SysArc recently contributed to an Exostar panel discussion entitled “NIST 800-171 & CMMC 2.0 Non-Compliance: What’s the Risk?” featuring SysArc CEO, Tim Brennan and GDIT CISO, Michael Baker. Streamed live on April 27th, 2022 — This webinar was recorded and is available to watch below.

In this webinar we discuss the following:

• • Threat Landscape: Cyber threats that exist today for DIB suppliers and why we all should be concerned.
  • Getting Prepared: SSPs, POA&Ms, SPRS scores and what DIB suppliers need to be doing now to be ready and compliant for upcoming compliance audits. 
  • DIBCAC Assessments: DCMA continues to conduct random DIBCAC assessments on suppliers to enforce DFARS 7019 & 7020.
  • Common Questions from DIB Suppliers:
    • What is Controlled Unclassified Information (CUI)?
    • Regarding CMMC Level 2, who will need a third-party assessment and who will need a self-assessment?
    • We are a small company, are the requirements scalable?
    • Has a firm timeline been set for the requirements to be validated by Tier 1 manufacturers and who is responsible for enforcing compliance?
    • What happens if I haven’t submitted an SPRS score yet?
    • Will my Prime check to see if I’m compliant
    • As a small business with few employees we use POA&Ms to create processes to be compliant with NIST. Is this an acceptable long-term solution?

  Need Help with CMMC? SysArc Can Help

  We are a Managed Security Service Provider (MSSP) that specializes in helping DIB suppliers protect their information systems and comply with the cybersecurity regulations from the Department of Defense. We’ve consulted over 1000 companies and helped them navigate the complexities of DFARS, CMMC, and NIST 800-171. 

  To learn more about preparing for CMMC and how SysArc can help, please visit our CMMC guide here. If you’d like to speak with our team about your compliance needs, please feel free to give us a call or schedule a CMMC consultation. 

As a Managed Security Service Provider (MSSP) for Department of Defense (DoD) contractors throughout the United States it is one of our missions to keep Defense Industrial Base (DIB) companies updated on DFARS requirements and the rollout of CMMC. This is so they can meet the DoD’s cybersecurity requirements and continue to offer their products and services to the department without any delays or surprises.

With that said, it is critical for DIB companies to understand that the Defense Contract Management Agency (DCMA) is currently conducting random DIBCAC assessments on company’s IT systems to enforce DFARS 7019 and 7020. For contractors who have either failed to start implementation of cybersecurity requirements or have put them on hold, we advise to have them completed immediately.  

What is the DCMA?

The DCMA provides contract administration services for the Department of Defense (DoD) and is an essential part of the acquisition process. The agency manages 250,000 contracts, valued at more than $3.5 trillion. DCMA makes sure DoD, other federal agencies, and partner nation customers get the equipment they need, delivered on time, at projected cost, and meeting all performance requirements.1

What is DIBCAC?

DCMA oversees the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). DIBCAC is a team of technology professionals that perform two primary missions:

1. Assess DIB Supplier Cybersecurity: Assess DIB companies to ensure they are meeting contractually required cybersecurity standards. The team ensures contractors have the ability to protect controlled unclassified information for government contracts they are awarded.
2. Establish & Expand CMMC Assessment Capabilities: The DIBCAC is also a member of the government team establishing the Cybersecurity Maturity Model Certification (CMMC) program to expand cyber assessment capabilities throughout the defense industrial base. 

Source: https://www.dcma.mil/News/Article-View/Article/2981222/tech-team-wins-cybersecurity-award/

What are DIBCAC Assessments?

DIBCAC assessments are essentially audits of DoD contractor systems to ensure they have implemented the security controls of NIST 800-171 as required by DFARS 7019 & 7020.

