Understanding DFARS 252.204-7021 Through the Contracting Officer’s Hidden Checklist

In a January 7, 2026 commentary published by Federal News Network, Jacob Horne argues that contractors who focus only on the text of DFARS 252.204-7021 are missing the operational reality: the clause is the outward-facing artifact of a contracting officer (KO) playbook embedded in DFARS subpart 204.75. Horne’s central point is that DFARS is not improvising new compliance expectations; rather, it operationalizes the Department of Defense’s CMMC program policy (32 CFR Part 170) by translating policy into mandatory award and administration procedures for KOs. For contractors, the practical implication is that “understanding CMMC” must include understanding how KOs are instructed to determine applicability, validate eligibility for award, and sustain compliance through options and extensions.

Horne explains that DFARS 204.75 is explicit about roles and decision rights. The program office (or requiring activity) determines the required CMMC level based on the mission and the data at issue; the KO’s responsibility is to implement that requirement in the solicitation and contract and to verify the offeror’s eligibility before award. The verification standard is not aspirational progress toward compliance but “current CMMC status” at the level required by the solicitation. Horne emphasizes that “current” is consequential because the status has a validity period (generally three years) and must be maintained throughout the period of performance, including at key contractual decision points.

A major operational detail in Horne’s analysis is that KO verification occurs in the Supplier Performance Risk System (SPRS) using a 10-character CMMC Unique Identifier (UID) tied to the specific assessed system or enclave. This UID linkage is more than administrative hygiene: it creates traceability from the contract to the particular environment handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). Horne warns that if the UID corresponds to one assessed boundary while performance reality routes CUI into another system, the contractor can create a contractual mismatch with potentially serious consequences, including heightened fraud-risk theories (for example, False Claims Act exposure) if representations about compliance become untrue in execution.

Horne further clarifies that “status” is tiered and time-bounded. Level 1 requires a final self-assessment and does not allow POA&Ms. Level 2 may be satisfied through self-assessment or a C3PAO assessment and may be final or conditional, but conditional status is constrained by a 180-day window to close permitted POA&Ms. Level 3 requires a government assessment (DIBCAC) and similarly can be final or conditional within policy limits. Because KOs must re-check status not only at award but also at option exercise, extensions, and certain mid-performance changes (such as introduction of a new UID after significant scope or boundary changes), contractors should treat CMMC not as a one-time gate but as a lifecycle obligation that can directly affect revenue continuity.

Disclaimer: This blog post is provided for general informational purposes only and does not constitute legal advice. Readers should consult qualified counsel and the applicable solicitation, contract, DFARS text, and program guidance before acting on any compliance or contracting decision.