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On October 22, 2024, the Department of Justice (“DOJ”) announced that Pennsylvania State University (“Penn State”) has agreed to pay $1,250,000 to settle a False Claims Act (“FCA”) case brought against the University approximately two years ago. The whistleblower in the case, former chief information officer of the Penn State Applied Research Laboratory, alleged that Penn State failed to comply with cybersecurity requirements in fifteen contracts and/or subcontracts with the Department of Defense (“DoD”) and National Aeronautics and Space Administration (“NASA”) between 2018 and 2023.Continue Reading Update – Penn State to Pay Up for Cyber-Related FCA Case

On October 15, 2024, the Department of Defense (“DoD”) published the final version of its Cybersecurity Maturity Model Certification (“CMMC”) rule in Title 32 of the Code of Federal Regulations (the “Final Rule”). (Reminder, there are two CMMC rulemakings going on in parallel. This Final Rule updates DoD national security regulations while the other rulemaking effort under Title 48 will update the Defense Federal Acquisition Regulation (“DFARS”) and trigger requirements for DoD contractors.)Continue Reading Countdown to Compliance: DoD Finalizes the CMMC Program Rule

Well, the wait is over. Just as 2023 came to a close, on December 26, 2023, the Department of Defense (“DoD”) published the much-anticipated Proposed Rule for the DoD’s Cybersecurity Maturity Model Certification (“CMMC”) program (the “Proposed Rule”). It has been just over two years since “CMMC 2.0” was announced in November 2021 (which we previously discussed here). And while there is nothing particularly surprising in the Proposed Rule, there certainly are several notable additions and clarifications. Below we outline the key portions of the Proposed Rule that will be of particular importance to defense contractors.Continue Reading New Year, New Rules: The CMMC Proposed Rule is Here