Most - but not all - government contractors are aware of the upcoming Cybersecurity Maturity Model Certification (CMMC). We're providing this comprehensive guide to show you how to prepare, achieve and maintain CMMC - along with timely updates as new information arrives!
Table of Contents - Guide to CMMC
1. What is CMMC Compliance?
CMMC stands for Cybersecurity Maturity Model Certification, and is the latest security framework mandated by the Department of Defense (DoD) for any contractor that sells into the DoD.
It specifies a range of security maturity levels that must be met, and will be used by the DoD as a qualification criterion for RFPs and vendor selection.
IT security for government contractors has always been a hot topic, but this recent change from the DoD has made compliance to security regulations even more important.
Once rolled out, CMMC will mandate strict compliance by DoD providers, and contractors who do not meet CMMC standards may find themselves shut out of DoD business.
The initial version of the CMMC framework was rolled out in January 2020 and was updated in March, according to the DoD CMMC website.
A MOU between the DoD and the CMMC Accreditation body was signed, and progress continues to establish the certification, licensing and training requirements for assessors and organizations.
DoD originally planned on releasing for a June 2020, inclusion of CMMC requirements included as part of Requests for Information.
Between the impact of the Covid-19 Pandemic and other factors, that hasn’t happened and the final training and certification requirements are still pending.
A limited group of provisional assessors are going through training.
Update: On Sep 28, 2020 DoD released interim cyber related DFARS rule changes that will go into effect on Nov 30, 2020.
You can read more about it in our latest post on NIST SP 800-171 here, but to summarize:
- -7012 is unchanged; you continue to require an Incident Response Plan and a SSP and POAM based on the NIST 800-171 controls.
- -7019 is added; you will be required to self score your SSP IAW the DoD Assessment Methodology
- -7020 is added; this allows trained DoD auditors to score your SSP IAW the DoD Assessment Methodology
- -7021 is added; this allows the inclusion of CMMC requirements in future RFPs and RFIs
The regulatory process to update the DFARS -7012 requirements is also pending so the plan for CMMC requirements in RFPs may be delayed until late 2020 or early 2021.
While some of the more than 300,000 DoD contractors will have the staff, resources, and expertise to meet their CMMC requirements in-house, many will not.
Fortunately for those in the latter camp, managed security service providers (MSSPs) such as Ntiva are developing specialized programs to help assess contractors’ current capabilities, create remediation plans where necessary, and conduct ongoing cybersecurity monitoring and reporting.
2. Why is the DoD Implementing CMMC?
According to the DoD, “CMMC is intended to serve as a verification mechanism to ensure appropriate levels of cybersecurity practices and processes are in place to ensure basic cyber hygiene as well as protect controlled unclassified information (CUI) that resides on the Department’s industry partners’ networks.”
The cybersecurity challenges faced by the DoD are enormous — for example, the Pentagon stops an estimated 36 million emails containing ransomware and phishing attacks every day.
Despite these best efforts, in late 2018 the Pentagon reported a data breach exposing the personal information of 30,000 DoD employees on a system operated by a third-party contractor.
2020 opened with the Department of Homeland Security warning of a possible increase in cyberattacks against government networks due to rising tensions in the Middle East.
It’s a never-ending battle, and predicted only to get worse!
But let’s go back to 2015, when the DoD identified specific cyber requirements in the Defense Federal Acquisition Regulation Supplement (DFARS) (252.204-7008 and 252.204.7012).
DFARS required DoD contractors to adopt cybersecurity processes and standards created by the National Institute of Standards and Technology (NIST). All government contractors needed to represent that they had implemented the requirements of the NIST SP 800-171 as of December 2017.
This framework, NIST SP 800-171, was part of the broader government initiative to protect the DoD supply chain from cyber threats and other security risks.
The adoption of the framework has been slow, despite DoD efforts to incent supplier compliance. The DoD has expressed concern that the vast majority of defense industry contractors maintain only adequate security hygiene practices.
Source: Office of the Under Secretary of Defense
Faced with unacceptable risks to Controlled Unclassified Information (CUI) stored on contractor systems, the DoD has now introduced CMMC to ensure that appropriate levels of cybersecurity protections and processes are in place.
What sets CMMC apart from ‘business as usual’ under the current regime is a strict audit process that will establish compliance as a condition of doing business with the Defense Department.
CMMC will replace the current ‘self-declaring’ model with third-party certification, and the resulting audit and certification process will establish compliance as a condition of doing business with the Defense Department.
3. An Overview of the CMMC Model
The most recent CMMC model framework is Version 1.02 published in March 2020.
The framework defines cybersecurity practices at the highest level by domains, and each domain is then segmented by capabilities. Capabilities identify contractor achievements that ensure cybersecurity objectives are met within each domain.
DoD contractors will demonstrate compliance with required capabilities by showing adherence to practices and processes that have been mapped across the five maturity levels of CMMC.
Practices will measure the technical activities necessary to achieve compliance with a given capability requirement, while processes will measure the maturity of a company’s processes.