According to John Ellis, the Technical Directorate’s Software Division director at DCMA, the following are problems that they are seeing regularly with the audits they have completed so far:

• Lack of Multi Factor Authentication (MFA)
• Poorly written or non-existent policies
• Lack of FIPS 140-2 validation for encryption solutions
• Poorly designed/implemented network segmentation

If a DoD contractor fails to pass a DIBCAC assessment, they may be ineligible to provide their products and services to the DoD. Because these assessments are currently being conducted, it is essential that suppliers are prepared now. 

Where to Get Help & How to Prepare

The laws and requirements of DFARS and CMMC can be daunting for many DoD contractors  — especially those that lack the resources and knowledge to implement security controls themselves. As a DFARS and CMMC consultant, we help DoD suppliers navigate the complexities of the DoD’s cybersecurity policies and have a team of cybersecurity professionals to implement security controls on their behalf.

To learn more about how to prepare for CMMC, visit our CMMC preparation guide. Also, feel free to give us a call or request on consultation. Whether you’re a small or large company, we’re happy to discuss your unique situation and help you find the best path to preparing for a DIBCAC assessment.   

Summary of Key Updates from CMMC 1.0 to 2.0

Below is a summary of the key changes you need to be aware of when understanding the difference between CMMC versions 1.0 and 2.0. For an in-depth guide into CMMC 2.0 changes, see here.

1. Only 3 CMMC Levels: CMMC Levels 2 and 4 from the original CMMC framework have been eliminated, leaving only 3 current CMMC Levels. These Levels are detailed below.
2. Level 1: Now only requires an annual self-assessment and affirmation by company leadership. No changes to the 17 basic cyber hygiene practices required.
3. Level 2: The “old” CMMC Level 3 now becomes Level 2. 20 controls have been eliminated from the original framework’s Level 3 requirements, leaving contractors only having to implement the 110 controls from NIST 800-171. The DoD will identify “prioritized acquisitions” that must undergo an independent third-party assessment against the new Level 2 requirements. All other organizations will only need to perform a self-assessment and affirmation by company leadership.
4. Level 3: This level will replace CMMC Levels 4 and 5 from the original framework. While details are still being worked out, it is expected that this level will include controls from NIST SP 800-172 and assessments will be government-led.

For more information about CMMC compliance and how to comply with CMMC 2.0, please read our CMMC Compliance Guide. If you have any questions about getting your organization in compliance, please don’t hesitate to give us a call or schedule a consultation.

Every organization within the Department of Defense (DoD) supply chain—including prime contractors and subcontractors—will be required to achieve at least one of the levels of CMMC compliance. According to the DoD, the CMMC compliance regulations will impact over 300,000 organizations.

Does My Organization Need CMMC Compliance?

If your organization is one of the following, you will need to achieve CMMC compliance in order to hold and be awarded contracts by the DoD:

• DoD prime contractors
• DoD subcontractors
• Any supplier within the DoD supply chain

Levels of Compliance

Depending on the amount and type of sensitive information your organization transmits, you’ll have to achieve one of 3 levels of CMMC compliance.

The DoD contract specifies which level of compliance an individual contractor must meet. For example, prime contractors may have to achieve Level 3 compliance while subcontractors may only be required to achieve Level 1.

Using the CMMC standards, organizations will be issued a score indicating the organization’s level of compliance. Each level requires you to comply with the previous level’s standards as well. The three levels are:

• Level 1 Foundational: Basic Cyber Hygiene. Level 1 focuses on basic cyber hygiene requirements. There are 17 practices that need to be implemented from FAR 52.204.21.
• Level 2 Advanced: DIB companies who send, receive and store controlled unclassified information fall into this category. There are 110 controls that must be implemented from NIST SP 800-171.
• Level 3 Expert: This level is for DIB companies who send, receive and store information from the Defense Industry’s high-risk programs. While details are still being worked out, it is expected that this level will include controls from NIST SP 800-172.

The CMMC Accreditation Body (CMMC-AB) is working to ensure that third-party assessments are available for contractors, subcontractors, and suppliers at each of the CMMC levels. In the meantime, organizations should consider working with a CMMC compliance consultant to prepare for their official audits because RPOs have gone through formal training, signed a code of ethics, and are more qualified and experienced than consultants that have not.

