Safeguarding sensitive information against cyber threats is paramount, especially for companies working with the Department of Defense (DoD). Enter the Cybersecurity Maturity Model Certification (CMMC), a comprehensive framework designed to ensure that contractors have the necessary cybersecurity measures in place.
This blog post will delve into what CMMC compliance entails, its significance, and how it impacts businesses seeking to work with the DoD. By understanding the intricacies of CMMC, organizations can better prepare themselves and streamline the road to compliance.
What is CMMC Compliance?
CMMC is a standardized framework aimed at enhancing the cybersecurity posture of organizations within (or who wish to be within) the Defense Industrial Base (DIB). These companies either hold federal contract information (FCI) or controlled unclassified information (CUI).
CMMC enforces DoD’s cybersecurity requirements for DIB partners by safeguarding shared unclassified information. Certification ensures contractors meet cybersecurity requirements for acquisition programs and systems handling controlled unclassified information.
Who Needs CMMC Compliance?
By 2026, most defense contractors conducting work for the DoD will need to achieve CMMC certification. The level of certification you need will depend on the requirements spelled out in your contract.
Each level requires different types of assessments:
- Contractors who do not handle information deemed critical to national security (Level 1 and a subset of Level 2) must perform a self-assessment every year.
- Contractors handling information critical to national security will be subject to third-party assessments at CMMC Level 2.
- Defense programs at the highest level (Level 3) require government-led assessments.
Learn more: CMMC vs. FedRAMP: What’s the Difference?
Let’s discuss the levels in more detail.
Levels of CMMC Compliance
You’ll be able to determine the specific level of compliance required for your organization once CMMC 2.0 is implemented. The DoD will clearly specify the necessary CMMC level in all solicitations and Requests for Information (RFIs), if applicable. This lets you ensure that your organization is fully equipped to meet the necessary requirements and standards for doing business with the DoD.
The CMMC 2.0 levels (and their former 1.0 counterparts) are as follows. Note that former levels 2 and 4 have been folded into the new structure for streamlining purposes.
Level 1 (Foundational)
Level 1 establishes the foundation for basic protection and compliance with cybersecurity requirements. This level is designed to ensure that all contractors have a strong cybersecurity posture by safeguarding Federal Contract Information (FCI) through practices such as limiting access and implementing basic security hygiene.
In other words, Level 1 aims to provide a baseline of cybersecurity practices to protect against common cyber threats and ensure adherence to cybersecurity standards. Requirements are drawn specifically from FAR 52.204-21, Basic Safeguarding of Covered Contractor Information Systems.
Level 2 (Advanced)
At Level 2, you move beyond basic cybersecurity practices. This level mandates the establishment of documented processes and practices tailored to your organization’s needs. It ensures a more mature cybersecurity posture, focusing on protecting Controlled Unclassified Information (CUI). Achieving Level 2 compliance demonstrates a higher commitment to safeguarding sensitive information within the DoD supply chain. The level establishes NIST SP 800-171A as the definite source of assessment requirements.
Level 3 (Expert)
Level 3 requires the establishment of comprehensive practices and a mature cybersecurity program to protect highly sensitive CUI. Achieving Level 3 compliance means that your company is capable of managing and responding effectively to advanced cyber threats within the DoD supply chain. This level introduces an additional 24 requirements from NIST SP 800-172.
The CMMC Process
Getting certified for CMMC doesn’t happen overnight. It’s an 8-step process that we’ll guide you through.
Phase 1: Determine CMMC Level
Identify the appropriate CMMC maturity level required for your organization. This is determined by the nature of your DoD contracts and the sensitivity of the CUI you handle.
What to Expect: An initial assessment and classification process that lays the groundwork for achieving compliance. This phase is crucial for understanding the specific cybersecurity requirements and preparing your organization for the steps ahead.
Phase 2: Establish Security Processes
At this stage, your organization needs to define and document comprehensive information security processes that are in alignment with your CMMC level requirements.
What to Expect: Expect to work on creating and implementing fundamental cybersecurity practices that are tailored to the unique operational and security requirements of your organization. Customization is crucial for ensuring that the cybersecurity framework you develop meets compliance standards while integrating seamlessly with your organization’s workflows, business objectives, etc.
Phase 3: System Security Plan (SSP) Development
Develop a detailed SSP that clearly outlines the methods and practices your organization employs to protect CUI. An SSP is a comprehensive document that outlines how an organization secures its sensitive information and systems.
It includes information on the policies, procedures, and technologies used to secure data, as well as the individuals involved in managing and maintaining the security of the system
What to Expect: The creation of a thorough document that serves as a blueprint for safeguarding sensitive information, demonstrating your commitment to effective cybersecurity measures.
Phase 4: Self-Assessment
Undertake a rigorous internal review to evaluate your organization’s compliance with the CMMC standards, pinpointing any discrepancies or areas for improvement.
What to Expect: A critical examination of your cybersecurity strengths and weaknesses, providing a clear perspective on where enhancements are needed to meet CMMC requirements.
Phase 5: Implement Security Measures
Implement the necessary security controls and corrective actions to bridge the gaps identified during the self-assessment phase, thereby strengthening your cybersecurity defenses.
What to Expect: The strategic deployment of security measures that significantly improve your organization’s resilience against cyber threats and vulnerabilities.
Phase 6: Third-party Assessment (as needed)
Engage with a CMMC Third Party Assessor Organization (C3PAO) to conduct an independent evaluation of your compliance with CMMC standards, as required by your CMMC Level.
It’s important to note that a third party assessment is not necessary for any Level 1, and a small number of Level 2s. They can do self-assessments and have a senior official sign off on an attestation instead.
What to Expect: An objective assessment that validates your cybersecurity practices and highlights areas for further improvement, providing an external perspective on your compliance status.
Phase 7: Remediation
Act on the feedback and findings from the third-party assessment to address any deficiencies or vulnerabilities, ensuring your organization meets all necessary CMMC requirements.
What to Expect: Targeted remediation efforts to resolve identified issues with your cybersecurity framework, ensuring comprehensive protection of sensitive information.
Phase 8: Certification Submission
Finally, submit all required documentation, including your SSP and the results of your third-party assessment, to the CMMC Accreditation Body (CMMC-AB) for review and certification approval.
What to Expect: The culmination of your hard work in an official certification that recognizes your organization’s adherence to DoD cybersecurity standards, marking a significant milestone in your commitment to protecting national security interests.
Streamline Your CMMC Compliance With 38North Security
CMMC compliance presents a complex challenge: you’ll need a deep understanding of the CMMC framework and how to apply it to both your organization and your contractual obligations. Working with 38North Security will help simplify the process as much as possible.
As a designated RPO by the CMMC Cyber Accreditation Body (Cyber-AB), we’re recognized as an expert U.S. DoD security organization. We’ll leverage our deep understanding of the CMMC framework and help you build tailored strategies that fit your unique operational needs.
Contact us today to book a conversation with one of our CMMC Registered Practitioners (RPs) to learn how 38North can help.