Source: CMMC Version 1.02
4. What Are The CMMC Levels?
The CMMC model has five defined levels, each with a corresponding set of practices and processes. Practices range from basic cyber hygiene (Level 1) to advanced/progressive capabilities (Level 5).
In parallel, processes step up from Level 1 (being performed) to Level 5 (being optimized across the organization).
Contractors must meet both associated practices and processes to achieve each specific CMMC level.
Source: CMMC Draft Version .7
The following table provides a more detailed summary of each CMMC level:
Source: CMMC Draft Version .7
5. Understanding CMMC Domains
The CMMC model consists of 17 domains. Many of these CMMC domains originated from the Federal Information Processing Standards (FIPS) 200 security-related areas and the NIST SP 800-171 control families.
Below is a summary of the domains, but if you would like more information on each domain take a look at our CMMC Compliance Checklist - 17 Domains for more details.
The current CMMC model also includes Asset Management, Recovery, and Situational Awareness domains.
Source: CMMC Draft Version .7
6. Understanding CMMC Process Maturity
The DoD defines process maturity as “the extent of institutionalization of practices within an organization.”
The following table outlines the maturity processes expected to be performed by DoD contractors at each of the five CMMC Levels:
7. How Do I Get CMMC Certified?
DoD contractors who have the necessary IT staff and resources may opt to prepare for their chosen CMMC cybersecurity certifications in-house.
NIST created this guide, the Self Assessment Handbook – NIST Handbook 162, as an aid for suppliers self-directing their certification initiative. The handbook details certification requirements for NIST SP 800-171 Rev. 2, which aligns with CMMC Level 3.
Unfortunately, at this time, there is no self-assessment guide available for NIST SP 800-172. A draft of the 172 specification, however, can be found here.
Before proceeding with an in-house CMMC program, contractors should consider the stakes, especially in light of the need to pass their third-party CMMC audit on the first try.
If the initial examination is unsuccessful, contractors stand to lose significant time while they correct any security shortcomings. They may also encounter hold-ups due to a potential backlog of audits, especially in the early days of CMMC.
As CMMC certification becomes a requirement for contract awards, such delays could prove costly for companies who count on DoD business for a considerable portion of their revenue.
8. The Benefits of Outsourcing CMMC
Many contractors may not have the skills or resources to address the requirements of NIST SP 800-171 Rev. 2 or SP 800-172.
For those organizations, an effective means to meet the CMMC cybersecurity requirements is to outsource their compliance initiative to a qualified Managed Security Services Provider (MSSP) such as Ntiva.
Experienced MSSPs have the necessary processes and templates to undertake a gap analysis and create the overall security plan. They also have the available resources and expertise to complete remedial activities if required. They should also have the tools necessary to monitor security performance, resolve issues, and provide detailed reporting.
As a result, contractors may find that outsourcing (rather than building) these capabilities saves significant money and time.
You should also make sure your provider is a Cybersecurity Maturity Model Certification Registered Provider Organization (CMMC RPO.)
Organizations that are given the CMMC RPO seal are ones that are “cyber-knowledgable” and have a good understanding of CMMC requirements and protocols.
In the next four sections we describe four critical activities that a qualified MSSP or CMMC RPO can perform to help prepare DoD contractors for the CMMC rollout:
- Readiness Assessment and Gap Analysis
- Remediation Plan
- Monitoring and Reporting
- System Security Plan (SSP)
9. What Is The Purpose of a CMMC Gap Analysis and Readiness Assessment?
The gap analysis and readiness assessment are foundational steps for contractors to gain a detailed understanding of how close they are to meeting the requirements of their targeted CMMC level.
The Readiness Assessment will help uncover systems and processes that may not meet the standards outlined in NIST 800-171, such as:
- How is data stored and access to information controlled?
- Are incident response plans in place, current, and effective?
- Are IT staff and other personnel adequately trained?
- How are security protocols implemented and maintained?
The resulting Gap Analysis will pinpoint risk areas for contractors and facilitate the creation and execution of the Remediation Plan, either by the MSSP or utilizing in-house resources.
Without an exhaustive Gap Analysis in hand, DoD contractors may find it impossible to identify risks, prioritize activities, and determine costs for any remedial steps required for CMMC certification.
10. Creating the Remediation Plan
The Remediation Plan is a prioritized, actionable plan of record to address any security gaps uncovered in the Readiness Assessment and bring the contractor into CMMC compliance.
This Plan of Action & Milestones (POA&M) will document:
- Activities necessary to address and resolve security issues
- Allocation of resources required to mitigate problems and close security gaps
- A timeline for the organization, with projected completion dates and milestones
- Insights into how security vulnerabilities were uncovered
- Quantification of risk levels, established priorities, and estimated remediation costs
11. On-Going Cybersecurity Monitoring and Reporting
Once the DoD Contractor has completed the remediation and is CMMC compliant, they will need to monitor, detect, and report on cybersecurity incidents within their own systems.
