CMMC Compliance: Standardize Cybersecurity For Defense Industrial Base Sector
The United States Department of Defense is currently employing the Cybersecurity Maturity Model Certification or CMMC compliance model to standardize cybersecurity awareness across the federal government’s defense industrial base (DIB).
This article will cover the important concept of a maturity model from the perspective of cybersecurity, the anatomy of CMMC levels, key depictions of the DB, and more. If you’re ready, let’s begin!
What is the CMMC?
CMMC is a program started by the US Department of Defense to measure their defense contractor’s sophistication, readiness, and capability in cybersecurity. At a high level, the framework is a collection of processes, inputs, and other frameworks from existing cybersecurity standards like DFARS, FAR, and NIST.
CMMC Level Overview
Every level has a set of Practices and Processes and a qualifier or goal for each of those as they connect to the applicable Domains in that level. For instance, accomplishing CMMC level 2 means a company’s goal is to have documented processes and Practices consistent with transitional cyber hygiene.
Why The DoD Created The CMMC
DoD created the CMMC to enforce a corporate culture shift to prioritize cybersecurity. It was also made to increase information and cybersecurity protection. Remember that CMMC is a vital element of the DoD’s security strategy, and the agency expects its plan to guarantee every company adopts CMMC-level best practices as the new standard.
Understanding the CMMC requirements
The Defense Federal Acquisition Regulation Supplement (DFARS) specified particular security requirements for suppliers under a self-attesting network. The DoD also stressed the significance of adopting NIST SP 800-171 standards under DFARs to secure all contracts, but most suppliers weren’t complying with requirements.
As an alternative, many wrongly evidenced their compliance and security became less efficient. These false attestation claims do not only slow the adoption rate, but they increase network risks.
Who Needs CMMC Certification?
Remember that the CMMC certification is needed of any person in the DoD supply chain, which includes contractors interacting with the Department of Defense and all subcontractors. The CMMC requirements will impact more than 300,000 organizations, hence they are increasingly reaching out to EPCGroup for CMMC Compliance Consulting.
What Are CMMC Certification Levels?
DIB contractors should meet one of three maturity levels of data security maturity to gain bidding opportunities for potential work with the DoD. The three levels are:
- Level I – Foundational
- Level II – Advanced
- Level III – Expert
Organizations might be needed to perform annual self-assessments, and others will be needed to perform a government audit once every three years.
What steps should businesses take who work with the DoD?
If a business is currently working for the DoD or has plans on working for them in the near future, they must have a clean bill of digital hygiene for their organization.
The rule in the DFARS obliges defense contractors to undertake particular data security corrections through the Basic Assessment process of DoD, which is presented to the Supplier Risk Management System.
Further, defense contractors should have certification under the CMMC network, evaluating practices and processes. Those assessments should be performed by CMMC Third-Party Assessment Organizations instead of self-certification.
Here are some steps businesses should do:
- Find a consulting company with a track record around cybersecurity advisory services with staff that tracks CMMC.
- If possible, find a fixed cost option for CMMC consulting services and related advice.
CMMC Compliance Preparation for DoD Contractors
Whether you’re a DoD contractor or not, there are particular things you need to undertake to stay ahead of the transition. Here are some key things you can do to prepare for compliance:
- Evaluate the current company for NIST 800-171 compliance
- Make or update the System Security Plan (SSP)
- Create the Plan of Action and Milestones (POA&M)
- Perform the Remediation Plan
- Keep compliant
Self-Assessments vs. Third-Party Assessments
The DoD will confirm contractors’ compliance in three different ways:
- Annual self-assessment is needed for CMMC level 1 and only selected programs within Level 2.
- Triennial third-party assessment by C3PAO: needed for CMMC level 2.
- Government-led assessments: needed for level 3
Remember that every contract will determine which level of CMMC contractors should meet before being awarded the contract.
Preparing For A CMMC Assessment
The following options are always accessible to prepare for a CMMC assessment, especially for DoD contractors who haven’t implemented any controls:
Work with a CMMC consultant
The most efficient way to meet the cybersecurity requirements is to outsource the work to a CMMC RPO specializing in CMMC consulting. Take note that DoD contractors stay responsible for ensuring their organization meets the proper cybersecurity requirements. Thus, it is important to pick an RPO you can trust.
Meet the requirements in-house
DoD suppliers or contractors who have the IT staff and resources accessible can meet the necessary CMMC level of cybersecurity in-house. Internal IT departments can utilize the Self-Assessment Handbook given by the National Institute of Standards and Technology (NIST).
Who does CMMC directly affect?
CMMC applies to anybody in the defense contract supply chain. Those involve contractors engaging directly with the DoD contractors and primes to execute or fulfill such contracts.
Many organizations will require level 1 to level 3 certification to qualify for government contracts. Further, the affected companies include every supplier at every DoD supply chain, small businesses, commercial items contractors, and foreign suppliers.
What steps should businesses take who work with the DoD?
CMMC will likely be completely implemented by 2026. However, organizations and companies must begin certification efforts as early as possible. Basically, that involves putting in place the best cyber security-based practices.
The rate at which an organization accomplished an acceptable level of cyber hygiene and complied with the CMMC requirements depends on the existing environment.
Here are other best practices businesses should take for CMMC Compliance.
- Continually visit the DoD’s website to check any updates on CMMC as you wish for assessment by a certified assessor.
- Check every CMMC practice against your current environment, beginning with the first practice in the first domain and working your way down.
