The CMMC Phase II suspension does not answer every question about a specific solicitation or signed contract. Identify the assessment designation, read the implementation direction, and find the amendment or modification that applies to your procurement.
Reviewed September 13, 2026: the official CMMC page continues to state that Phase II is suspended and Phase I self-assessment requirements remain in place. This page follows the published implementation direction; a later program announcement or procurement change requires another review.
What the implementation memo directs
The implementation memorandum, attachment pages 2–3, allows requiring activities to designate Level 1 (Self) or Level 2 (Self) during the suspension. It prohibits designating Level 2 (C3PAO) or Level 3 (DIBCAC) in that period.
For active solicitations containing the latter requirements, it directs an amended requirements document and a corresponding solicitation amendment as soon as practicable. For existing contracts or agreements, it directs removal by modification before the next option period or during the next scheduled administrative modification.
That is a document-change process. Do not treat an announcement, a direction to acquisition staff and a completed modification as the same record.
Identify which situation you are in
| Situation | What to obtain or confirm |
|---|---|
| Active solicitation states Level 2 (C3PAO) or Level 3 (DIBCAC) | The corresponding amendment, or a written question about its status and the interim instruction |
| Active solicitation states Level 1 (Self) or Level 2 (Self) | The actual level, system scope, timing and other package requirements |
| Signed contract contains a designation covered by the removal direction | Modification status, next option timing and the contracting authority’s interim instruction |
| Subcontract contains a fixed designation | The prime’s direction and the subcontract change, if applicable |
| Package has a blank or inconsistent insertion | Clarification of the intended designation and checkpoint |
Do not resolve a blank level field by assuming it means “no requirement.” Do not change “Level 2” into “Level 2 (Self)” unless the actual source or authoritative clarification supports that reading.
Keep the independent records separate
The memo expressly preserves DFARS 252.204-7012 requirements. Where that clause applies, review safeguarding and incident-reporting duties against its incorporated text and the covered systems.
The 7019 provision concerns a current NIST SP 800-171 DoD Assessment for covered systems relevant to the offer, including the applicable SPRS score record. 7020 addresses the DoD assessment framework and subcontract treatment.
CMMC status and affirmation under 7021 are separate from that Basic Assessment score. Neither should be relabeled as the other. Review the required status and representation for the actual system and procurement.
Ask a question that produces a usable answer
Identify the designation in your document, the paragraph, the relevant date and the decision affected. Ask which amendment or modification implements the direction and what the contracting authority expects during any interval.
For a subcontract, address the prime’s authorized contact. A government memorandum does not by itself document a change to the private subcontract. Use the subcontract change handoff.
Keep the response with the source record, then revisit the affected assessment, evidence and schedule items. The amendment review log provides the working structure.
Read reform news without inventing an outcome
The July 13 announcement established a task force and a 60-day review. A planned report date does not establish that a report has been issued, that recommendations were adopted or that a particular award changed.
Check the official source, publication date, issuing authority and implementation document before changing your plan. Commentary can identify questions. It cannot fill a contract’s missing amendment.
Deep Fathom can demonstrate the compliance assessment and evidence workflow relevant to the work that remains. Review bid requirements. The campaign version remains a separately attributed, noindex destination. This guide is the permanent procedural answer.