The current state of the world economy demands leaner, more transparent, and fiscally responsible governance. In an attempt to answer this call, the U.S federal government is rapidly becoming more dependent on contractors as quality control and cost-cutting measures.
What Is CMMC Compliance?
According to usaspending.gov, spending on supplies and contractual services reached $765.7 billion as of June 2020. And as the world economy rebounds, this figure is set to rise
Such contracts can put your business in direct contact with sensitive governmental institutions. Such departments include the Department of Defence (DoD), the Treasury, Health services, and even NASA. That’s why the government needs to ensure your business procedures and the tools that support it enough integrity to secure Confidential Unclassified Information (CUI) from the malicious intent of hackers.
So, how do you proceed in fulfilling such a requirement? Well, you should institute a practical IT security framework to qualify for CMMC certification. Such standardized measures came into full effect on July 22. This means you will not be able to transact with the various government institutions without such compliance.
Fortunately, the federal government is ready and willing to work with more companies that are privately owned.
“We estimate that over 7,500 organizations will be certified by 2021.” Katie Arrington, CIS office of the undersecretary of defense.
So, let’s waste no more time finding out what you can start doing to attain CMMC compliance.
CMMC: Definition in a Nutshell
CMMC is an acronym for Cybersecurity Maturity Model Certification. This fresh raft of compliance measures will be a compulsory minimum requirement for businesses hoping to secure competitive Federal contracts.
CMMC compliance allows the DOD to vet your business’ initiatives and the precautions for Cybersecurity controls. This is essential in securing CUI, financial data, and privileged Contract Information.
Such standards include the following:
- NIST SP 800-53
- ISO 27001,
- ISO 27032
- NIST SP 800-171
CMMC unifies all the control-points of such security requirements into a single conducive structure. It is also a more straightforward process that eliminates all the complexities of previous certification standards.
When Will This Compliance Be Mandatory?
OUSD (A&S) expects CMMC to be fully implemented by the end of fall 2020. Here’s the expected timeframe for rolling out CMMC:
- April – May 2020: training of Third-party assessment Organizations (3PAOs)
- June 2020: CMMC will feature in Requests for Information (RFI’s)
- August – September 2020: CMMC certification will function in Requests for Proposal (RFP’s)
This means your business will need this certification by fall 2020 if it wishes to renew bids or to start bidding for government contracts.
What’s the Essence of CMMC Certification?
Cybercriminals have identified contractors as a vulnerable endpoint in accessing information that could be detrimental to national security. Pervious security measures and standards such as DFARS 252-204-7012 may be complicated, but it’s still fallible.
As a business, you’re fully aware of the inherent risks of transacting with other companies in diverse industries. In 2019, the Federal government suffered 83 data breaches that exposed 3.6 million sensitive files. That was just 5.6% of the annual.
Our adversaries have been able to advance their military technology because of such lapse. Case in point, China’s J-class of stealth fighters look and function eerily close to the F-35.
What are the Essential Components of CMMC?
The good thing with CMMC is that it recognizes the fact that not all pieces of information share the same level of complexity. Therefore, businesses can have varying clearance levels. This model tests framework procedures through five distinct maturity levels.
The First Level
The most basic level requires your organization to have the necessary IT security measures in place. It also calls for the full implementation of 17 NIST SP 800-171 Rev2 controls
Measures you need to have in place include:
- Anti-malware and virus
- Effective passwords
- Collation of incident reports
- Sufficient data protection measures
CMMC Maturity: Emergent.
The Second Level
This level requires your company to adhere to the best practices in cybersecurity and have a well-documented history of such initiatives. It’s fulfilling 46 NIST SP 800-171 Rev2 controls to get CMMC certification.
Things you’ll need to do:
- Prove you have enough situational awareness on cyber threats
- Perform a comprehensive risk management assessment
- Have a laid down Security contingency and continuity
- Have business continuity measures such as sufficient data back-ups in place
CMMC Maturity: Basic operational procedures, IT security policies, and contingency plans are in effect through all your business processes.
The Third Level
This is more of an elaboration of NIST 800-171 r2 standards that you have to fulfill before you get the certification. You must also ensure that NIST SP 800-171 Rev2 controls are fully implemented down to the final stage.
What you’ll need to do includes:
- Have zero-trust login measures such as MFA (multi-factor authentication) in place
- Share regular updates on IT security threats with relevant stakeholders
- Show complete compliance to NIST SP 800-171 plus 20 controls
CMMC Maturity: Activities will be subject to periodic reviews to ensure your organization follows all guidelines.
The Fourth Level
Here’s where things start getting critical. You’ll need to ensure your network and systems infrastructure has the most cutting edge and effective cybersecurity. Such measures will be carefully scrutinized to ensure they remain proactive. You will need to implement 26 controls of NIST SP 800-171 Rev B to pass this audit level.
Associated tasks include:
- Have a dynamic execution environment, such as detonating chambers.
- Include mobile devices in your IT security blanket
- Demonstrate effective use of DLP technologies
- Proactive threat detection and hunting initiatives
- Have a well-segmented/ partitioned data network
- Show adequate consideration for the risks associated with your supply chain
CMMC Maturity: Activities are regularly reviewed for consistency, effectiveness, and proper management.