- Determine the scope of the assessment and configure the current security environment to align with the requirements
- Identify the CMMC level you need to accomplish, check cyber hygiene requirements, and collect CMMC tools, templates, and documents.
How Do You Get CMMC Certification?
Here are the steps you need to get CMMC certification:
Evaluate your infrastructure
Assess your existing IT infrastructure against the control framework, aligning with your preferred CMMC level. That’s also called gap analysis and is the foundation for knowing what controls, procedures, and processes should be implemented to accomplish compliance.
Organizations with the proper resources can perform their self-assessment, while others outsource the assessment to a third party, like CMMC RPO.
The second step is remediation which includes the real work to execute the procedures, processes, and controls that are called out in the assessment. Remember that organizations with the resources can do the remediation work themselves, while others consider using an RPO.
Even when an organization does have the resources, an RPO can do it faster and more effectively.
Get assessed by a C3PAO
For organizations that should meet the CMMC levels 2 and 3, the last certification step is to receive an official assessment from a Certified Third-Party Assessor Organization (C3PAO). Nonetheless, no assessments are being done as the Assessors are trained. The first assessments are anticipated to begin this 2022.
FAQs on CMMC Compliance
Do you have more questions want to be answered about CMMC? This section will answer all of them.
Who is required to be CMMC compliant?
Any supplier that’s part of the Defense Industrial Base (DIB) and bids on DoD tenders are obliged to comply with no less than one of the levels of maturity of the CMMC. Remember that which level varies on the contract types you bid in.
When it comes to sub-contractors, the CMMC advice is that if the DoD contract needs CMMC compliance and your organization doesn’t solely crate COST products, you should get a CMMC certification. Also, that level is dependent on the data type shared along with the main contractor.
What level of CMMC is required?
The CMMC is composed of five mature levels of cybersecurity based on the principles contained within the cybersecurity maturity level of NIST. Every group specifies best practice cybersecurity, and every level is dependent on the previous level.
- Level V – These involves optimizing, advanced and progressive
- Level IV – reviews, preemptive
- Level III – controlled, good cyber hygiene
- Level II – detailed, intermediate cyber hygiene
- Level I – completed basic cyber hygiene
How do I become CMMC compliant?
The steps to becoming CMMC compliance at a selected level cover:
- Determine the CMMC level needed by the company to bid on DoD contracts
- Pick a professional CMMC-AB marketplace vendor to direct your company through the process and run a pre-assessment practice.
- Look for an accredited C3PAO through the CMMC-AB marketplace
- The C3PAO then takes your company through an assessment process according to the selected CMMC maturity level requirements.
- The CMMC-AB check the assessment made by the C3PAO through a quality auditor
- Your company has ninety days to amend any gaps discovered during the formal assessment.
- The CMMC-AB will issue your company a CMMC certificate of compliance after the assessment meets the criteria for the selected CMMC level.
Who determines CMMC level?
The CMMC Accreditation Body is the only organization entity to pick third-party C3PAOs who can offer certification for CMMC. On top of that, registered provider organizations can offer great services and tools to help companies meet compliance standards. However, they don’t typically offer official certifications or assessments.
Can I continue to use Commercial O365 or Gmail if I need to be CMMC?
Yes, you can. You can continue using platforms such as Gmail or Commercial 0365. However, they should be removed from your compliance boundary and must not handle CUI.
Can I use PreVeil to communicate with suppliers?
Fortunately, PreVeil is also a good tool for working with suppliers. That’s because contractors could set granular permissions like view only or read-only to keep control over their data. Also, they can revoke access anytime through sharing.
How are CMMC Level and NIST related?
The CMMC compliance requirements and NIST 800-171 requirements deal with CUI and are similar rigor. However, the frameworks differ in their assessment and scope standards
The major difference between the two is that companies could set and perform their cybersecurity framework and announce themselves compliant with the NIST standards for NIST.
Meanwhile, to get a CMMC certification, your company should be certified by a CMMC C3PAO. Those companies perform audits to issue that organizations in the DIB meet a specified level of CMMC cyber hygiene.
Moreover, C3PAOs are sanctioned by the CMMC-AB, the only entity charged by the DoD with licensing, accrediting, and managing the CMMC ecosystem. Also, the scope of NIST covers Non-Federal Organization controls, while the CMMC framework doesn’t.
How much does a CMMC certification cost?
The short answer to this is, it depends. The cost of CMMC certification depends on the desired maturity level as well as the size of the organization. The good thing is that the cost of CMMC certification is considered a reimbursable, allowable cost and will be valid for at least three years.
Therefore, you probably have the same concerns on your journey to compliance if you are a DoD contractor or subcontractor seeking to join a federal contract on or before 2025.
Keep in mind that full implementation of the CMMC is not expected to happen until 2025. That’s because there’s no clear guide as to which types of contracts will need CMMC compliance and by what time. Further, others may elect to delay until the last minute.
However, that could result in missed revenue, increased costs, contract termination, or even penalties for hasty or poor business and security decisions. Successful DIB contractors are also taking the time today to get ready, offering themselves the competitive advantage with early certification positioning themselves for potential business along with the federal government. We hope you find this guide useful and informative at the same time.
With over 25 years of experience in Information Technology and Management Consulting, Errin O’Connor has led hundreds of large-scale enterprise implementations from Business Intelligence, Power BI, Office 365, SharePoint, Exchange, IT Security, Azure and Hybrid Cloud eﬀorts for over 165 Fortune 500 companies.