These activities require specialized tools and expertise and can place an administrative burden on many contractors, another key reason why many contractors will opt to outsource this task to an MSSP who specializes in cyber security.
12. Building and Updating the System Security Plan
The System Security Plan (SSP) is a living document that must be updated when a company makes substantial changes to its security profile or processes.
Typical information captured in the plan includes company policies, employee security responsibilities, network diagrams, and administration tasks.
For NIST 800-171 and CUI requirements, the SSP must document information about each system in a contractor’s environment that stores or transmits CUI. The SSP also details the flow of information between systems, as well as authentication and authorization processes.
The DoD mandates a review of contractors’ SSPs as part of the awards contest. Without a current, valid SSP in place, contractors may not be awarded DoD business.
While creating and updating the SSP is critical to maintaining certification requirements, it can be a resource-intensive process so contractors need to ensure they have the resources in place to do this.
13. What is a CMMC Audit?
While the DoD has not finalized all details of the audit process, here is what has been confirmed to date:
- All DoD Contractors will need to become CMMC Certified by passing a CMMC audit. The Accreditation body recommends that you start at least 6 months in advance.
- This will validate they have met the appropriate level of cybersecurity for their business with DoD
- Certification will become a requirement for any organization that wishes to hold Department of Defense contracts or act as subcontractors on DoD-related projects
- The DoD will employ certified third-party assessor organizations (C3PAO’s) to conduct audits on DoD Contractor information systems and verify that DoD Contractors have met the appropriate level of cybersecurity controls
- Based on the audit results, contractors will be awarded the applicable certification (from Level 1-5) if they meet the requirements of 100% of the controls for that level
- While 3rd party organizations will normally perform assessments, some of the higher-level evaluations may be performed by DoD assessors within the Services, the Defense Contract Management Agency (DCMA), or the Defense Counterintelligence and Security Agency (DCSA)
DoD Statement on the Assessment Process
“Your organization will coordinate directly with an accredited and independent third party commercial certification organization to request and schedule your CMMC assessment. Your company will specify the level of the certification requested based on your company’s specific business requirements. Your company will be awarded certification at the appropriate CMMC level upon demonstrating the appropriate maturity in capabilities and organizational maturity to the satisfaction of the assessor and certifier.”
Office of the Under Secretary of Defense for Acquisition & Sustainment — Cybersecurity Maturity Model Certification
14. Important Dates and Milestones for DoD Contractors
Official CMMC Levels and requirements released.
Training for the first round of assessors is being developed. Certification exams, job descriptions, levels of assessors are all in development. Check out the CMMC Accreditation body for updates.
On September 28, 2020 DoD released interim cyber related DFARS rule changes that will go into effect on Nov 30, 2020. You can read more about it in our latest post on NIST SP 800-171.
Initial round of audits will launch for a limited number of DoD Programs with the required CMMC Levels specified. Contractors will need to be certified to the appropriate CMMC level in order to receive the RFP for those programs. It's believed that only the companies submitting on these RFI/RFPs will be eligible for CMMC assessment in the initial stages.
DoD contractors will need to be certified by an accredited Assessor to qualify to bid on new projects. Since CMMC will not be applied retroactively on existing contracts, the current DFARS 7012 requirements will be in place through 2026.
15. CMMC Compliance Checklist: Next Steps for Contractors
Whether or not DoD contractors choose to prepare for CMMC in-house or outsource to an MSSP, there are key activities they should undertake to stay ahead of the transition.
You will also want to check out our CMMC Compliance Checklist located here that breaks down the CMMC framework by domain, showing you the exact requirement per domain.
- Assess the current organization for NIST 800-171 compliance. NIST 800-171 requires that contractors “periodically assess the security controls in organizational systems to determine if the controls are effective in their application.”
- Create or update the System Security Plan (SSP). NIST 800-171 also mandates contractors to document and update SSPs, including information such as company policies, network diagrams, and relationships with other systems.
- Build the Plan of Action & Milestones. The POA&M will document the remediation project plan and help establish timelines and resource requirements.
- Implement the Remediation Plan. Completing the POA&M will ensure compliance with NIST 800-171 and existing contracts while preparing for the full CMMC rollout.
- Maintain Compliance. Maintaining compliance with DoD security standards can be a complex undertaking and is often overlooked. It requires a documented plan and frequent (sometimes daily) activities.
16. How Ntiva Can Help With CMMC
Submission of a proposal to the DoD – as a prime or sub – requires that you have an SSP and POA&M that documents your cyber practices against NIST SP 800-171 and shows a clear plan for addressing any gaps.
Haven’t done it yet? In addition to being in violation of your DoD Ts&Cs, you are not ready for CMMC.
One of the first steps you should take is to perform a CMMC Readiness Assessment and Gap Analysis. Our Security Team will assess your process, policies and systems, develop an SSP and POA&M, and give you a documented plan of what you need to remediate in order to pass your CMMC audit.
Click on the image below to learn more about how we can help you get ready for NIST and CMMC!