If you are interested in learning more about CMMC and the process for becoming compliant, please read our CMMC Compliance Guide. If you have any questions, don’t hesitate to give us a call or schedule a free consultation. Our team will be happy to help your organization navigate the complexities of compliance.

The process of becoming CMMC compliant can be broken down into three essential steps:

1. Assess your IT infrastructure
2. Remediate based on your assessment
3. Get assessment by C3PAO

Let’s walk through each in more detail.

Step 1: Assess Your IT Infrastructure

Typically the first thing you’ll need to do is conduct an assessment of your current IT infrastructure against the control framework that aligns with your desired CMMC Level. This is also called a gap analysis and is the basis for understanding what controls, processes and procedures need to be implemented to achieve compliance. Companies with the right resources will be able to conduct their own self-assessment, while some will need to outsource the assessment to a third-party, such as an CMMC Registered Provider Organization (CMMC RPO). Self-assessment resources can be found here and templates for System Security Plans (SSP) and Plan-of-action and Milestones (POA&M) can be found here and here, respectively.

Step 2: Remediate

The next step is remediation which involves the actual work to implement the controls, processes and procedures that are called out in the assessment. Again, companies with the resources may be able to perform the remediation work themselves, while others might consider utilizing an RPO. Even if a company does have the resources, an RPO will likely be able to do it faster and more efficiently.

Step 3: Get assessed by a C3PAO

For companies that need to meet CMMC Level 2 and 3, the last step to become CMMC compliant is to get an official assessment from a Certified Third-Party Assessor Organization (C3PAO). However, no assessments are currently being performed as the Assessors are being trained. The first assessments are expected to start in 2022.

When To Call In An Expert

If you are having trouble navigating the complexities of your self-assessment and/or developing an SSP and POA&M, it may be time to call in an expert to help. As one of the nation’s top CMMC experts, we’ve helped over 1000 DoD contractors get prepared for CMMC. Please feel free to request a consultation to speak with us about your challenges with CMMC, DFARS and NIST 800-171 and how we can help. Also check out our CMMC compliance guide for more information.

We recently presented in a webinar entitled, “CMMC 2.0, NIST 800-171 & Current Threat Landscape,” with the Small and Emerging Contracting Advisory Forum (SECAF).

In this webinar we discuss the following:

• Important changes with the release CMMC 2.0 and what this means for you
• DFARS 7012 and NIST 800-171
• The current theat landscape for the DIB
• Frequently Asked Questions from the community

Watch the webinar here:

A CMMC assessment is the process in which a company’s IT network is assessed against the cybersecurity controls required for each specific level of CMMC compliance. The control frameworks for each level are as follows:

• Level 1 Foundational: FAR 52.204.21
• Level 2 Advanced: NIST SP 800-171
• Level 3 Expert: NIST SP 800-172

When it comes to the subject of CMMC, the word “assessment” gets thrown around a lot. There are a few different versions of the CMMC assessment and it’s important to understand what each one is and the purpose it serves:

1. Self-Assessment: These are assessments that are performed in-house by employees within the organization. The National Institute of Standards and Technology (NIST) has provided a self-assessment handbook for NIST 800-171 for companies that want to self assess. That can be downloaded here. There is no self-assessment handbook for FAR 52.204.21 or NIST 800-172.
2. Assessment by a Registered Provider Organization (RPO): These RPOs are third-party consultants that conduct their own assessments of a company’s network so that they can help prepare the organization for an official assessment by a C3PAO. Technically, any Managed Service Provider (MSP) can perform CMMC assessments, however, we recommend that you choose an RPO since they’ve been audited by the CMMC-AB and are qualified to perform the task.
3. Assessment by a Certified Third-Party Assessor Organization (C3PAO): These are the official assessments that are conducted during the certification process.

