By: Christopher Parrella, Esq., CPC, CHC, CPCO
Parrella Health Law, Boston, MA
A Health Care Provider Defense and Compliance Firm

The DoD’s Final Rule on CMMC: What It Means

The Department of Defense has finalized its long-awaited rule incorporating the Cybersecurity Maturity Model Certification (CMMC) into nearly all defense contracts.

Why This Matters for Health Care Providers

You might be wondering: Why should a health care provider that doesn’t play in the DoD space care about a DoD cyber rule?

Here’s why:

1. Cybersecurity Is a Growing Compliance Obligation
   
   • HIPAA, HITECH, and state laws mandate safeguarding patient information.
   • CMMC compliance overlaps with these obligations, creating an opportunity to further strengthen your cybersecurity posture.

The Benefits of Compliance Beyond DoD Contracts

Even if your practice isn’t currently contracting with the military, CMMC compliance can pay dividends or health care providers:

• Protects Sensitive Data
  Health care organizations are prime targets for cyberattacks. Complying with CMMC standards reduces the likelihood of ransomware and data breaches that could cripple operations.
• Supports Intellectual Property
  DoD highlighted that protecting intellectual property from cyber theft is a key driver of the rule.

What Health Care Providers Should Do Now

1. Assess Your Data Environment
2. Determine Your Likely CMMC Level
   
   • Level 1: Basic safeguarding: likely where most small providers fall.
   • Level 2: More rigorous controls.
   • Level 3: Highest level.
3. Start with a Gap Assessment
   
   • Benchmark your current cybersecurity practices against CMMC requirements.
   • Use this to create a Plan of Action and Milestones (POA&M)—a roadmap to closing gaps.
4. Leverage Existing Compliance Programs
   
   • Align CMMC with your HIPAA Security Rule compliance.
   • Integrate controls into your existing IT, billing, and clinical workflows.

Federal Register – DFARS Final Rule on CMMC

https://www.federalregister.gov/documents/2025/09/10/2025-17359/defense-federal-acquisition-regulation-supplement-assessing-contractor-implementation-of

For health care providers, the DoD’s cybersecurity rule is more than a defense contracting requirement, it’s a roadmap to stronger data protection and future ready compliance reducing cyber risk across their entire provider organization. If you have any questions or comments about the subject of this blog, please contact Parrella Health Law at 857.328.0382 or Chris directly at cparrella@parrellahealthlaw.com.