CMMC Fundamentals: 4 Key Steps for Achieving Compliance
As you embark on your journey towards Cybersecurity Maturity Model Certification (CMMC), grasping the nuances of the different compliance tiers becomes paramount. In this post, we'll explore the distinctions between CMMC Level 1 and CMMC Level 2, shedding light on what's needed for compliance and providing actionable steps to navigate the process effectively.
CMMC 2.0, the latest iteration of the Cybersecurity Maturity Model Certification, is currently underway with a phased rollout. Contracts will state which level is required for bid. All requirements are currently expected to flow down, from Primes to all subcontractors and some associated service providers (referred to as either external or cloud service providers). All Department of Defense (DoD) contracts are expected to mandate certification that aligns with this updated standard by Q4 2025, posing a challenge for many organizations to revamp their cybersecurity programs before the deadline.
Components of CMMC Compliance:
Here's what businesses need to focus on:
Clarity on NIST 800-171 Controls: CMMC 2.0 closely aligns with NIST 800-171, offering a smoother transition for most businesses already adhering to this standard. However, it's essential to note that compliance requirements may evolve with the impending release of NIST Revision 3.
Scoping of Level needed and data: Level 1 certification is sufficient for handling of Federal Contract information only (FCI). Level 2 and 3 are specific to Controlled Unclassified Information (CUI). Your contract officer can provide a scope of data specific to the contract.
Robust Reporting: Comprehensive reporting plays a pivotal role in demonstrating compliance with CMMC. Leveraging advanced tools equipped with automatic reporting features can streamline this process, saving valuable time and resources.
Thorough Assessment: CMMC assessments enable the DoD to validate cybersecurity standards implementation. Level 1 compliance requirements will require self-assessment, Level 2 will require organizations to engage Third-Party Assessors (C3PAOs) on a 3 year periodic basis, Level 3 will require a C3PAO assessment with government staff engagement. Level 1 self-assessments will have periodic review, may be subject to spot-checks, and have significant consequences if false claims are made.
Actionable Steps for CMMC Compliance:
Step 1: Define Your CMMC Level:
Understand the level of compliance mandated for your organization. With the release of CMMC 2.0, the structure has evolved, with three distinct levels: Level 1 for basic cyber hygiene, Level 2 for moderate standards, and Level 3 for comprehensive cybersecurity functions. Most organizations will fall under level 1 or 2, depending on the nature of their work and the specific contract. These requirements flow down from prime contractor to their subcontractors.
Step 2: Assess Your Cybersecurity Posture:
If you are a current Defense Industrial Base (DIB) contractor or subcontractor- what is your DFARS score? Do you have a system security plan? Do you have a data flow diagram or shared responsibility table? If you are not already taking these steps; Review your current contracts. You may be years behind your current compliance requirements.
Step 3: Conduct a Gap Analysis:
Identify areas of non-compliance through internal and external assessments. If you are already on the path to achieving NIST 800-171 compliance; Continuous monitoring is part of achieving CMMC level 2 compliance.
Step 4: Identify Cost:
Acknowledge the investment required for CMMC compliance. From process and personnel adjustments to system upgrades and consultancy services, adequate budgeting is crucial for a successful compliance journey. This is a culture change, there is no fast and easy solution.
In Summary:
Navigating the intricacies of CMMC compliance demands a structured approach and proactive measures. By understanding the nuances of the updated standard, aligning with NIST guidelines, conducting thorough assessments, and budgeting appropriately, organizations can effectively achieve and maintain CMMC compliance.
This is a moving target, but the day is coming where those who are prepared will be ready to succeed.
To learn more about how Hoop5 Networks can help your organization achieve and maintain compliance with CMMC standards contact us today to speak with one of our security experts!