The Cybersecurity Maturity Model Certification, or CMMC, has been a topic of conversation for a few years within the Defense Industrial Base (DIB). CMMC is a unified standard for implementing cybersecurity across the DIB, which includes over 300,000 companies in the supply chain. The CMMC is the DoD’s response to significant compromises of sensitive defense information located on contractors’ information systems. The US Department of Defense (DoD) released the much-anticipated Cybersecurity Maturity Model Certification (CMMC) version 1.0•• on January 31, 2020. Since then, CMMC has undergone much scrutiny and discussion. Here is a timeline of CMMC:
September 2020: The CMMC program published by the DoD (now known as CMMC 1.0). This framework assesses a Defense Industrial Base (DIB) contractor’s compliance with a set of cybersecurity standards.
November 2020: A Presidential interim rule became effective, establishing a five-year phase-in period and requiring compliance with NIST 800-71 rules.
March 2021: The DoD announced an internal review of CMMC’s implementation.
November 2021: The DoD announced CMMC 2.0, and updated program and requirements designed to meet certain goals, including:
- Protecting sensitive information to enable and protect the warfighter.
- Dynamically enhance DIB cybersecurity to meet evolving threats.
- Ensuring accountability while minimizing barriers to compliance with DoD requirements.
- Contributing to a collaborative culture of cybersecurity and cyber resilience.
- Maintaining public trust through high professional and ethical standards.
The anticipated launch of CMMC 3.0 has brought new changes and requirements for compliance that are vital for business owners to understand.
The CMMC (Cybersecurity Maturity Model Certification) 3.0 is a long-awaited update to the original CMMC 1.0, which was developed by the Department of Defense (DoD). This update is designed to increase cybersecurity standards across government contractors and subcontractors in order to protect sensitive government data from potential cyberthreats.
In this article, we’ll cover what changes are anticipated with CMMC 3.0 and provide an outlined CMMC compliance checklist for businesses to use as guidance when preparing for their certification audit. We’ll also talk about how an IT provider like Braxton-Grant Technologies can help.
Here’s everything you need to know:
An Overview of CMMC
The Cybersecurity Maturity Model Certification (CMMC) is a certification program developed by the US Department of Defense to ensure contractors handling sensitive information comply with cybersecurity standards and best practices. The CMMC assesses the maturity level of an organization’s cybersecurity practices and processes and assigns a certification level ranging from Level 1 to Level 3 based on the extent to which the organization implements recommended security controls. The certification will be mandatory for all DoD contractors, and the level required for a particular contract will be specified in the Request for Proposal (RFP).
What Businesses Need To Know About CMMC
Since CMMC 1.0 launched in 2020, several changes have been implemented to ensure businesses achieve the highest levels of cybersecurity protection. The major changes to CMMC 2.0 included a scalable approach to CMMC that uses five different maturity levels, rather than one single certification level as was used in CMMC 1.0. In addition, the latest version includes 17 domains with 113 processes that must be completed to become compliant. This is based on anticipating that CMMC 3.0 will continue to utilize the controls of NIST 800-171 which recently came out with a Version 3.
CMMC 3.0 Requirements
Implementing CMMC 3.0 into a company’s existing systems requires time and expertise from an organization’s management team and outside CMMC consultants. To prepare for becoming compliant with the new standard, businesses should break down each step of the process into manageable sections, including:
- Developing appropriate security policies and procedures
- Creating action plans for implementing these initiatives
- Conducting internal audits
- Preparing for external audits
- Maintaining compliance once certified through continued monitoring
CMMC 3.0 Timeline of Changes for 2023
While CMMC is currently in official rulemaking, it is anticipated to be published in 2024 with enforcement likely happening by the end of 2024 or early 2025.
In the meantime, companies doing business with the US Government are CURRENTLY obligated to follow NIST 800-171 under either/booth DFARS 252.204-712 and/or FAR 52.204-21, depending on whether the contract is a Department of Defense contract or a non-DoD Government contract. Check your contracts that you are a prime or sub on and you will likely see one of these two clauses.
CMMC Compliance Checklist
By following these steps closely and working with a reputable partner like Braxton-Grant, businesses can successfully become compliant with NIST 800-171 and subsequently CMMC 3.0 when it is published without compromising any aspect of their data privacy or security operations. Outlined below is the comprehensive CMMC compliance checklist:
Assessments and Audits
These assessments will be conducted by an accredited third-party through either a self-assessment or an external audit process, depending on the company’s size, scope, and complexity of operations. Once these assessments have been completed successfully, organizations will receive a certification indicating they have met the required security controls outlined in CMMC 3.0 compliance requirements.
The CMMC Process
Businesses must use the Cybersecurity Maturity Model Certification (CMMC) process as part of their audit or assessment activities to achieve compliance with CMMC 3.0 standards. The CMMC process involves five phases:
- Prepare
- Assess
- Implement
- Validate
- Monitor
Each phase outlines specific security controls that must be met in order for an organization to be deemed compliant with CMMC 3.0 standards.
But remember, you are likely to already have obligations for compliance with NIST 800-171 on your current contracts. Braxton-Grant Technologies can help you to understand your obligations and take you through the assessment process.
IT Provider Assistance
Businesses benefit from working with an experienced IT provider, like Braxton-Grant, who can assist with the audit preparation process. An IT provider can help companies to meet all their compliance requirements efficiently without compromising any aspect of their data privacy or security operations. In addition, an IT provider can also provide pre-audit preparation services, post-audit assistance, and ongoing maintenance support for security control systems. Working closely with a trusted partner like Braxton-Grant throughout this process helps guarantee success when it comes to auditing.
Implementation
Once businesses have completed their assessment activities, they must implement specific technical safeguards to integrate them into their company’s security infrastructure. This includes establishing the following:
- Access control measures
- Encryption protocols
- Network segmentation components
- Intrusion detection systems, vulnerability tests
- Incident response policies and procedures
- Patch management strategies
- Firewalls and gateways configurations
- Disaster recovery plans and strategies
- Log management strategies and strategies for employee awareness training and education initiatives
CMMC Compliance Checklist
Understanding how to become compliant with CMMC 3.0 is key for any business engaging in government contracts or subcontracts. By adhering to our above checklist and working with an experienced IT provider like Braxton-Grant, companies can ensure they complete all necessary steps along the path toward achieving successful certification. Give us a call today to begin the shift to CMMC 3.0.
