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For businesses seeking to secure contracts with the Department of Defense (DoD), understanding and achieving compliance with the Cybersecurity Maturity Model Certification (CMMC) is crucial. CMMC provides a framework for implementing and enhancing cybersecurity practices, offering a standardized approach to safeguarding sensitive data. In this blog post, we will demystify CMMC, explore its key components, and guide you towards achieving compliance. Thus enhancing your ability to compete for DoD contracts.
Contents
What Is CMMC Compliance?
Cybersecurity Maturity Model Certification (CMMC) compliance refers to the adherence to a set of cybersecurity standards that companies must meet if they want to bid on Department of Defense (DoD) contracts. The CMMC framework was designed to safeguard sensitive data. That includes Federal Contract Information (FCI) and Controlled Unclassified Information (CUI), against cybersecurity threats.
CMMC is built upon existing regulations such as the Defense Federal Acquisition Regulation Supplement (DFARS). And the National Institute of Standards and Technology’s (NIST) guidelines. But adds a certification element to verify compliance. This model comprises five levels of cybersecurity maturity, each with its own set of required practices and processes.
What Are The Five Levels of CMMC?
The Cybersecurity Maturity Model Certification (CMMC) encompasses five levels of cybersecurity maturity. Each level corresponds to an increasing degree of sophistication and effectiveness in a company’s cybersecurity practices and processes. The levels include:
Level 1 – Basic Cyber Hygiene
At this level, a company must implement 17 controls from the NIST SP 800-171 Rev1 to safeguard Federal Contract Information (FCI). The practices at this stage are basic and serve to protect against common cyber threats.
Level 2 – Intermediate Cyber Hygiene
This level serves as a transition from safeguarding FCI to protecting Controlled Unclassified Information (CUI). It introduces an additional 48 practices and involves the implementation of select controls from NIST SP 800-171 Rev1.
Level 3 – Good Cyber Hygiene
This level requires a company to establish, maintain, and resource a plan that demonstrates the management of activities for practice implementation. At this stage, all 110 controls from NIST SP 800-171 Rev1 must be implemented. Plus 20 additional practices, to adequately protect CUI.
Level 4 – Proactive
The practices at this level are proactive and aim to protect CUI from advanced persistent threats (APTs). Companies at this level must demonstrate a substantial and proactive cybersecurity program and implement an additional 26 practices.
Level 5 – Advanced/Progressive
At this highest level, a company is required to standardize and optimize its cybersecurity practices across the organization. It includes an additional 15 practices for a total of 171. At this stage, a company’s cybersecurity program is highly advanced and can protect CUI from sophisticated threats.
Each CMMC level also has an increasing number of processes that must be in place. These processes range from performing tasks to managing them, reviewing them, and continuously optimizing them.
Why Is CMMC Compliance Important?
CMMC compliance is important for several reasons:
- Securing Defense Information: At its core, CMMC is designed to protect sensitive Department of Defense (DoD) information stored on contractors’ systems. By implementing the cybersecurity practices defined in the CMMC, contractors can better safeguard this data against cyber threats.
- Maintaining National Security: The information protected by CMMC, such as Controlled Unclassified Information (CUI), plays a crucial role in national security. Ensuring that such information doesn’t fall into the wrong hands helps maintain the security and interests of the nation.
- Business Requirement: For companies that wish to do business with the DoD, CMMC compliance isn’t just important—it’s mandatory. Only companies that meet the relevant level of CMMC can bid on DoD contracts. Therefore, achieving and maintaining CMMC compliance is a business necessity for DoD contractors.
- Demonstrating Cybersecurity Commitment: Achieving CMMC compliance shows that a company takes cybersecurity seriously and has implemented the necessary controls and practices. This can boost reputation and trust with not just the DoD, but other partners and customers as well.
- Guarding Against Cyber Threats: The practices and processes required for CMMC compliance can also help companies better defend against general cyber threats, not just those related to DoD information. This can enhance a company’s overall cybersecurity posture and resilience.
Difference Between NIST 800 171 And CMMC Compliance
The National Institute of Standards and Technology Special Publication 800-171 (NIST SP 800-171) and the Cybersecurity Maturity Model Certification (CMMC) are both designed to enhance cybersecurity. But there are significant differences between them.
