CMMC, the Cybersecurity Maturity Model Certification, is looming on the horizon for Department of Defense (DoD) contractors and subcontractors. The certification outlines the requirements organizations that work with the DoD must meet to protect the controlled unclassified information (CUI) in their systems.
The proposed CMMC rule was officially published in the Federal Register on December 26, 2023, and outlines a four-phase implementation plan.
Phase 1 – Final Rule Effective Date: Conduct a self-assessment for compliance with NIST 800-171 rev2 requirements for all new solicitations and contracts. This requirement includes contracts that cover the use of federal contract information (FCI) and CUI. Suppliers must meet this condition to be awarded applicable new contracts. Phase 2 – 6 months after Final Rule Effective Date: Implement CMMC Level 2 Assessment requirements in contracts and solicitations. Level 2 Assessments must be completed by a CMMC Certified Third-Party Assessor Organization (C3PAO). When the assessment is complete and on an annual basis, a company executive must file an affirmation with the DoD.
Phase 3 – 1 year after the start date of Phase 2: Implement CMMC Level 3 Assessments requirements in contracts and solicitations. Due to highly sensitive CUI levels, Level 3 Assessments are performed by DIBCAC from the DoD. CMMC Level 3 requirements may be included as a condition of awarding DoD contracts.
Phase 4 – Oct 1, 2026: CMMC requirements are scheduled to be included in all applicable contracts and solicitations by the DoD.
Proactive preparation is critical to avoiding last-minute compliance scrambles and securing (and keeping) those coveted DoD contracts.
Where do you start with CMMC?
Don’t fret, warriors of the supply chain! Here are ten actionable steps you can take today to conquer the CMMC and prove your organization is cyber-savvy to Uncle Sam:
1. Educate Yourself (and Your Team) on CMMC Requirements
Knowledge is power, and understanding the CMMC framework is your first line of defense. Dive into the CMMC website, attend webinars, and invest in training for yourself and your employees. Familiarity with the three levels of maturity – from basic hygiene to advanced cyber-fortress – will guide your roadmap for improvement.
2. Conduct a Cybersecurity Self-Assessment
Don’t wait for an official assessment to reveal your vulnerabilities. Take a proactive approach with a thorough self-evaluation. Look at your existing policies, procedures, and technical controls through the lens of the CMMC requirements. Performing this internal audit will highlight gaps and prioritize areas for improvement.
3. Inventory Your CMMC Data
Not all data is created equal, and understanding the specific types of information you handle is crucial. Identify Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) in your systems and map them to relevant CMMC controls. This will help you apply the right level of protection to the right data.
Need a primer on CUI? Download and read the CUI Frequently Asked Questions and Quick Start Guide from the Defense Counterintelligence and Security Agency (DCSA).
4. Implement Access Control Measures
Secure your data from unauthorized access with robust access control policies. Enforce multi-factor authentication (MFA) for all systems handling CUI and FCI. Implement role-based access control (RBAC) to limit privileges based on job function and need-to-know. Remember, least privilege is your mantra!
5. Fortify Your Endpoint Defenses
Endpoint devices like laptops and smartphones are often entry points for attackers. Install endpoint detection and response (EDR) solutions to detect and respond to malicious activity in real time. Implement antivirus and anti-malware software and keep all devices updated with the latest security patches.
6. Encrypt Sensitive Data
Encryption scrambles your data into an unreadable mess for prying eyes. Encrypt CUI and FCI at rest and in transit – think locked filing cabinets and armored trucks for your digital assets. Implement strong encryption algorithms that are FIPS 140-2 validated and key management practices to secure the keys that unlock the code.
7. Train Your Troops (CMMC Cyber Warriors, that is)
Security awareness training is not just a checkbox exercise. Regular training sessions equip your employees with the knowledge and skills to spot phishing emails, avoid social engineering attacks, and practice safe security habits. Make it engaging, make it relevant, and make it continuous – a well-trained workforce is your impenetrable shield.
8. Document, Document, Document
Cybersecurity policies and procedures are only effective if written down, understood, and followed. Develop a comprehensive set of CMMC-compliant policies and procedures, covering everything from incident response to data breach notification. Train your employees on these policies and ensure they’re readily accessible for reference. Ensure your System Security Plan (SSP) and Plan of Action and Milestones (POA&M) are current and comprehensive. Agree on a documented Shared Responsibility Matrix with your Cloud Service Provider (CSP).
9. Build Your Cybersecurity Arsenal
Investing in the right tools can significantly enhance your cyber defenses. Consider adopting security information and event management (SIEM) solutions for consolidated threat intelligence and log analysis. Secure cloud access control providers (CASBs) can protect your data in the cloud, a rapidly growing storage space for DoD projects.
10. Partner with CMMC Experts
No one is an island, especially in the complex world of cybersecurity. Seek guidance from CMMC Registered Practitioners and advisors who can help you navigate the CMMC framework, implement controls, and prepare for assessments. Their expertise can save you time, resources, and headaches.
Remember, CMMC compliance is not a sprint; it’s a marathon. Start small today, make incremental progress, and celebrate your milestones. By taking these steps today, you’ll be well on your way to conquering the CMMC and securing your future as a trusted partner to the DoD.
CMMC Registered practitioners from EXTEND Resources can perform an internal audit and work with you and your MSP to complete your level 1 or level 2 self-assessment today. Contact us to get started and earn more about our information security and data privacy services.