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Cybersecurity Maturity Model Certification is the latest data security standard established by the Office of the Under Secretary of Defense for Acquisition & Sustainment. The primary goal for creating CMMC is to guarantee that all DoD prime contractors and subcontractors are adequately prepared to safeguard the Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) they handle.
The CMMC model is based on various data security control standards like ISO 27032, IS 27001, NIST 800-171, and 800-53. While this model combines multiple other frameworks, one requirement sets it apart. And that is the third-party assessment for compliance. To achieve CMMC for DoD contractors, they must undergo third-party evaluation. CMMC Third Party Assessment Organization, or C3PAO, is the sole body entrusted by the DoD with certifying, licensing, and administering the CMMC ecosystem.
Why Should DoD Contractors Become CMMC Compliant?
In the recent past, cyber threat incidents against federal agencies have seen an uptick. Since most DoD contractors are small or mid-sized businesses, they lack cybersecurity infrastructure, making them more prone to cyberattacks.
Thus, to safeguard the federal data processes and handle outside federal systems, the CMMC requirement has been made compulsory for any business directly or indirectly working within the Defense Industry Base.
Now, contractors are required to produce CMMC compliance certification when asking for requests for information (RFIs) and requests for proposals (RFPs) for new contracts.
So, if you have taken adequate measures to be CMMC certified, you will have a competitive advantage over other contractors. You will have a better chance of winning the bid and government contract.
Besides this, if you are not CMMC compliant, you may lose your existing government contract, and the DoD may bar you from bidding on new contracts. But that is not all. CMMC-certified contractors enjoy other advantages like:
- Reduced risk of insider threats and data leaks.
- Low risk of cyberattack and data breaches.
- Establish as a trusted contractor.
CMMC model is a multi-layered framework having three levels in total. Each level has different practices and control measures. The assessment team will determine your organization’s cybersecurity maturity level based on your adopted cybersecurity protocols and standards. Then, the DoD will allocate the certification level you need to fulfill. To become compliant, you must satisfy all the requirements and undergo third-party assessment.
What is CMMC Audit and How to Prepare for it?
Once you have fulfilled all the certification requirements, the contractor must undergo and pass a CMMC compliance audit. According to the CMMC Accreditation Body, contractors seeking compliance certificates should prepare for it in advance.
The auditor will thoroughly inspect the contractor’s IT systems and data center to ensure all the cybersecurity controls needed for a specific level are in place. The auditor will only grant the contractor a maturity-level certificate of compliance if they fulfill all the requirements. Besides this, the Defense Counterintelligence and Security Agency (DCSA) and the Defense Contract Management Agency may conduct the assessments.
Steps to follow when preparing for CMMC Audit
- Start early: Since CMMC and DFARS have many control measures and requirements, one should start preparing for them as early as possible. Make sure your systems and cybersecurity framework are robust and working.
- Conduct self-Assessment: You can conduct a self-assessment to evaluate your organization’s cybersecurity maturity level if you have a dedicated IT staff. You can refer to the Self-Assessment Handbook – NIST Handbook 162 for a step-by-step guide on self-assessment.
- Identify the compliance gap: The Cybersecurity Maturity Model Certification is built on NIST 800-171. Thus, it’s essential that you first evaluate your current security posture as per the requirements stated in the NIST handbook. Since there are 110 control requirements for Level 2 compliance, you should clearly understand your cybersecurity stance to be better prepared for the audit. Identify any security gaps and resolve them as per the NIST guidelines. According to the CA.2.158 requirement, DoD contractors must conduct periodic assessments of the organization’s security control systems. Periodic evaluations will help you identify security gaps and better understand your security posture.
- Document Plan of Action & Milestones (POAM): Plans of Action3.12.2 of DFARS state that DoD contractors must develop, document, and implement Plan of Action & Milestones (POAM). In the action plan, the contractor must outline how security gaps and deficiencies identified in the initial step would be remediated. This may be an easy operation for contractors with a robust IT ecosystem and a team of professionals. However, other contractors may require help from C3PAO.
- Deploy the security controls: When preparing for a CMMC regulation evaluation, the primary goal should always be to remediate the security gaps and bolster security measures. Pick the controls that are the least impactful to the users and fix them first. Cover the controls with the most user impact for the last.
- Create a System Security Plan or SSP: System Security Plan is an essential document in CMMC audit. This is the first document that an auditor would ask you to produce in the event of an assessment. The CMMC requirement CA.2.157 3.12.4 makes it mandatory for all contractors to create, report, and regularly update system security plans for compliance. It’s worth mentioning that cyber security compliance is a continuous process that doesn’t stop at achieving CMMC compliance. The cybersecurity landscape is constantly evolving, and so are hackers and malicious actors. Thus, one must deploy the latest data defense measures to safeguard sensitive information. System Security Plan should have a record of current data security controls put in place.
- Maintain Compliance: Implementing CMMC requirements isn’t a set-and-forget methodology. When it comes to any compliance, for that matter, it requires regular assessment of internal and external resources to stay compliant. One has to conduct periodic risk assessments, run penetration testing, and manage internal and external vulnerabilities. Maintaining compliance is relatively easy for a big company with a robust IT infrastructure. However, small contractors and subcontractors are often small businesses with limited resources and workforce. They rely on consultants who can help them prepare for the audit and achieve compliance.