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.
In today’s rapidly evolving digital landscape where cyber threats are becoming increasingly sophisticated and prevalent, safeguarding sensitive information is extremely important. For businesses involved with the Department of Defense (DoD) as contractors or subcontractors, the need to implement robust cybersecurity measures cannot be overstated.
One critical regulation that demands attention is the Cybersecurity Maturity Model Certification (CMMC), a framework designed to measure and enhance companies’ cybersecurity posture and processes within the Defense Industrial Base (DIB) supply chain. CMMC is currently in the rule making process but will be here quickly given the amount of time it takes for a company to get all controls in place to be compliant. In the mea time, contractors should be mindful of recent updates to the Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012, which mandates compliance with specific cybersecurity requirements to protect valuable defense information. DFARS 7012 requires defense contractors to: Provide adequate security to protect unclassified Covered Defense Information (CDI). To provide adequate security, contractors must implement the 110 security controls stipulated in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171.
The CMMC compliance deadline is expected to take effect in October 2025. DFARS 7102 is here NOW. Keep reading for a deep dive into the importance of staying compliant with upcoming changes to the CMMC clause and how waiting too long can be detrimental.
Are You CMMC Compliant?
The CMMC standard will provide a clear roadmap for contractors to enhance their cybersecurity practices, and with over 300,000+ organizations that make up the Defense Industrial Base (DIB), organizations need to stay updated and aligned with the latest frameworks. By adapting to emerging threats, businesses can move closer toward safeguarding sensitive data and maintaining their security posture.
The Recent Changes to the CMMC Regulations
In November 2021, the DoD announced CMMC 2.0, which aims to do the following:
- Safeguard sensitive information to enable and protect the warfighter
- Enforce DIB cybersecurity standards to meet evolving threats
- Ensure accountability while minimizing barriers to compliance with DoD requirements
- Perpetuate a collaborative culture of cybersecurity and cyber resilience
- Maintain public trust through high professional and ethical standards
Additionally, this mandate comes with several fundamental changes that redefine the original CMMC program requirements, including:
- A streamlined model that takes the CMMC’s original five compliance levels to three
- Reliable assessments that allow Level 1 and Level 2 companies to show compliance via self-assessments
- More flexible implementation and speed that allows the government to waive the inclusion of CCMC rules under limited circumstances
While not official – Industry anticipates that the final rule for CMMC, once published will look very much like CMMC 2.0 did before being pulled for official rulemaking.
Understanding the DFARS Rule 252.204-7012
The DFARS clause 252.204-7012 is a pivotal regulation established by the Department of Defense (DoD) to safeguard sensitive unclassified information held by contractors and subcontractors. This clause necessitates compliance with a set of security requirements, including the implementation of the NIST SP 800-171 framework. The primary objective of these measures is to thwart cyber threats and unauthorized access, thereby fortifying the defense supply chain and upholding national security.
NIST SP 800-171: A Foundation for Cybersecurity
At the heart of the DFARS rule lies the implementation of the NIST SP 800-171 framework. Developed by the National Institute of Standards and Technology, this publication offers a comprehensive set of guidelines to enhance the cybersecurity posture of organizations that handle controlled unclassified information (CUI). The framework encompasses 14 families of security requirements, ranging from access control to incident response, with each family addressing specific aspects of cybersecurity. (Note: CMMC is based on these same controls so complying with NIST 800-171 will position your company for CMMC compliance.)
The Importance of Adhering to the CMMC Rules
Cybersecurity has long been a concern within DoD contracts, but historically, it has been addressed through recommended best practices, self-attestation, and isolated security requirements. This system created an inconsistent patchwork of protection.
The CMMC program will provide a unified cybersecurity standard that all contractors must meet at the appropriate level. By directly correlating certification to contract eligibility, CMMC gives contractors extrinsic motivation to pursue security.
With CMMC, contractors have defined standards to guide their security investments and improvements. The model outlines cyber hygiene practices all contractors should execute, regardless of size and sophistication. To top it off, CMMC is designed to be cost-effective and achievable for businesses to implement.
The Risk of Falling Behind on CMMC Compliance
Given the critical role played by DoD contractors and subcontractors within the defense supply chain, timely compliance with the CMMC framework is non-negotiable. Failing to adhere to the DFARS and NIST regulations jeopardizes the loss of DoD contracts and exposes businesses to reputational damage and potential legal ramifications. As cyber threats evolve, the urgency to fortify cybersecurity defenses has never been more pronounced.
Staying Up-to-Date With Evolving Compliance Measures
To remain informed and compliant for NIST 800-171 and CMMC, contractors can invest in the following:
Continuous Learning
Regularly educate yourself and your team about the evolving landscape of cybersecurity regulations, best practices, and emerging threats.
Industry Resources
Leverage resources from reputable organizations like NIST, DoD, and cybersecurity associations to stay current with updates and guidance.
Regular Audits
Conduct internal audits to identify areas for improvement and make sure that your cybersecurity measures align with the latest requirements.
Professional Partnerships
Collaborate with experts, consultants, or cybersecurity service providers who specialize in CMMC compliance and can offer timely insights.
Navigate the Challenges of NIST 800-171 and CMMC Compliance With Braxton-Grant
Understanding the intricacies of the CMMC framework can be daunting. However, partnering with experts in the field can ease this journey significantly. At Braxton-Grant, we recognize the gravity of cybersecurity and the challenges organizations face in achieving compliance. Our team of seasoned professionals is dedicated to guiding you through the intricacies of these regulations, offering a comprehensive suite of cybersecurity solutions tailored to your needs.
We’ve successfully worked with government agencies and private industries worldwide, so we can customize our solutions to fit your unique risks, compliance obligations, and vulnerabilities. We are committed to providing practical and expandable solutions for your small business.
