Immediate Compliance for Government Contractors: Section 889 and CMMC

The days of simply checking a box and hoping for the best on Section 889 compliance are officially over. If you are a small or mid-sized government contractor (GovCon)—especially in IT, professional services, or anything telecom-adjacent—this isn't just a compliance concern; it's a survival issue. Recent waves of enforcement guidance, updated FAR clauses, and real-world exclusions make it crystal clear: you must be able to prove your supply chain is clean, or risk losing the contract entirely.

In this episode, we break down Section 889, including Part B, which bans agencies from contracting with any company that uses covered telecommunications technology (such as equipment from Huawei, ZTE, Hikvision, or Dahua) anywhere in its operations. We explain why enforcement is ramping up right now, pushing for annual "reasonable inquiry" reviews by GSA and DOD. If you misrepresent compliance on your proposal or SAM.gov registration, you risk bid protests or severe False Claims Act penalties.

This is your no-fluff guide to protecting your pipeline. We provide the essential, low-cost steps small businesses must take this week to shore up their 889 and CMMC posture. Learn the 889 Survival Checklist, which includes vital action items:

• Run a network scan using existing tools or free open-source scanners to check for banned telecom equipment in your IT setup.
• Get vendor attestations from subcontractors using a FAR 52.204-26-style checkbox, and keep those signed copies on file.
• Regularly check SAM exclusions for key vendors, monitoring both the Excluded Parties List and new FASCSA Orders.
• Document everything—from scans and attestations to internal review emails—as this will be your defense if audited or protested.
• Confirm every key vendor’s Unique Entity ID (UEI) and CAGE code to ensure they are registered and active in SAM.gov.

We also cover the urgent requirements for CMMC-Lite Hygiene. Even though full CMMC enforcement begins in November 2025, the DoD expects contractors to start self-assessing against Level 1 or Level 2 requirements now. We detail the essentials you need to implement immediately, including Multi-Factor Authentication (MFA) for all users, maintaining a current System Security Plan (SSP) and POA&M, and having encrypted backups of Controlled Unclassified Information (CUI).

Don't treat 889 and CMMC as background noise. Implementing these checks now is like preventive maintenance. Agencies are increasingly risk-averse, and a clean 889 and CMMC record can serve as a powerful proposal differentiator, helping you win contracts and avoiding costly surprises mid-performance.