The Complete Guide to CMMC Compliance
Companies face a lot of responsibilities when working with data. Tracking use, managing backups, and ensuring integrity are all essential for controlling data flows and maintaining best practices.
Any companies that want to keep data secure generally follow specific guidelines to ensure they don’t make common mistakes or fail to understand important procedures.
When it comes to using vulnerable data, companies need to be even more careful. By adhering to existing frameworks, companies can effectively mitigate many of the shortcomings of working in digital security. For those interested in working with government agencies, CMMC compliance is essential.
With that in mind, we present this complete CMMC compliance guide for making sure your cybersecurity threat detection and response models are up to date.
What Is CMMC?
The United States Department of Defense (DoD) has outlined some basic requirements for private companies with which the department shares vulnerable data.
This Cybersecurity Maturity Model Certification (CMMC) allows the DoD to measure the strength of a company’s data security model to determine whether it meets the department’s requirements.
CMMC compliance ensures companies have the needed experience before they’re allowed to work alongside the DoD and other federal agencies. If you’re interested in working alongside the government on a particular project, doing a CMMC assessment can give you an idea of where you fall regarding data security preparedness.
The History of CMMC
The DoD worked alongside various organizations, including Carnegie Mellon University and Johns Hopkins University, to create a threat assessment model for companies that may need to access Controlled Unclassified Information (UCI) and Federal Contract Information (FCI).
This model involves a self-assessment for protecting sensitive data on private systems and standardized labeling of all information.
Originally conceived in 2002, the model was intended to deal with the post-911 cybersecurity environment by making it easier to share IT-related reporting and incidents among agencies and with the private sector.
The model was further refined over the next decade, and in 2019 the CMMC was officially established. CMMC 2.0 was announced by the DoD in November of 2021 and addressed many of the shortcomings of the previous version.
CMMC 1.0 vs. CMMC 2.0
While the original CMMC guidelines offered five levels of preparedness, the updated CMMC 2.0 guidelines simplify this to only three.
The first CMMC required audits for each company that the DoD worked with within five years, but smaller and mid-sized businesses pointed out that this would be unfair to them. Added costs and the need to hire outside sources would leave them at a disadvantage, locking them out of the defense contract industry.
The CMMC 2.0 revisions offer some important changes to the guidelines, including fewer requirements and the availability of waivers in rare situations.
Beginning in May of 2021, CMMC 2.0 will address many of the complexities of the original guidelines by trimming down the CMMC levels from five to only three, alongside other important changes. With CMMC 2.0, Plan of Action and Milestones (PoAM) standards, which were previously excluded, can now be created and reinforced.
Why Is CMMC Important?
Private contractors operating in the defense sector often need to meet strict security requirements. Contractors need to be able to secure controlled, unclassified information and do ongoing self-assessments to determine eligibility for their roles.
The CMMC is a powerful tool for determining whether a company or organization is equipped to deal with important government data on its own.
In offering a way to measure the cybersecurity capabilities of would-be government contractors, the CMMC is essential for improving operational safety when using FCI and UCI.
CMMC offers many important benefits. These include:
- Reduced risk against cyber threats
- Availability of cybersecurity standards and best practices
- Preparedness verification
- Cost-effective security modeling for businesses
Proper CMMC practices encompass everything ranging from basic cybersecurity solutions to advanced optimizations of architecture. For those who use CMMC, the right investments can lead to better performance of managed capabilities, which in turn lead to measurable business results.
Who Uses CMMC?
CMMC is used across all industries working on defense contracts and encompasses the entire supply chain from beginning to end. This expansiveness can make the execution of contracts more complex, and contractors need to ensure they’re prepared to deal with the ongoing requirements of certification.
Cyber defense standards and practices outlined within the CMMC requirements can be applied to any organization operating with important data. As for the government, it often has specific requirements for individuals and organizations that it shares its assets with.
Contractors, security personnel, and any other entities doing business with the government use CMMC to provide credentials for their current service capabilities.
The government relies on many private companies for its goods and services. While these businesses operate independently, they are required to meet specific standards when working with the government.
Government contractors are any private entities working with a U.S. agency or organization. Because they work outside of federal systems, the government can’t track and reinforce data practices effectively.