The Fifth Level
The penultimate level classifies highly advanced organizations that have sophisticated cybersecurity. To attain CMMC level 5 certification, you will need to effect an additional 30 controls of NIST SP 800-171 Rev B and satisfy level 4 audit requirements.
It’s more about sustaining IT security through managerial practices as opposed to satisfying additional technical requirements.
Associated tasks include:
- Have a 24/7 Security operations center (SOC)
- Effective devices authentication
- Cyberspace maneuver operations
- Real-time asset location and tracking schemes
- Enterprise-wide custom protections
CMMC Maturity: All activities within your organization are standardized for all applicable hardware and data networks. Any improvements are also updates and shared with all associated stakeholders.
What are Its Similarities and Variations to NIST?
CMMC certification requires a third party audit/assessment or 3PAO, unlike previous compliance measures. Attaining CMMC, certification from level 3 -5 satisfies all the criteria of NIST concerning CUI.
However, Tailoring Criteria (800-171 Appendix E) requires your organization to have all the basic NIST security protocols. You risk not attaining compliance by failing to address these basic controls.
How Can Your Organisation Acquire CMMC Certification?
A level 1 CMMC is the essential minimum requirement if you want to be a Federal contractor. This criterion is also subject to your industry’s threats posed by nation-state actors because of varying levels of sensitivity associated with government data.
The first thing you need to do is schedule a CMMC audit with a qualified 3PAO. They will perform a thorough review of the technology and data networks that power your business processes. Once this assessment is done, you’ll be presented with a Plan of Action and Milestones (POAM).
You can pass this POAM to your MSP for sanitation. From then on, you can rest assured that your company meets 100% compliance for the prescribed CMMC certification for your maturity level.
This could be a drawn-out process, so it’s always best to get started as soon as possible. After all, you would not want to lose on lucrative Government contracts. You can breathe easy as the audit findings will be kept private, and only your certificate of compliance will be viable via the Government web database.
Why Should You Get Started on CMMC Certification Immediately?
CMMC certification will give you a competitive edge over other businesses in need of DOD contracts. This is especially true since most contractors are dragging their feet until the end of the OUSD (A&S) grace period.
Does this have any far-reaching implications? Well, there are numerous strategic business advantages to CMMC compliance. Most Federal contracts run for up to 5 years. If you attain such compliance now, your revenue streams are set as other contractors struggle to catch up.
Other Strategic Advantages Include:
- A minimized risk of sustaining critical data breaches
- Reduced risk of internal data breaches and other threats even those occasioned by human error
- CMMC certification also aligns your business to different compliance standards such as HIPPA and FISMA
- Certification can also help you overcome the threats posed by nation-state actors
How Will CMMC Certification Affect Your Organization?
CMMC requirements will radically transform the way the government approaches doing business with civilian contractors. Here are a few ways such changes will influence every associated industry.
Enhanced Cybersecurity Will Become a Bare Minimum Requirement for Federal Government Procurement Processes
CMMC compliance has put IT security at the top of due diligence, oversight, and procurement supervision. Your company’s CMMC maturity level will be a vital aspect of the government supply chain.
It also touches on contractors and subcontractors that previously did not need to adhere to any compliance requirements. Such companies include those in industrial domains that did not covered defense information (CDI)
All companies transacting with the government will need to receive CMMC levels 1 through 5 after this new regime of requirements takes full effect after September 2020.
Such policies a strict but will have a multiplier of benefits that include:
- Eliminating the confusion created by various security and compliance vetting agencies
- Third-party auditing will unify and streamline IT security vetting and assessment standards across all industries
- The neutrality of third party auditors will enhance transparency among contractors. There will be fewer fraudulent claims, which will ensure taxpayer dollars are put into the right use.
Non-Compliant Organizations Will Be Disqualified From Bidding
The government will effect a triage of measures against all non-compliant organizations. They will use the five levels of compliance to decide which business can qualify for a particular contract.
There Will Be a Rise in CMMC Consultants
Since CMMC will be the new standard, qualified auditors and CMMC advisers will be in high demand. This demand is set to rise to an unprecedented level by January 2021. As a result, every qualified assessor will look to leveraging their skills to help all the contractors that will be in a rush to meet this deadline.
What Can Your Organization Do to Prepare?
If you’ve been able to comply with previous compliance requirements, then you have a great foundation. However, you’ll still need to do a few more things to get full CMMC certification status. Here are a few tips to help you get started.
Start an In-House Audit
If your organization has the required personnel and resource, you can use a self-assessment guide to get things rolling. But, this guide will only get you through to level two. You will need to take other measures for all the different control points.
Outsource a Qualified Auditor
Compliance can be a sensitive issue, so if you lack the internal resources for an effective audit, it’s best to seek a seasoned professional’s services. Fortunately, there are various MSPs specialized in such tricky issues. So, Engaging one to help you can be a great way to save loads of valuable time and money.
What’s Your Next Move?
The months counting down to January 2021 will be tough for a majority business that wants to get those lucrative government contracts. Such requirements are stringent, but the federal government’s unifying compliance formula will make things a little easier.
As your organization moves forward, it’s essential to have a partner that understands the complexities of dealing with defense department contracts.
LaScala IT can be such a partner. We have a capable team of seasoned IT professionals, and we are proud to say that we are veteran-owned. Feel free to give us a call anytime you are ready to get started on this crucial journey.