Advisory
Your SPRS affirmation is now a False Claims Act liability.
A recent provider shutdown has left some contractors with a gap between current operating conditions and active SPRS affirmations.
That gap can create exposure under DFARS, 32 CFR § 170.22, and the DOJ Civil Cyber-Fraud Initiative. Coalfire Advisory is the authorized engagement path.
600+ CONTRACTORS AFFECTED
3× FCA EXPOSURE: Treble damages plus per-claim fines on every invoice submitted under a false SPRS affirmation. 31 U.S.C. § 3729.
C3PAO CONTINUITY PATH: Authorized C3PAO and RPO — the only engagement that preserves posture and produces legally defensible audit artifacts.
Act now WINDOW TO ACT: CMMC posture decays daily. Each day of inaction deepens FCA exposure and contract-performance risk.
Regulatory Basis
DFARS 252.204-70122
DFARS 252.204-70213
DFARS 252.204-70254
32 CFR § 170.22 — Affirmation
32 CFR § 170.23 — Flow-down
31 U.S.C. §§ 3729–3733 — FCA
DOJ Civil Cyber-Fraud Initiative
Anatomy of the collapse
Q2 2026 TIMELINE
PRE-EVENT · Q1 2026
Financial decline: Sustained revenue erosion; no public restructuring signal issued to contracted DIB clients.
MAY 1, 2026
Sudden shutdown: Total cessation with no transition plan and retroactive cancellation of employee benefits.
MAY 1–5
Strategic bifurcation: Accounting services preserved; IT enclave abandoned with no successor operator.
MAY 5–PRESENT
Risk concentration: Lock-out cascade across 600+ contractors; CMMC posture and deliverables at risk.
Recovery & compliance protocol
1. VERIFY
Confirm administrative credentials
Validate that your organization holds top-level, unrestricted administrative rights to its tenant — independent of any provider-managed identity.
2. ASSESS
Evaluate the lock-out exposure
If administrative rights reside solely with a third-party provider, your organization may be effectively locked out of its environment. Treat this as a CMMC artifact custody event and escalate to your contracting officer and DCMA.
3. EXTRACT
Forensic extraction — not migration
Do not attempt a standard data migration. Engage Coalfire Advisory to lead chain-of-custody extraction and quarantine of CUI, audit logs, and SSP evidence. DFARS 252.204-7012(c) cyber incident obligations apply.
4. REBUILD
Re-platform under a CMMC-aligned enclave
Stand up a successor enclave with documented administrative ownership, reciprocal SSP, and continuous monitoring. Coalfire Advisory partners live through remediation and posture preservation — not a post-event audit.
If your CUI hosting environment has been disrupted and you invoice DoD
IMPACT 01
EVERY INVOICE IS A LEGAL EXPOSURE
- Under DFARS 252.204-7021(b)(3), your affirming official attested to continuous compliance in SPRS. That infrastructure is now dormant. Every invoice you submit to DoD against an active contract is a potential false claim under 31 U.S.C. § 3729 — regardless of whether you have performed the work. The DOJ Civil Cyber-Fraud Initiative treats "reckless disregard" of a false affirmation the same as intentional fraud.
IMPACT 02
AWARD AND OPTION ELIGIBILITY IS AT RISK
- DFARS 252.204-7025 makes a current CMMC status and current SPRS affirmation a hard prerequisite for contract award, option exercise, and delivery order issuance. Contracting officers are prohibited from awarding or extending any contract where CMMC status has lapsed. If the infrastructure tied to your CMMC UID is no longer actively monitored or supported, SPRS may not reflect the true state of your environment.
IMPACT 03
YOUR CUI IS UNMONITORED AND UNDEFENDED
- DFARS 252.204-7012(b) requires adequate security on all covered contractor information systems at all times. If the environment supporting your CUI is no longer actively staffed, monitored, or enforced, you may no longer have visibility into access, identity controls, or security events. Under DFARS 252.204-7012(c), cyber incidents affecting CUI must be reported within 72 hours. You cannot report what you cannot see. Forensic extraction should precede any re-use, destruction, or migration of data.
Coalfire Advisory vs. no-action path
ADVISORY ENGAGEMENT
SPRS AFFIRMATION
Corrected to factually accurate state per 32 CFR § 170.22 and DFARS 252.204-7021(b)(3).
CUI CUSTODY
Forensic extraction with chain-of-custody; 72-hr reporting obligations met under DFARS 252.204-7012(c).
AWARD ELIGIBILITY
CMMC UID status restored; satisfies DFARS 252.204-7025 award and option eligibility.
FLOW-DOWN
C3PAO + RPO authorized; satisfies 32 CFR § 170.23 prime-to-sub flow-down obligations.
OUTCOME
Posture preserved; invoicing defensible; award eligibility maintained; FCA exposure closed out.
NO-ACTION / UNVETTED VENDOR PATH
SPRS AFFIRMATION
Remains false; every invoice is a potential FCA violation under 31 U.S.C. §§ 3729–3733.
CUI CUSTODY
Unmonitored environment; incident reporting obligations actively accumulating; no admissible artifacts.
AWARD ELIGIBILITY
CMMC status lapses; contracting officers are barred from award, options, and extensions.
FLOW-DOWN
Unvetted vendors lack authorization and technical staff; engagement breaches 32 CFR § 170.23 flow-down; prime exposure compounds.
OUTCOME
Posture decays daily; every invoice compounds liability; contract performance and award eligibility forfeit.
Engage with an advisor now.
Coalfire Advisory is the only authorized engagement path that preserves CMMC posture, corrects SPRS affirmations, meets 72-hour CUI reporting obligations, and closes out False Claims Act exposure.