This vulnerability makes it important to maintain strict standards when dealing with government contractors. The CMMC is a powerful solution for ensuring government contractors handle important data properly.
Security professionals may want to go through the CMMC process to ensure they’ll be prepared to work with any client. Defense contractors and other individuals working with government agencies must demonstrate cybersecurity readiness to show their maturity level.
The term “security professional” refers to anybody working as a professional in managed security services. This field includes cyber protection and defense as well as IT. Anybody working alongside the DoD requires a certain level of cybersecurity readiness and training to ensure they’re able to properly handle vulnerable data.
Many non-profit organizations do business with the U.S. government offering important services to the public. The National Cybersecurity Alliance, the Center for Internet Security, and the Open Rights Group are just a few of the non-profits that may want to access government data.
CMMC doesn’t just apply to contractors — it applies to subcontractors as well. Digital security requires understanding how to reduce risk and improve data management capabilities. Any organizations that want to ensure they’re following best practices can follow CMMC guidelines to reinforce their day-to-day operations.
With this guide to CMMC compliance, you’ll have all the tools you need to address potential liabilities and stay on top of regulations, no matter what industry you’re in.
What Is CMMC Compliance?
CMMC compliance determines whether a company meets the security expectations for working with DoD and other agencies. There are three domains that companies that pass the assessments will fall into, depending on their data security preparedness.
Proper CMMC compliance is essential for government agencies to determine which companies are eligible for which contracts.
Why Companies Should Maintain CMMC Compliance
Maintaining CMMC compliance is a complicated process. Businesses that want to be awarded a contract should take specific steps to ensure they don’t miss anything.
The most lucrative contracts are awarded to those companies that can demonstrate the highest level of compliance. This reality means that companies that proactively work to reinforce compliance within their environments will have access to more opportunities for work.
For many companies — especially small and medium-sized businesses — preparing for the inevitabilities of data security can be expensive and difficult. That’s why the DoD simplified the process of CMMC compliance in its 2.0 revisions, allowing more businesses to reap the benefits of maintaining digital security readiness.
The Three Levels of CMMC Compliance
When the 2.0 revisions take effect, there will be three levels of readiness considered by certification providers. These levels are based on the type of information that the organization works with and determines authorization credentials alongside other important information.
Agencies can create PoAMs to indicate which type of data they’ll be working with and how they’re expecting to handle securing it.
By stating resources in advance, the CMMC guidelines offer a picture of the contractor’s capabilities and potential for compliance. Foundational, advanced, and expert CMMC operators will have different clearance levels designating their digital preparedness capabilities.
Companies that work with FCI to secure essential assets are eligible for Level 1 CMMC domain clearance. There are 59 objectives that must be met for companies that want to practice as Foundational DoD contractors.
CMMC 2.0 Level 1 is aligned with CMMC 1.0 Level 1. Level 1 eligibility requires yearly self-certification and reporting on individuals, equipment, and other external sources that may need to work with DoD data.
Companies with CUI are eligible for Level 2 CMMC domain clearance. At this level, there are 320 objectives and 110 practices that should be in accordance with NIST SP800-171.
CMMC 2.0 Level 2 is aligned with CMMC 1.0 Level 3. To be eligible for Level 2, organizations must have a third-party assessment completed every three years. In addition, those taking part in certain programs may be required to complete an annual self-assessment.
Companies found the most capable of protecting CUI are eligible for Level 3 CMMC domain clearance. With more than 320 objectives to be fulfilled, this is the most difficult level of CMMC capability. In addition to the NIST requirements outlined for advanced contractors, experts must also meet some requirements in NIST SP800-172.
CMMC 2.0 Level 3 is comparable to CMMC 1.0 Level 5. Expert clearance is given only to the most capable companies. Level 3 maturity requires a government-led assessment to be performed every three years.
Tips for Maintaining CMMC Compliance
Getting started with CMMC compliance is easier said than done. When it comes to maintaining digital security, there are many endpoints that must be accounted for.
The National Science Foundation offers an 8-step plan for DoD contractors and subcontractors who want to obtain compliance certification for their organizations. These steps can be simplified into three basic ideas: creating a plan, gathering information, and creating solutions to problems.
