Why The DoD Created The CMMC
Department of Defense (DoD) contractors are now well aware of the cybersecurity mandates that have been sweeping across the defense industry over the past several years. In 2015, The U.S. Department of Defense published the Defense Acquisition Federal Regulation Supplement, known as DFARS, which mandates that private DoD Contractors adopt cybersecurity standards according to the NIST SP 800-171 cybersecurity framework. This is all part of a government-led effort to protect the U.S. defense supply chain from foreign and domestic cyber threats, and reduce the overall security risk of the sector.
Since the passing of DFARS, over 300,000 U.S. DoD contractors have been scrambling to understand DFARS and implement NIST SP 800-171 standards within their companies to become compliant with the regulation. Some have had the internal resources to become compliant themselves, while others have outsourced the task to Managed Service Providers, such as SysArc, who help DoD contractors comply with their cybersecurity mandates. Even though the DoD has incentivized compliance by making it a “competitive advantage” within the contract awards process, many contractors have chosen to put off compliance. There are even reported cases in which DoD contractors have stated false claims, stating to be in compliance on DoD contracts, but have later been found to be non-compliant. Because of the slow adoption rate of the DFARS 252.204-7012 regulation, the Department of Defense has released the Cybersecurity Maturity Model Certification (CMMC) to ensure appropriate levels of cybersecurity controls and processes are adequate and in place to protect controlled unclassified information (CUI) on DoD contractor systems.
The official version of CMMC (Version 1.0), was released in late January 2020, and since then two updates have been made. This guide was written for DoD contractors specifically and provides information about what we know about the CMMC, what contractors can expect as the DoD rolls out this program, and the options they have to prepare for a CMMC audit so they can become certified and continue to offer their products and services to the DoD without delay.
Note: This guide has been updated to Version 1.02 of the CMMC model and will be updated as more information is released by the Department of Defense. Because CMMC rollout is a rapidly changing topic, we also have a CMMC News page which features our executive summaries of the latest updates to the Cybersecurity Maturity Model Certification (CMMC) from the Accreditation Body, CMMC-AB.
The CMMC Model
The CMMC encompasses multiple maturity levels that range from “Basic Cybersecurity Hygiene” to “Advanced”. The intent is to identify the required CMMC level in RFP sections L and M and use it as a “go / no go decision.”
The CMMC model combines various cybersecurity control standards such as NIST SP 800-171 (Rev. 1 & Rev. B), NIST SP 800-53, ISO 27001, ISO 27032, AIA NAS9933 and others into one unified standard for cybersecurity. In addition to cybersecurity control standards, the CMMC also measurse the maturity of a company’s institutionalization of cybersecurity practices and processes.
What the CMMC Means for DoD Contractors
The DoD has built upon existing DFARS 252.204-7012 regulation and developed the CMMC as a “verification component” with respect to cybersecurity requirements. The DoD had entrusted DoD contractors to achieve compliance, and with continued pressure to ensure 100% adoption of cybersecurity controls, the DoD has updated its policies.
So what does this mean for DoD Contractors?
It means that all DoD Contractors will need to become CMMC Certified by passing a CMMC Audit to verify they have met the appropriate level of cybersecurity for their business. Eventually, this will be a requirement for any organization who wants to hold contracts with the Department of Defense or work as subcontractors on DoD related projects. For more information on the appropriate levels of cyber security, see “About CMMC Levels” below.
CMMC Certification and Audits
To verify that DoD Contractors have met the appropriate level of cybersecurity controls, the DoD will deploy certified third-party assessor organizations (C3PAO’s) to conduct audits on DoD Contractor information systems. It is from this audit that a DoD contractor will be awarded a certification Level of 1-5, if they comply with 100% of the controls for a given Level.
Important Dates and Milestones for DoD Contractors
- January 2020: The official CMMC Levels and requirements will be released along with training materials for the independent CMMC Accreditation Board (CMMC AB) to use for training auditors and C3PAO’s.
- February-May 2020: The initial round of assessors will be trained
- June-September 2020: Initial round of audits will begin for a select number of DoD Programs/RFI’s with the required CMMC Levels identified and contractors wishing to bid on those Programs will need to be certified to the required Level in order to receive the RFP.
- October 2020 and beyond: DoD contractors will need to get certified by an accredited Assessor/C3PAO in order to bid on new work
About CMMC Levels
The CMMC combines various cybersecurity standards and best practices and map these controls and processes across several maturity levels that range from basic cyber hygiene to advanced.
Here’s what we currently know about the CMMC levels and their respective requirements:
- Level 1 – “Basic Cyber Hygiene” – In order to pass an audit for this level, the DoD contractor will need to implement 17 controls of NIST 800-171 rev1.
- Level 2 – “Intermediate Cyber Hygiene” – In order to pass an audit for this level, the DoD contractor will need to implement another 48 controls of NIST 800-171 rev1 plus 7 new “Other” controls.
- Level 3 – “Good Cyber Hygiene” – In order to pass an audit for this level, the DoD contractor will need to implement the final 45 controls of NIST 800-171 rev1 plus 13 new “Other” controls.
- Level 4 – “Proactive” – In order to pass an audit for this level, the DoD contractor will need to implement 11 controls of NIST 800-171 RevB plus 15 new “Other” controls
- Level 5 – “Advanced / Progressive” – In order to pass an audit for this level, the DoD contractor will need to implement the final 4 controls in NIST 800-171 RevB. plus 11 new “Other” controls
Note: This information is based on Version 1.02 of the CMMC model. If necessary, we will update this document as official updates are released.
For more information, a full list of frequently asked questions can be found here.
