The Cybersecurity Maturity Model Certification (CMMC) is the Department of Defense's method for ensuring that contractors are effectively securing sensitive data and following regulatory requirements and if your organization works within the Defense Industrial Base (DIB) then your organization will have to comply. For many businesses, this process can be costly and time consuming. With the finalization of the CMMC final rule in late 2024, organizations that haven't already begun to implement these controls are behind. This blog seeks to offer a checklist that your organization can follow to help structure your path the CMMC compliance.
First, your organization needs to have a solid understanding of what the CMMC model is, and what level applies to your contract. CMMC is made up of three maturity levels (Foundational, Advanced, and Expert) that build upon one another, requiring additional protocols to be put in place to protect controlled unclassified information (CUI). Organization should understand that CMMC is not adding any new requirements but rather is enforcing the ones outlined in NIST SP 800-171. These requirements have been around of several years. CMMC is the mechanism in which the DoD will validate whether or not defense contractors have accurately reported their compliance status.
You must first determine what level of CMMC compliance is required for your organization. If your business has access to FCI, then you will only need to comply with Level 1 (Foundational). Contractors that are responsible for protecting CUI, will most likely have to achieve Level 2 (Advanced) compliance. The level your organization is required to reach will inform what controls need to be implemented.
In many cases, only certain aspects of an organization will come in contact with CUI and need to be in scope of CMMC requirements. Your organization must determine which assets, systems, and personnel are in scope and what can be separated from the non-CUI part of your business. This will help reduce the cost, time, and complexity it takes to achieve compliance. Using principles of least privilege, only give users access to the resources they need to do their job. Prevent privilege creep by restricting the creation, storing, and transmission of CUI across your organization.
You cannot begin the work of improving your cybersecurity and compliance posture without an understanding of where your gaps lie. Your organization should perform a security and risk assessment to determine where you fall short of NIST 800-171 requirements and what can be done to remediate those gaps. This assessment should include your policies and procedures, network security, access controls, and incident response plans.
Your organization should adopt a cybersecurity framework that aligns with the CMMC model and streamlines your compliance process. Examples include the NIST Cybersecurity Framework (CSF). The NIST CSF provides a set of guidelines and best practices for managing cyber risk. This framework aligns nicely with CMMC and can help structure your approach to CMMC compliance.
The CIS Controls are another industry standard framework that also aligns with CMMC requirements. Made up of 18 critical cybersecurity domains, the Controls are practical and can be implemented by any organization regardless of the size. CorpInfoTech has utilized the CIS Controls since their inception and became the first business to be accredited under CREST, for our implementation of the CIS Controls.
With an up-to-date gap assessment and a framework in place, your organization can begin to remediate any compliance gaps that may prevent you from passing an audit. Begin to address any deficiencies found in your security assessment through updates to policies, procedures, and technical controls. You will need to also make any necessary changes to your organizations System Security Plan (SSP). An SSP is a document outlining how your organization plans to protect CUI and what policies have been set up. For any compliance gaps that you are not able to address, you will need to create a Plan of Action and Milestones (POAM).
With compliance, documentation is important. Your organization will want clear records of all the work you've done to achieve CMMC compliance. Your most fundamental document will be the SSP. If you have partnered with an MSP or external organization, a Customer Responsibility Matrix (CRM) is necessary to determine who is responsible for what policies.
Once your organization is ready for its audit, you will need to engage a Certified Third-Party Assessment Organization (C3PAO) to perform an independent Level 2 certification assessment. The CyberAB Marketplace provides a list of C3PAO's and other CMMC professionals that can assist you with your audit.
Finally, it is time for your organization to undergo its independent third-party audit. Conducted by a C3PAO, upon passing your organization will receive a certification that is valid for 3 years. Your organization should understand that this is not a one-time process. Maintaining compliance is an ongoing process that much change and evolve as the threat landscape shifts. Throughout the entirety of your contract, your organization must be committed to protecting CUI. An MSP is often hired to help ensure that your compliance posture is monitored and updated when needed. An MSP can help your organization at any part of the compliance journey but are especially helpful in maintaining security and compliance for the duration of your contracts.
1. Waiting Too Long
One of the first mistakes your organization can make is waiting too long to being your CMMC compliance journey. For several years now, many contractors have been in the "wait and see" mindset while CMMC made its way through the legislation process. With the CMMC Final Rule's publication and C3PAO's beginning their audits, there is no longer time to wait. Full implementation can take roughly 18 months. Don't fall behind!
2. Too Broad of a Scope
When scoping out your compliance boundary, only include resources, assets, and personnel that need access to CUI. The larger your CMMC compliance scope, the greater risk there is to CUI. A larger scope means increased costs as well.
3. Zero Continuous Monitoring
As previously mentioned, compliance is not a one and done process. Organizations must continuously monitor their compliance posture to avoid falling behind. Your organization must always be improving and building upon your processes rather than neglecting them until a problem arises. An MSP like CorpInfoTech can provide monitoring services that let you focus on running your business.
4. Lack of Detail
Documentation is a crucial part of achieving CMMC compliance. Your organization should keep detailed records of the processes, technologies, and individuals responsible for securing CUI. Your SSP, CRM, and POAM are key documents that will testify to your businesses ability to achieve and maintain compliance.
CorpInfoTech is a managed service provider that offers IT, cybersecurity, and CMMC compliance solutions to small-medium sized businesses. Through TAS for CMMC Compliance, your organization will be able to achieve and maintain CMMC compliance with confidence.
Partnering with CorpInfoTech (TAS for CMMC Compliance) provides your organization with:
Contact CorpInfoTech today to learn more about TAS for CMMC Compliance!