Create a Plan
In CMMC planning, the most important thing to ask is whether CUI or FCI will be used for the project. If not, then CMMC compliance isn’t necessary. For those working with classified intelligence, there are important considerations when developing a security system for storage, access, and use.
Have specific goals and milestones in mind so you can track your progress. Your intended score will depend on which level you wish to align with. By identifying the scope of the problem, you’ll be equipped to create an actionable plan that gets you where you need to be for CMMC compliance.
Gather Documents and Resources
After deciding which plan of action your company will take, it’s crucial to gather vital resources and information, so you’ll have it readily available.
Some documents and resources you may need include:
- NIST SP 800-171 Compliance Template
- GSA Federal Risk and Authorization Management Program (FedRAMP) requirements
- Information about other international partner agreements that may go into effect
You may also have to be assessed by either a third party or the government if you want to have a higher rating. Make sure to understand all parts of the process before moving forward to save time and money.
Address Key Vulnerabilities
IT systems often have unseen security vulnerabilities and gaps that can be missed without a comprehensive security audit. This oversight can become a problem when attempting to gain CMMC compliance through a third party.
Companies that want to obtain CMMC certification should work to discover and fill gaps that they may have missed in their initial security implementation. By assessing network architecture, software, and other IT resources, companies can ensure their digital security practices are up to the task of protecting government data.
Once these steps have been addressed, companies will need to schedule a CMMC assessment to ensure they’re compliant.
Creating a Secure CMMC Environment
CMMC requirements expect companies to have secure infrastructure available for working with government data. While creating your own environment might seem tempting, there are so many variables involved that it’s easiest to outsource to a certified cloud provider.
Cloud-based CMMC providers offer virtualized services that standardize the deployment of compliant environments for working with CUI and FCI. This setup makes it easy to track and manage sensitive data without worrying about added overhead for your company’s internal operations.
Having easy access to a CMMC environment that strictly adheres to government regulations puts you in a stronger position when going through the certification process.
The CMMC Assessment
The CMMC assessment itself is fairly straightforward. Companies that have addressed which level they’re targeting and the specific objectives and practices that must be reinforced can move forward with the review process.
For better oversight over the assessment ecosystem, higher levels of practice will involve a more involved approach to certification. This reality means that companies that wish to obtain a better score need to find and address existing vulnerabilities beforehand to demonstrate their security potential.
Hire a Certification Provider
For third-party certification, companies must find a CMMC Third Party Assessment Organization (C3PAO) capable of conducting an assessment.
C3PAOs are agencies authorized to determine whether a specific company or organization meets compliance standards and make decisions accordingly. Companies should share only the information required and have it readily available for a more efficient process.
Approved C3PAOs have the knowledge and resources to advise businesses that don’t meet standards or want to reach a higher certification level.
C3PAOs offer more flexibility for the government because they can take on more assessments and provide service continuously. Make sure to hire your C3PAO as soon as possible to avoid any delays in processing.
Go Through the Review Process
Whether doing a self-assessment, going through a third-party provider, or being audited directly by the government, the review process involves looking at critical information and considering whether specific requirements have been met. This step is the most essential part of CMMC compliance.
If you fail, you’ll have 90 days to fix any stated issues and go through the review process once more.
Addressing deficiencies and creating better strategies moving forward is essential for gaining CMMC compliance. By keeping track of continuous improvements and making advised changes, companies can reinforce their security postures and obtain higher compliance scores.
Getting Help with CMMC Compliance
Companies shouldn’t be afraid to find an experienced contractor capable of assisting with their CMMC compliance needs. With the right partner, you can effectively mitigate many of your security concerns and meet your compliance goals before the review process takes place.
Managed cybersecurity solutions offer a consistent set of tools for finding and dealing with hidden vulnerabilities and weaknesses in your security ecosystem.
Companies around the world use managed cybersecurity partners for their cloud management needs. By removing the complexity from the IT environment, managed security services ensure your data is secure from potential theft, destruction, or corruption.
Experienced professionals are waiting to support your CMMC compliance goals and offer support and advice when you need it.
With so many variables associated with CMMC compliance, you must ensure you have everything you need to go through the assessment. Managed security services are an essential part of any comprehensive digital security strategy.