How to Prepare for a CMMC Audit
As mentioned above, the various CMMC levels call for different controls outlined in NIST SP 800-171 Rev. 1 and NIST SP 800-171 Rev. B. DoD Contractors should determine which CMMC level they wish to obtain and then implement the controls necessary. For DoD contractors that have already implemented all NIST SP 800-171 controls, they should have no issues with passing a CMMC audit successfully up to CMMC Level 3.
For DoD contractors who have not implemented the NIST SP 800-171 Rev1 or RevB controls, the following options are available to prepare for a CMMC audit:
Do it Yourself: Meet Requirements In-House
DoD contractors or suppliers who have the resources and IT staff available can meet the appropriate CMMC level of cybersecurity in-house. Internal IT departments can use the “Self Assessment Handbook – NIST Handbook 162” provided by the National Institute of Standards and Technology (NIST). This handbook was created by NIST with the intention of assisting U.S. DoD contractors who provide products and services for the Department of Defense. Unfortunately, this handbook only covers NIST SP 800-171 Rev. 1 (Good for certification up to CMMC Level 3) and there is currently not a Self Assessment Handbook for NIST SP 800-171 Rev. B. However, a draft of the Rev. B can be found here.
If the contractor does not have the expertise to meet the requirements of NIST SP 800-171 Rev. 1 or Rev. B, DoD contractors have the option of outsourcing the requirements to a third-party CMMC consultant who offers CMMC compliance services. There are many qualified and experienced Managed Security Service Providers (MSSP) in the U.S. who specialize in compliance services and monitored cyber security for DoD contractors who need to implement NIST cybersecurity controls. A qualified MSSP will be able to perform this assessment and perform any remediation work necessary to pass a CMMC Audit.
Outsource: Work with a CMMC Consultant
For many DoD contractors, the most effective way to meet the CMMC cybersecurity requirements is to outsource the task to a Managed Security Service Provider (MSSP) that specializes in CMMC Consulting. Remember that DoD contractors remain ultimately responsible for ensuring that their company meets the appropriate cybersecurity requirements, so it is essential to choose an MSSP you are sure they can trust.
By outsourcing the NIST cybersecurity work to a qualified provider, DoD contractors should save a lot of time and money getting and staying compliant with CMMC. An outsourced provider will have all of the required document templates for the Gap Analysis, System Security Plan (SSP), and Plan-of-Action & Milestones (PO&AM), as well as the advanced tools required to monitor and respond to security incidents. They will also have the resources required to perform the remediation steps required to become compliant and the legal documentation to prove compliance has been reached and is being maintained when the time comes for a CMMC Audit.
The CMMC Readiness Assessment
The first step towards certification is for the DoD contractor to get a third-party Readiness Assessment completed to see how close, or how far away, the DoD contractor is from meeting the minimum requirements outlined in the appropriate CMMC Level. The Readiness Assessment is designed to discover inadequate system setups and processes that may not meet all of the required controls. Taking a close look at a company’s network and procedures is the first step to ensuring compliance.
The results of the CMMC Readiness Assessment may reveal issues such as:
- How access to information systems is controlled
- How managers and information system administrators are trained
- How data records are stored
- How security controls and measures are implemented
- How incident response plans developed and implemented
Without a gap analysis, it’s impossible to know what changes an organization needs to make before it meets the required CMMC Level. The professionals at an MSSP use their findings to create remediation plans that will correct any problems and keep our clients in line with CMMC requirements.
The gap analysis will either aid a DoD contractor in performing their own remediation plan, or they may opt to have a third-party, such as an MSSP, perform the remediation for them.
The Remediation Plan
A CMMC Readiness Consultant should develop a remediation plan based on the findings outlined in the Readiness Assessment. A remediation plan may involve small, relatively inexpensive fixes to a network and/or its processes, or it may involve more extensive, from the ground up, development of compliant networks and processes that meet today’s cybersecurity standards.
Remediation plans provide detailed documentation of processes that don’t meet today’s standards. Having a well-researched plan also makes it easier for DoD Contractors to make necessary changes to their systems.
Ongoing Cyber Security Monitoring and Reporting
Once the remediation plan is complete and a DoD Contractor’s systems and procedures are compliant with the appropriate CMMC Level, an MSSP will have the tools and processes in place to monitor, detect, and report on cybersecurity breaches within the DoD Contractor’s systems. If the DoD Contractor is not outsourcing compliance to an MSSP, they have the option to report cyber incidents themselves, given they have tools to monitor and detect such incidents.
The Importance of Passing the First CMMC Audit
For many companies, DoD contracts make up a substantial percentage of their revenue, and because CMMC certification will now be a requirement for contract awards, it’s extremely important that contractors get prepared to pass the CMMC audit as soon as possible. If you are not prepared to pass your desired CMMC Level you run the risk of being unable to offer products and services to the DoD for an extended period due to:
- The time it takes to implement all of the security controls required for the Program you desire to bid on if you have waited until the last minute
- The potential backlog of audits could affect the time it takes to get an audit done.
Therefore, it is highly recommended that a contractor consult with an experienced CMMC Readiness Consultant who can ensure that the contractor meets the requirements of their specified CMMC Level and can pass a CMMC Audit on the first try.
CMMC Audit Preparation & Assessment Services
SysArc has helped over 50 DoD contractors throughout the U.S. navigate the complexities and financial hurdles of the NIST SP 800-171 requirements. We have worked closely with our customers to ensure they are compliant with DFARS 7012 and now we are working with them to achieve the CMMC certification level they need to be competitive in the industry. For more information, please see our CMMC Preparation Solution. If you’d like to speak with someone about preparing for a CMMC audit now, feel free to give us a call at (240) 453-4146 or schedule a CMMC consultation now.