 2026

Please note: This is an unclassified data call. Do not include Controlled Unclassified Information (CUI), proprietary data, export-controlled information, or any other sensitive or restricted content in your response.

We look forward to learning more about the important work you’re doing.

Respectfully,

Office of Industrial Base Growth
U.S. Department of War
https://business.defense.gov
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About:

The Office of Industrial Base Growth serves as the Department’s umbrella organization for efforts focused on expanding and strengthening the defense industrial base through vendor growth and supplier maturity. Its work increases competition, builds capacity, and creates clearer pathways for businesses to enter and succeed in the defense marketplace.

Many of you know the Office of Small Business Programs, or OSBP, which remains a vital and unchanged part of the broader organization. Its mission and services continue to grow. The name “Industrial Base Growth” reflects the full scope and strategic importance of the work already underway to expand the industrial base for companies of all sizes, while dedicated small business-specific support and programs remain firmly in place.

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Client Alert: 8(a) participants notified by SBA to provide financials

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On December 5th, the SBA notified all 4,300 8(a) participants they are mandated to provide financial documents for the last three fiscal years before January 5th, 2026 (Note this deadline has been extended to January 19, 2026) or they “may lose their eligibility to participate in the 8(a) Program and could face further investigative or remedial actions.” Please note this is part of an audit to expose fraud, waste, and abuse. We want to make sure our clients don’t miss this request and are able to respond in a timely manner. Read more directly from the SBA’s news release here: https://www.sba.gov/article/2025/12/05/sba-orders-all-8a-participants-provide-financial-records and respond with the information requested in their official notice.

 

Additional resources:

Note: Q&A was published and updated on December 18th by the SBA which also extended the deadline to January 19, 2026.

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Share Your Feedback on DoD Cybersecurity Requirements before November 9th

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The Department of Defense (DoD) Office of Small Business Programs (OSBP) is seeking input from small businesses like yours to better understand how companies are preparing for the implementation of Cybersecurity Maturity Model Certification (CMMC) requirements, which begin appearing in DoD contracts starting November 10, 2025.

Your voice is critical in helping the DoD keep informed about the real-time impact on small businesses so they can tailor the resources, support, and guidance during the transition. We encourage you to take just a few minutes to complete this short, anonymous survey:

Survey Link: https://forms.osi.apps.mil/r/Kj8RFat4A8

The survey explores your current readiness, concerns, challenges, and efforts related to CMMC compliance. Your responses will help ensure that the support small businesses receive is relevant, timely, and aligned with real-world needs. Feedback is due November 9.

Participation is completely voluntary, and you may choose to provide contact information if you’d like to stay informed or receive follow-up from the DoD OSBP team.

Thank you for taking the time to contribute to this important effort and for your continued role in supporting the defense industrial base.

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Strategy for Modernization of the Defense Industrial Base (DIB)

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Please follow this link to learn more about the Department of Defense strategy for modernization of the Defense Industrial Base (DIB). Released in 2022, the 2022 National Defense Strategy (NDS), is a plan to catalyze generational change from the existing defense industrial base to a more robust, resilient, and dynamic modernized defense industrial ecosystem. This document outlines a comprehensive plan that aligns with the strategic vision of the NDIS by both addressing consequential risks in critical areas and presenting six key DoD leader-driven initiatives to mitigate the risks and shift the strategy from vision to a fortified reality. If you are already part of the DIB, or aspire to be, this is critical information for you and your organization.

https://www.businessdefense.gov/NDIS.html?bbeml=tp-sOPCAsgj7kixPqV475FvCA.ja0eCQEu0vEG13R3HWirJzg.rEgxRSNUAA0SrfXkI1Q2Y4w.l9QgvHpEzzUq9UU64BuXlVw

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Final DFAR Supplement Rule Implementing the CMMC Program Announced

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On September 9, the Department of War (DoW) released the final DFARS rule implementing the CMMC Program as described at 32 CFR 170.3 for public inspection in the Federal Register. The final rule will ensure DoW procurements will include CMMC assessment requirements that ensure defense contractors properly safeguard the Department’s Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). The CMMC program will provide a consistent methodology for assessing compliance with DoW’s cybersecurity requirements.

The Federal Register Notice is available for public inspection at the following location: https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of

An introductory course about the CMMC program is available to both Government and industry at: https://www.dau.edu/courses/cyb-1010

Additional information on the CMMC Program can be found at: https://dodcio.defense.gov/CMMC/

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Crater APEX Accelerator Changes

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The Virginia APEX Accelerator will begin covering an additional 26 counties/jurisdictions of Virginia starting April 1, 2025 so be on the lookout for updated coverage areas on our website locations page as we implement these changes. These counties were formerly covered by the Crater APEX Accelerator, which is closing its doors on March 31, 2025. The Crater team will become part of our team and we are excited to have them on board. Existing clients of Virginia APEX Accelerator should see no impact to services and new registrants in the affected area should follow the below links for registration. All active clients at Crater affected by this change will continue to be served and will receive further guidance from their counselors along with updated counselor contact information.

Counties now covered by SWCC APEX Accelerator: Henry County and Martinsville City

Counties now covered by Virginia APEX Accelerator: Buckingham, Cumberland, Amelia, Prince Edward, Charlotte, Halifax, Pittsylvania, Danville, Franklin, Nottoway, Lunenburg, Mecklenburg, Chesterfield, Powhatan, Goochland, Hopewell, Colonial Heights, Prince George, Petersburg, Dinwiddie, Brunswick, Charles City, Surry, Sussex, Emporia and Greensville.

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Key Technology Areas

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The Department of Defense is interested in small businesses engaged in key technology areas. If you are currently working in these mission critical areas, please reach out to your counselor or apex@gmu.edu so we may include your core competencies into our database. This information is only for DoD use, please review the document and determine if you have capability and/or capacity in these areas: https://virginiaapex.org/wp-content/uploads/2024/12/Key-Technology-Sub-Areas-for-DoD-Industry-Survey.pdf

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