If you have additional questions about CMMC, check out our CMMC Compliance Guide, or give us contact us for a free consultation and to learn about how SysArc can help your company navigate the complexities of complying with DFARS, NIST 800-171 and CMMC.

The CMMC Accreditation Body (CMMC-AB) is the only authorized entity to choose third-party assessors (C3PAOs) who can give certification for CMMC.

Registered Provider Organizations (RPOs), like SysArc, can provide excellent tools and services to help the organization reach compliance standards, but they do not generally provide official assessments or certifications.

How the CMMC-AB Chooses Third-Party Assessors

The CMMC-AB is responsible for role alignment between the CMMC, the CMMC Assessment Body (CMMC-AB), and the CMMC Certification Body (CMMC-CB). The role alignment identifies which companies are performing what tasks within the CMMC process.

The assessment body evaluates all organizations that want to provide certification to ensure they are following the appropriate standards and there is no conflict of interest. The certification body then audits organizations that provide CMMC assessments and ensures they are correctly following assessment process guidelines.

Any person or organization wishing to provide CMMC certification must be approved by the CMMC-AB through this application process.

How to Schedule an Official Certification Assessment

The CMMC certification process is divided into two phases: the self-assessment or an assessment by a third-party consultant, and the official assessment. The self-assessment can be completed at any time, while organizations must wait until sometime in 2022 for their official assessment appointment since assessors are still in training.

One of the key steps in becoming a CMMC certified organization involves preparing for your official assessment during this period. Organizations Seeking Certification (OSCs) can prepare by working with a reliable CMMC Consultant to work towards compliance now.

If you are a DoD contractor and are wanting to learn more about how to prepare your organization for DFARS and CMMC, read our CMMC Compliance Guide or contact us for more information about how SysArc can help you meet DFARS requirements and prepare for CMMC.

To understand the difference between DFARS and CMMC, it is helpful to know why the Department of Defense (DoD) created the Cybersecurity Maturity Model Certification (CMMC) in the first place.

The DoD created CMMC as a “verification component” of the Defense Federal Acquisition Regulation Supplement (DFARS) law. What does “verification component” mean? When DFARS 7012 was originally passed, DoD contractors only needed to state that they implemented the cybersecurity controls of DFARS. Basically, implementation was based on trust. This resulted in a poor adoption rate within the Defense Industrial Base, which pushed the DoD to clamp down and create a verification mechanism to ensure DoD suppliers were in fact compliant with DFARS. While CMMC is still being rolled out, this verification mechanism will come in the form of 3rd party audits from CMMC Third-Party Assessor Organizations (C3PAOs).

In short, DFARS is the legal text for the cybersecurity requirements that all DoD suppliers must follow, and CMMC will be the verification mechanism for ensuring that it’s actually being implemented.

With the new CMMC 2.0 model, not all DoD Contractors will be subject to a 3rd party assessment — only ones that are working on what the DoD calls “prioritized acquisitions.” Some will only be required to perform a self-assessment and affirm their compliance annually. The DoD has not yet announced how it will prioritize acquisitions.

Still, with the Department of Justice (DOJ) announcement that it will start pursuing government contractors who falsify cybersecurity affirmations, it is imperative that contractors have the documentation and evidence to back up their affirmation of compliance, even if they will not be assessed by a C3PAO.

If you are a DoD contractor and are wanting to learn more about how to prepare your organization for DFARS and CMMC, read our CMMC Compliance Guide or contact us for more information about how SysArc can help you meet DFARS requirements and prepare for CMMC.

As a Managed Security Service Provider (MSSP) that specialises in helping DoD contractors navigate the complexities of cybersecurity and compliance, we’ve been closely monitoring the evolution of the Cybersecurity Maturity Model Certification (CMMC) since its inception in 2020 and going back to 2016 when DFARS 7012 was just getting off the ground.

On November 4th, 2021, the DoD released CMMC 2.0 which includes several updates and changes to the original framework.