- Scope: NIST SP 800-171 is a set of standards that apply to Non-Federal Information Systems and Organizations, and it primarily deals with the protection of Controlled Unclassified Information (CUI) in non-federal systems and organizations. On the other hand, CMMC is a unified standard specifically for the Department of Defense (DoD) contractors and subcontractors to safeguard FCI (Federal Contract Information) and CUI, with a broader objective of securing the Defense Industrial Base (DIB) sector.
- Compliance Verification: Under NIST SP 800-171, organizations were largely on an honor system, with self-attestations of compliance. The DoD found that this approach was not fully effective, as it often led to a gap between the self-reported security posture of contractors and the reality of their cybersecurity measures. Conversely, CMMC requires third-party audits by certified assessors to ensure organizations meet the necessary cybersecurity practices and processes.
- Maturity Levels: NIST SP 800-171 does not include levels of maturity; it is a single set of standards that companies must implement. On the other hand, CMMC consists of five levels of cybersecurity maturity. That allows the DoD to tailor the security requirements to the sensitivity of the information that a contractor will handle or process.
- Practices and Processes: While NIST SP 800-171 comprises 110 security controls, CMMC includes those controls and additional practices and processes. Totaling up to 171 depending on the level of certification.
Both NIST SP 800-171 and CMMC are critical to securing the Defense supply chain, but CMMC represents a more comprehensive and verifiable approach to cybersecurity.
How To Achieve CMMC Compliance?
Achieving CMMC compliance requires a systematic approach and a commitment to improving your organization’s cybersecurity posture. Here’s a step-by-step guide to help you achieve compliance:
- Understand the CMMC Requirements: The first step is to familiarize yourself with the CMMC framework and its requirements. You’ll need to understand the five levels of CMMC and what each level entails in terms of practices and processes.
- Identify Your Desired CMMC Level: Depending on the nature of the work you perform for the Department of Defense (DoD), you’ll need to achieve a certain CMMC level. Identify which level is relevant for your organization.
- Perform a Gap Analysis: Compare your current cybersecurity practices with the requirements of your desired CMMC level. Identify where there are gaps that need to be addressed. This step often involves a thorough review of your cybersecurity policies, procedures, and systems.
- Develop and Implement a Remediation Plan: Once you’ve identified the gaps in your cybersecurity practices, create a plan to address them. This may involve updating policies, implementing new security measures, and providing training for your staff. Then, put this plan into action.
- Choose a Certified Third-Party Assessment Organization (C3PAO): To achieve CMMC compliance, you must pass an audit conducted by a C3PAO. These organizations are certified by the CMMC Accreditation Body (AB) to conduct audits.
- Address Audit Findings: If the C3PAO identifies areas where your organization is not compliant, you’ll need to address these issues and potentially undergo a follow-up audit.
- Maintain Compliance: Once you’ve achieved CMMC compliance, you must maintain your cybersecurity practices and processes to remain compliant. Regular reviews and updates to your cybersecurity program can help you stay in line with the CMMC requirements.
Remember, CMMC compliance isn’t a one-time effort. It requires ongoing attention to ensure your organization continues to meet the necessary standards.
What Is The Cost Of CMMC Compliance?
The cost of achieving CMMC compliance varies significantly depending on a number of factors, such as:
- current state of your organization’s cybersecurity practices
- CMMC level you are trying to achieve
- size and complexity of your IT environment
Compliance costs could involve expenses for implementing necessary cybersecurity controls, upgrading systems, hiring or training staff, engaging consultants, and undergoing the mandatory third-party audit. Preliminary cost estimates by the DoD suggested that achieving:
- Level 1 compliance might cost a small company around $1,000
- Level 3 compliance might range from $30,000 to $50,000 for the first year
However, it’s important to note that these are rough estimates and actual costs can be considerably higher or lower. Ultimately, investing in cybersecurity and achieving CMMC compliance is a crucial step in safeguarding your organization’s data.
Conclusion
In conclusion, achieving CMMC compliance is a strategic necessity for any organization seeking to secure and maintain contracts with the Department of Defense. It demonstrates an organization’s commitment to cybersecurity and protects the integrity of sensitive information critical to national security. Though the path to compliance requires understanding complex regulations and potentially significant investment, the benefits far outweigh the costs.
By understanding the requirements, carefully planning your approach, and maintaining ongoing diligence, your organization can successfully achieve and sustain CMMC compliance. If you are looking to implement any of the Infosec compliance frameworks such as SOC 2 compliance, HIPAA, ISO 27001, and GDPR compliance, Impanix can help. Book a Free consultation call with our experts or email us at [email protected] for inquiries.
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