The CMMC Final Rule was issued on October 15, 2024. We are aware that many federal contractors are under a lot of stress right now.
The Cybersecurity Maturity Model Certification (CMMC) was created by the U.S. Department of Defense (DoD), and achieving CMMC compliance is a must for any firm hoping to obtain or retain DoD contracts. The CMMC certification procedure is complex.
Consequently, we have compiled a plethora of information in this blog to assist you in navigating your company’s new path to CMMC 2.0 compliance.
What is CMMC?
The DoD uses CMMC, or Cybersecurity Maturity Model Certification, to evaluate how well companies in the DoD supply chain can safeguard sensitive information like FCI, CUI, and/or ITAR. CMMC is divided into three levels (more below).
A lot of Americans don’t realize that the US is engaged in a cyberwar right now. And we’re not winning. The U.S. Department of Defense (DoD) and the Defense Industrial Base (DIB), which is its supply chain, are the main targets in this war.
The problem’s intimidating:
- Due to intellectual property theft, China is now at the forefront of 37 of 44 vital technologies, including cybersecurity, advanced radio frequency, and optics.
- According to former NSA Director General Keith Alexander, the illicit acquisition of intellectual property and the cybersecurity crisis represent “the largest transfer of wealth in human history.”
It is more important than ever for DoD contractors in the Defense Industrial Base to protect intellectual property sensitive data and ensure CMMC compliance because the CMMC is the DoD’s attempt to address the mounting cyber risks.
The Levels of CMMC 2.0
Three certification levels are available under CMMC 2.0, depending on the kind of information a business manages and the degree of cybersecurity needed:
Level 1: Foundational
This level is designed for businesses that handle Federal Contract Information (FCI) and focuses on fundamental cyber hygiene. It calls for an annual self-evaluation in addition to 17 security procedures.
Level 2: Advanced
Level 2 comprises 110 security procedures based on NIST SP 800-171 and is intended for businesses that handle Controlled Unclassified Information (CUI). Depending on the terms of the contract, businesses are required to perform either third-party or self-assessments.
Level 3: Expert
For businesses handling the most sensitive data, this is the highest level. It calls for government-led evaluations and incorporates advanced cybersecurity techniques based on NIST SP 800-172.
To whom does CMMC apply?
CMMC has an immediate effect on entities that assist the Department of Defense or academic research institutes that deal with:
- Controlled Technical Information (CTI)
- Controlled unclassified information (CUI)
- Federal contract information (FCI)
- Covered Defense Information (CDI)
- Export-controlled/ITAR data
The DoD estimates that more than 200,000 defense and aerospace suppliers will have to comply with CMMC.
Budgeting for CMMC?
There are five main areas to take into account when determining how to budget for CMMC:
- Scoping: The process of inspecting your systems to find all of the sensitive data you handle (CUI, ITAR, etc.).
- Licensing: Seeking a CMMC-approved cloud service such as Microsoft Government Cloud.
- Implementation: Expenses related to setting up CMMC controls.
- Migration: Transferring your existing setup to a new, reliable cloud provider
- Support: Putting together a suitable team to fulfill CMMC’s threat detection and monitoring responsibilities.
- Evaluation: Covering the cost of the real CMMC evaluation (every three years)
10 Steps to CMMC Compliance
1. Identify Your Required Level
The maturity level of your organization determines which controls apply to your firm. Selecting the appropriate level is essential because each one builds on the one before it.
2. Appoint a Compliance Manager
Choose a person to manage the CCMC compliance initiatives. This individual will be in charge of working with outside parties, creating appropriate policies to fulfill the goals of the company, and making sure that every action complies with the CMMC checklist.
3. Collaboration, Communication, and Documentation
Recognize the technologies, people, and processes that make up your infrastructure. Recognize which sensitive systems need to be handled by whom and which safety measures are in place to secure them, and work with all departments to create a single channel for communicating compliance efforts.
4. Monitor Internal CUI Flow
You should understand the flow of CUI inside your IT infrastructure in order to protect it. Once found, minimize the number of devices that store data across all endpoints.
5. Create a POA&M and SSP
Create a document called the Plan of Actions & Milestones (POA&M) to monitor the status of your CMMC compliance checklist. It should provide dates, remedial measures, and any deficiencies discovered throughout the audit.
6. Make an Internal Evaluation
Using the CMMC self-assessment guide, conduct a self-assessment to gauge the success and advancement of the controls you put in place.
7. Submit the Paperwork to SPRS
All CMMC documentation is centrally stored in the Supplier Performance Risk System (SPRS). Send the SPRS your POA&M, SAR, and SSP.
8. Resolve and Eliminate Current Risks
To fill in any gaps, use the results of your self-evaluation. Apply the rest of the controls and measures using the POA&M as a guide. Send the SSP, SAR, and POA&M to the SPRS once the risks have been addressed. Your score has been updated.
9. Certification by CMMC
Make contact with a CMMC 3rd Party Assessment Organization (C3PAO) to establish a timeline and share your status. The C3PAO will assess your present level of progress and compile their findings into a thorough report.
10. Ongoing Evaluation
Certification is just the beginning of your CMMC framework implementation. Regularly updating your training materials, reviewing policies, updating records, and making sure all controls and measures are operating as intended are all necessary to keep your certification current.
Final Words
Remember, given the size and complexity of the company, a CMMC assessment usually takes several weeks. The timeline is influenced by preparation, the examination of paperwork, and the actual audit procedure. The length of the evaluation could range from a few weeks to many months. Therefore, you must move quickly!