CMMC Compliance Requirements: What You Need to Know

On average, every 39 seconds a cybercriminal attempts to hack into someone’s personal information. On top of this, human error on the receiving side of the attack is the number 1 cause of all data breaches. No pressure or anything.

This is why organizations must hold cybersecurity and other defense programs as a top priority. It is for the Department of Defense (DoD). The Defense Industrial Base (DIB) regularly faces countless complex cyberattacks. The DoD created the Cybersecurity Maturity Model Certification (CMMC) program to fix gaps in cybersecurity among defense contractors and protect sensitive information.

This program sets clear cybersecurity rules to keep Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) safe. With cyberattacks on the rise, protecting your information is paramount. Especially as a business within the DIB.

So what exactly is the CMMC? And what are the requirements to achieve compliance? Today we are going to talk about what it looks like to be CMMC compliant as a business. Let’s go over what CMMC is, how to meet the set requirements, and why it is so important.

What is the Cybersecurity Maturity Model Certification (CMMC)?

The Cybersecurity Maturity Model Certification (CMMC) is a defense program developed by the U.S. Department of Defense (DoD). This framework standardizes and ensures that both contractors and subcontractors handling Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) have safeguards in place to protect against cyberattacks. Let’s take a moment to understand what this information includes:

• Federal Contract Information (FCI): Section 4.1901 of the Federal Acquisition Regulation (FAR) defines FCI as information provided by or generated for the Government that is not intended for public release. It is under a contract to develop or deliver a product or service to the Government. This excludes information provided to the public by the Government. Such as information on public websites. It also excludes simple transactional information, like process payments.
• Controlled Unclassified Information (CUI): Title 32 CFR 2002.4(h) defines CUI as information the Government creates or possesses that a law or regulation permits an agency to handle using safeguards. This also includes Government information that an entity creates or possesses.

The CMMC creates a clear set of rules that require defense contractors to protect sensitive unclassified information. It follows existing security standards to help businesses stay compliant. By enforcing security controls for contractors and subcontractors, the DoD gains assurance that all businesses within the DIB meet cybersecurity requirements.

CMMC Key Aspects

There are a few key features of the CMMC Program:

1. Tiered Model. The CMMC outlines the process and requirements for staying compliant at different levels. Depending on the type and sensitivity of the information, these levels advance in terms of what is necessary to achieve compliance. It also outlines the process and protection of information sent down to subcontractors.
2. Assessment Requirement. These assessments allow the DoD to verify the DIB implementation of cybersecurity standards that already exist.
3. Implementation through Contracts. As a condition of contract award, DoD contractors and subcontractors must achieve a specific level when handling sensitive unclassified information.

CMMC 2.0 Compliance Level Requirements

The tiered approach to DoD cybersecurity compliance ensures that companies align with requirements based on the sensitivity of the data they work with. The latest version of CMMC, CMMC 2.0, consists of 3 levels. Level 1 offers your basic safeguarding standards. Level 2 includes the broad protection of CUI. Level 3 covers the highest level of protection against Advanced Persistent Threats (APTs).

Let’s look at each level’s basic requirements together:

1. Level 1: basic safeguarding of FCI. Organizations must complete an annual self-assessment and affirm compliance with the 15 security requirements in FAR 52.204-21.
2. Level 2: broad protection of CUI. This level aligns with NIST SP 800-171 Revision 2. Requires either an annual self-assessment or a C3PAO assessment every three years. This often depends on the type of information the contractor or subcontractor processes. As well as the type of information they transmit, or store in their system. Required annual affirmation and compliance with 110 security requirements. Found in NIST SP 800-171 Revision 2.
3. Level 3: higher-level protection of CUI against APTs. Aligns with NIST SP 800-172. This level is for organizations that handle highly sensitive data. They must achieve CMMC status of final Level 2. And undergo an assessment every 3 years by the Defense Contract Management Agency’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). Also, required to provide an annual affirmation verifying compliance with the 24 identified requirements. Found in NIST SP 800-172.

Some General Security Practices to Consider

Achieving CMMC certification all depends on the type of sensitive information you work with. However, all contractors and subcontractors need to take certain general steps to ensure a compliant workplace. They all must implement the required security practices. And follow controls designated by their particular CMMC level. Let’s look at a few examples of necessary security practices regardless of the level you fall under.

Perform regular risk assessments. As cybercrime continues to evolve, so do your monitoring and risk assessment practices. Identify and mitigate risks through the continuous monitoring of your business. Being able to identify vulnerabilities can help you from landing in hot water down the road.

Develop a System Security Plan (SSP). An SSP is a document which details an organization’s security:

• Policies.
• Procedures.
• Technical Implementations.

It is a roadmap for your business to refer to. Especially when it comes to maintaining compliance. Outlining how security controls become implemented and maintained over time.

Finally, always seek to maintain ongoing compliance. This is not a one-time achievement. But instead an ongoing process and commitment to security. Update your policies as needed and make sure you stay informed on any CMMC changes or updates. Try to incorporate regular training and audits to facilitate long-term regulatory compliance.

Why is CMMC Compliance Important?

CMMC compliance is important for many reasons. First and foremost, it protects our country’s sensitive information on defense-related topics. Having that fall into the wrong hands could be catastrophic. Next, CMMC compliance is mandatory if you plan on working as a contractor with the DoD. You must achieve the required CMMC level before working with certain defense sectors. As I mentioned above.

It also helps to reduce the risk of cybersecurity attacks. By meeting these regulations, you’re strengthening your defenses against hackers. Finally, it can enhance your business opportunities. By being CMMC compliant, you can enter contracts and partnerships that you wouldn’t be able to without it. More opportunities for professional growth means more opportunities to grow your bottom line.

Here are some tips on how to prepare for CMMC Compliance in your company:

1. Assess your current security process. Take this opportunity to conduct a gap analysis. This will help you to identify any areas needing improvement.
2. Align yourself with NIST SP 800-171.
3. Ensure your security controls meet the required CMMC level.
4. Train your team on cybersecurity etiquette.
5. Work with a CMMC Consultant.
6. Review and update security measures regularly to ensure compliance.

Conclusion

As cyberattacks become more frequent and refined, our digital landscape becomes more dangerous. This Wild West is in need of constant monitoring. That is why achieving CMMC compliance is much more than a regulatory requirement. It’s the key to protecting all sensitive defense-related data. After all, the cost of falling victim to a cyberattack can be extremely damaging. From financial loss to even a national security risk.

By aligning the CMMC requirements with your organization, you are demonstrating commitment. A commitment to safeguarding highly sensitive information. Whether you are working with CUI, FCI, or both, you want to be sure you are implementing best practices. This includes performing regular risk assessments, monitoring your security processes, and so on.  By taking proactive steps, you can create a robust cybersecurity defense now. Doing so will not only meet regulatory requirements but also solidify your long-term success and resilience.