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.
The CMMC Final Rule becomes effective on December 16, 2024, at which point C3PAO assessments can begin. This rule empowers the DoD to incorporate CMMC into contracts once the 48 CFR Acquisition Rule is finalized, expected in early 2025. Contractors must be ready to demonstrate CMMC compliance starting from Q1 2025.
Phase 1 - (Q1 2025):
DoD will begin requiring CMMC Level 1 self-assessments for contracts involving FCI. In some cases, C3PAO assessments for CMMC Level 2 may also be required for contracts involving CUI.
Phase 2 - (Q1 2026):
Contractors must begin obtaining CMMC certifications for applicable DoD contracts, particularly Level 2 certifications for handling CUI. Specifically Level 2 (C3PAO) certifications will only be considered valid for these applicable contracts.
Phase 3 - (Q1 2027):
CMMC certifications will be mandatory for all new DoD contracts, with Level 2 or Level 3 compliance depending on the sensitivity of the information. This will be determined by the DoD/Contracting Officer at the time of solicitation or option period.
Phase 4 - (Q1 2028):
Full implementation of CMMC 2.0 across all applicable DoD contracts, including option periods, will be enforced.
By 2028, all contractors involved with DoD contracts at all levels will need to meet CMMC requirements to be eligible for awards.
If CMMC still hasn't been finalized and full implementation will take 2 years, why start now?
Finalization is Here
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. What does this mean for your organization? With this final rule, contractors must take immediate action to protect CUI and align with regulatory requirements! If your business needs guidance on navigating the complexities of CMMC 2.0, CorpInfoTech is here to help.
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 (know as ESP, External Service Provider, for CMMC Compliance) to ensure compliance is met and audits are passed. MSP/ESPs 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.