Coalition for Academic Scientific Computation (CASC) Response to Department of War “Reforming CMMC and Reducing Compliance Burden for the Defense Industrial Base (DIB)”

With many of CASC's member organizations seeking CMMC certification, or already certified, CASC meetings and communication channels have been a venue for institutions to discuss compliance questions around CMMC and NIST SP 800-171. The CASC organizations represent a distinct subset of the Defense Industrial Base (DIB) focused on basic and open science, and through contracts with the DoW, the translation of that science into applications that further the readiness of America's defense. As such, this response centers on how CMMC implementation affects the continuity and pace of the research our members support — not on ranking security architectures — and aims to help ensure CMMC reform accounts for the distinct risk profile, governance structure, and open-science mission of research universities.