If you are a DoD contractor, you've no doubt heard a lot about CMMC and the requirements your business will have to abide by in order to do business with the federal government. These regulations are non-negotiable in order to keep your current contracts or bid on new ones. However, the arduous rule making process has caused many businesses to delay their implementation of the required controls. CorpInfoTech is here to tell you that now is the time!
The CMMC rule has been in the works for several years now and has been changed throughout its review process. The original CMMC model began with 5 levels of maturity. Since then, the second version of CMMC has reduced that number to 3. Major steps toward finalization were made in December of 2023 when Title 32 (the CMMC rule) was entered into the federal register as a "proposed rule". The final CMMC 2.0 rule is here The Cybersecurity Maturity Model Certification has been officially published into the federal register as a final rule on October 15th.
Once CMMC passes, the DoD plans on implementing it into contracts through 4 phases:
Phase 1: Begins on the effective date of DoD's final CMMC rule. The DoD will begin requirements CMMC Level 1 and 2 self-assessments along with some level 2 third-party assessments.
Phase 2: 6 months after phase 1 begins, phase 2 will start requiring third-party assessments for contractors seeking CMMC level 2 contracts.
Phase 3: This phase begins 1 year after phase 2 starts. During this time period, the DoD will extend level 2 assessment requirements to contracts awarded prior to CMMC finalization.
Phase 4: A year after phase 3 begins, CMMC implementation will be complete.
If CMMC still hasn't been finalized and full implementation will take 2 years, why start now?
Finalization is Near
As mentioned above, finalization for CMMC is quickly approaching. The CMMC rule is currently at its last stop in the rule making process meaning that within the next couple of months we will see the CMMC final rule published. The "wait and see" approach is not a viable option when it comes to CMMC compliance.
These Requirements Aren't New
The controls that are required by CMMC are not new to DoD contractors. In fact, they've been required since 2017. While CMMC does not include or create new controls or protocols for organizations to follow, it is founded in NIST SP 800-171 which DoD contractors have been required to implement since 2017. In the past, contractors were able to self-attest that they were correctly following the guidelines of NIST 800-171, CMMC is now the mechanism in which contractors prove their compliance through external validation.
Implementation of CMMC is Time Consuming
Unfortunately, becoming CMMC compliant is not possible overnight. Depending on the progress your organization has already made, CMMC implementation can take anywhere from 12-18 months. You'll need a considerable amount of lead time between when you start implementing the required controls and your audit date.
Larger Organizations are Already Requiring CMMC Compliance
Regardless of when CMMC is finalized, larger enterprises and contractors are already requiring their partners and suppliers to become CMMC compliant. Due to the fact that compliance requirements flow down from prime contractors to sub-contractors, many larger companies are getting ahead of the game and making sure their entire supply chain is compliant. Your organization will not want to miss out on opportunities now or in the future.
When faced with the daunting task of implementing the 300+ controls required by CMMC, many businesses will enlist the help of a Managed Service Provider (MSP) to ensure compliance is met and audits are passed. MSPs provide a number of benefits to SMBs including reduced costs, access to enterprise level resources, and expertise. Why CorpInfoTech?
CorpInfoTech is an MSP that offers IT and security solutions to SMBs looking to bolster their security posture. As a certified RPO with the Cyber AB, CorpInfoTech is in a unique position to serve contractors by offering CMMC compliant managed services that automatically apply 200+ of the 320 controls required by CMMC. Our main goal is to ensure contractors achieve and maintain CMMC compliance while also securing their organization from end to end. Our CMMC compliant services include Firewall Management (xDEFENSE), Vulnerability Management (v360), security assessments, and managed IT services.