Are you a DoD contractor who isn’t sure if CMMC applies? It absolutely does, so be prepared for your federal contracts to be at risk should you choose non-compliance. Don’t simply attempt to pass CMMC Audits so you can keep your Business. Construct a Cybersecurity System as a foundation that will keep your business ready for contracts.
What the CMMC Final Rule Means for Contractors?
The DoD has implemented the Cybersecurity Maturity Model Certification (CMMC) 2.0 within procurement processes by integrating it within the Defense Federal Acquisition Regulation Supplement (DFARS). This integration means the CMMC requirements will become part of the contract addenda.
In accordance with this, any Defense Industrial Base (DIB) organization that manages Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) is required to obtain the required certification level to obtain or sustain a DoD contract.
If you don’t know where these places are, our IT Compliance and Governance Services guide you on what needs to be modified.
Three Certification Levels
Level 1 – Basic Cyber Hygiene
This only applies to companies that handle FCI, and consists of 17 basic security practices and an annual self-assessment submitted to the Supplier Performance Risk System (SPRS).
Level 2 – Advanced CUI Protection
This is the most common certification and consists of all 110 security controls from NIST SP 800-171, and a self-assessment or a third-party assessment by a Certified Third-Party Assessment Organization (C3PAO), depending on the sensitivity of the contract.
Level 3 – Advanced Security
This is the most comprehensive certification and is usually for companies that work on the most sensitive programs that the DoD offers. To obtain this, companies usually have to provide advanced protections based on the NIST SP 800-172 and undergo a formal assessment led by the government.
Who Needs to Obtain CMMC Certification?
Organizations tend to believe that CMMC is only for large prime contractors. This is incorrect, and you have to comply if you are:
- A prime contractor who deals with CUI or FCI.
- A subcontractor with the given requirements in your contract.
- A cloud service provider that stores or throws CUI.
- A managed service provider that functions in a DoD contractor’s environment.
The only exclusion is with companies that only sell Commercial Off-The-Shelf (COTS) products that are free from CUI. If you provide IT management for defense contractors, Managed IT Services for DoD Contractors provides you with complete information about your required services.
The Critical Documents You Should Have
Before any assessment is done, you should have your compliance documentation set. Assessors expect to find a full compliance documentation System Security Plan (SSP) that explains how each control from the NIST SP 800-171 is implemented in your organization’s system. A Plan of Action and Milestones (POA&M) is also required, as well as evidence of your access control policies, incident response plans, and the standard of your encryption.
The number one cause of an organization’s failures to comply with CMMC requirements is poorly constructed documentation. Our IT-centered Cybersecurity Compliance audit is a great place to begin. A trustworthy framework coupled with a Zero Trust Security Model will help close gaps in access controls.
Gaps that can delay/derail your certification
Organizations often discover some of their most glaring weaknesses during the gap analysis. Examples include missing SSP documentation, no multi-factor authentication (MFA) on every device, unregulated access for third parties, and no endpoint protection for remote devices.
A very common problem includes the use of state-of-the-art commercial cloud tools for the storage of CUI, which are simply unapproved cloud tools and a direct breach of the CMMC assessment boundary.
Once your Cloud Security Posture is reviewed early, you can avoid most of the concerns raised during a formal C3PAO audit.
Start your CMMC readiness assessment now
Once a contract is awarded and a CMMC certification is required, you have missed your opportunity to address many of the gaps. The best placement is to lead with a gap analysis of the 110 NIST SP 800-171 controls, identify and address the highest priority gaps, enhance your SSP, and then you can either aim for self-attestation or, at the Contract Details level, a C3PAO certification. Organizations with early adoption experience reduced counters and assessment costs while embodying permanent cyber defense habits.
CUI hosting and your Cloud Security Posture joint assessment is persistent, automatic, and periodic. The self-sustaining C3PAO self-attestation is the instrument of choice.
CMMC is continuous, recurring, and occurring. The same contractors maintain their footing in the defense ecosystem.