This short guide was written for DoD contractors so that they can understand what these changes mean for their organizations and take the appropriate actions for their company.

Summary of Key Updates: CMMC 1.0 vs. CMMC 2.0

• Only 3 CMMC Levels: CMMC Levels 2 and 4 from the original CMMC framework have been eliminated, leaving only 3 current CMMC Levels. These Levels are detailed below.
• Level 1: Now only requires an annual self-assessment and affirmation by company leadership. No changes to the 17 basic cyber hygiene practices required.
• Level 2: The “old” CMMC Level 3 now becomes Level 2. 20 controls have been eliminated from the original framework’s Level 3 requirements, leaving contractors only having to implement the 110 controls from NIST 800-171. The DoD will identify “prioritized acquisitions” that must undergo an independent third-party assessment against the new Level 2 requirements. All other organizations will only need to perform a self-assessment and affirmation by company leadership.
• Level 3: This level will replace CMMC Levels 4 and 5 from the original framework. While details are still being worked out, it is expected that this level will include controls from NIST SP 800-172 and assessments will be government-led.

Visualizing the New CMMC 2.0 Levels:

Source: https://www.acq.osd.mil/cmmc/about-us.html

CMMC 2.0 Changes Explained

Beyond the modification of the Levels, here are two key changes that DoD contractors need to be aware of.

Change One: Assessment Requirements

Level 1: Self-Assessments

One of the biggest complaints from DoD contractors was that CMMC 1.0 required them to undergo third-party certification, even at CMMC Level 1. CMMC 2.0 eliminates this requirement. Instead, contractors can perform their own self-assessments and will only be required to affirm annually that they comply with CMMC 2.0 Level 1.

Level 2: Third-Party Assessments & Self Assessments

CMMC Level 2 is divided into two separate assessment requirements. Only DoD Contractors working on “prioritized acquisitions” will need to undergo a third-party assessment every 3 years. All other contractors are permitted to perform a self-assessment and affirm annually that they comply with CMMC 2.0 Level 2.

The DOD has not yet announced how it will prioritize acquisitions.

Level 3: Government-Led Assessments

CMMC Level 3 applies to only the most sensitive and high-risk DoD projects. Therefore DoD contractors who fall into this category will need to undergo a government-led assessment every 3 years.

Change Two: Allows Plan of Action and Milestones (POA&M)

Another big criticism from DoD Contractors was that they were being required to meet every single practice and process for their required Level of certification. CMMC 2.0 allows for the DoD contractors to submit a Plan of Action and Milestones, also known as a POA&M, for those practices and processes not yet met.

Important: DFARS 7012, 7019 & 7020 Are Still Required

A very important fact is that DFARS 7012, 7019 and 7020 are still required for DOD contractors who handle controlled unclassified information, or CUI. To comply with these requires the implementation of NIST 800-171 which equates to CMMC Level 2 – Advanced.

Final Thoughts & Next Steps

The bottom line is that CMMC 2.0 significantly streamlines the requirements and eliminates many of the barriers to compliance, especially for smaller DoD contractors with less resources to dedicate to cybersecurity compliance.

We continue to strongly advise that companies do not sit on the sidelines and continue to explore their options for meeting their required Level of CMMC compliance. We heed this advice because of the following reasons:

• DFARS 7012, 7019 and 7020 are still required for DoD contractors Handling CUI.
• Early adopters of NIST 800-171 are likely to have a market advantage with their DoD customers and partners.
• DoD contractors should consider the risks to their organizations and balance sheets from ransomware and other types of breaches that NIST 800-171 can defend against.

We understand that many DoD contractors lack the resources in-house to complete their own self-assessments. That’s why many contractors choose to outsource the task to a provider like SysArc. We can take the burden of compliance off your team’s plate while at the same time protecting your IT infrastructure against cyber criminals.

If you have questions about implementing any of the cybersecurity controls in CMMC and about how SysArc can help, feel free to give us a call. We’ll be happy to speak with you and help you find a solution that works best for your business.