DoD’s Cyber DFARS FAQ in 2026: which answers need a fresh check

This Cyber DFARS FAQ edition is revision 4, dated June 13, 2024. It is not a 2021 edition. Its explanations remain useful, but the document predates later CMMC program developments and procurement changes.

As of September 30, 2026, use the FAQ as a reading aid alongside the incorporated contract clause and current official guidance. A “No” in an older assessment answer cannot establish that a contractor has no assessment obligation today.

Start with the edition and the question number

The June 2024 FAQ groups safeguarding, cloud, incident-reporting and assessment questions. Those subjects overlap, but their legal bases differ.

Save the question number with any extracted answer. A search-result snippet that loses the clause, edition or assessment method can change the apparent meaning.

The table below is a reading map for selected high-value questions. It is not a verification of every answer in the document.

Outsourcing still leaves a contract responsibility to manage

Q7 explains that outsourcing IT does not transfer the contractor’s DFARS 252.204-7012 responsibilities. Its practical advice is to put requirements and deliverables into the provider agreement.

Current DoW CIO CMMC FAQ adds useful provider detail. Its section E distinguishes cloud and non-cloud services, CUI, and security protection data. It also explains that a non-cloud MSP need not have its own CMMC assessment merely because its services are included in the customer’s assessment.

The older FAQ’s A7 preserves the responsibility distinction:

Outsourcing your IT to another company does not transfer your DFARS clause 252.204-7012 responsibilities

Read those sources together. A provider’s sales label doesn’t describe the customer’s full obligation. The MSP scope guide and shared responsibility guide provide the working questions.

An alternative control needs the specified process

Q8 distinguishes prohibited informal waivers from the clause’s process for proposing an inapplicable requirement or an equally effective alternative. DFARS 252.204-7012(b)(2)(ii)(B) describes the written submission and adjudication path.

A consultant’s opinion that a requirement “doesn’t fit” is not the written determination described in that process. Retain the request, supporting explanation and actual response when relying on an adjudicated alternative.

In Deep Fathom’s view, the key editorial distinction is between an argument and an authorization. The working record should show which one exists.

Assessment answers need their original context

Several FAQ answers discuss the DoD assessment methodology and the oversight arrangements associated with particular rules. Those answers should not be generalized into “DoD never requires third-party assessment” or “an SSP and POA&M always establish acceptable CMMC status.”

As of September 30, 2026, the DoW CIO program page says Phase II is suspended and the program remains in Phase I. That page also describes Level 2 against Revision 2’s 110 requirements and addresses conditional status and closeout.

That current status matters, but it still does not replace the solicitation or contract. Use the assessment-failure guide for the conditional-status question, after confirming the assessment type.

For clause numbering and procurement changes, start with the clause-family reading map. Record any deviation incorporated into the package. This FAQ review does not declare every legacy clause superseded in every contract.

Worked example: an old answer in a new provider proposal

Suppose a hypothetical MSP proposal quotes an old FAQ sentence about assessments and concludes, “No separate evidence is required from us.” The customer plans to use the MSP for administration of its CUI environment.

Don’t debate the snippet in isolation. Ask four narrower questions:

1. Which FAQ question, edition and assessment method is being cited?
2. Which service and information does the MSP handle?
3. Which contract and program requirements apply to the customer?
4. What evidence and assessment cooperation will the provider supply under the agreement?

One possible answer is that a standalone provider assessment is unnecessary while provider evidence remains necessary to the customer’s assessment. Those conclusions can coexist.

Our suggested record is a short decision note containing the quoted question, the current controlling source, the service boundary, and the contractual deliverable. It gives the procurement and security teams the same issue to resolve.

Keep a useful answer current

When reusing the FAQ, attach its date, question number, contract context and later source check. Revisit answers affected by a new clause, deviation, assessment rule or provider arrangement.

For a specific interpretation question, take a non-sensitive description and the clause reference to the appropriate contracting channel. The DFARS 7012 guide is a starting map, not a replacement for that contract-specific determination.