Key Takeaways
1. CMMC Compliance is Mandatory for DoD Contractors: Contractors and subcontractors handling FCI or CUI must comply with CMMC to secure and maintain DoD contracts. However, the level of CMMC compliance depends on the type of information your organization handles.
2. To Prep for CMMC Assessments, Identify Your Gaps and Create a Plan:
While CMMC Levels 1, 2, and 3 have distinct assessment processes and requirements, organizations can prep for each by documenting existing security controls with an SSP, identifying gaps, and creating a POA&M that outlines how you plan to bring unmet requirements into compliance.
3. C3PAOs Offer Essential Support for Level 2 CMMC Compliance:
Partnering with an Authorized C3PAO can significantly enhance your organization’s preparedness, especially for CMMC Level 2, through expert guidance, customized roadmaps, mock assessments, documentation support, and training.
The Department of Defense (DoD) mandates that contractors and subcontractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) comply with the Cybersecurity Maturity Model Certification (CMMC). Achieving CMMC compliance is essential for securing and maintaining DoD contracts.
In this blog, we will explore key steps in the CMMC assessment process and highlight how partnering with a Certified Third-Party Assessment Organization (C3PAO) CMMC audit readiness consultant can facilitate certification.
What Is a CMMC Assessment?
A CMMC assessment evaluates an organization’s adherence to DoD cybersecurity practices and processes across three maturity levels:
- Level 1 (Basic Safeguarding of FCI): CMMC Level 1 focuses on the basic safeguarding of FCI and requires adherence to 15 practices derived from FAR 52.204-21. Under CMMC Level 1, organizations must conduct annual self-assessments and affirm compliance with the Supplier Performance Risk System (SPRS). A full breakdown of how to prepare for and conduct a CMMC Level 1 self-assessment can be found in the DoD’s official CMMC Assessment Guide Level 1.
- Level 2 (Broad Protection of CUI): CMMC Level 2 focuses on safeguarding CUI and encompasses 110 security requirements aligned with NIST SP 800-171 Revision 2. Depending on the sensitivity of the information and contract requirements, organizations may undergo either a self-assessment or a third-party certification assessment conducted by an Authorized C3PAO. More details can be found in the DoD’s official CMMC Assessment Guide Level 2.
- Level 3 (Higher-Level Protection of CUI Against Advanced Persistent Threats): CMMC Level 3, also known as the “Expert” level, is designed to protect Controlled Unclassified Information (CUI) against Advanced Persistent Threats (APTs). It encompasses all 110 security requirements from NIST SP 800-171, plus an additional 24 enhanced controls from NIST SP 800-172, totaling 134 practices. Unlike Levels 1 and 2, Level 3 assessments are conducted by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC), a government-led body. You can find a full breakdown in the DoD’s official CMMC Assessment Guide Level 3.
Key Steps When Preparing for a CMMC Assessment
While the CMMC assessment process varies depending on which level of CMMC certification you’re pursuing, there are some common steps that organizations can take to prepare.
- Determine the Applicable CMMC Level: Identify the appropriate CMMC level based on the type of information your organization handles and your contractual obligations. If you have any assets—such as systems, people, and facilities—that process, store, or transmit FCI, you’ll want to focus on CMMC Level 1. If your organization handles CUI, you’ll want to pursue CMMC Levels 2 and 3. Contracts involving critical national security information typically require a third-party assessment, while others may permit self-assessment.
- Conduct a Gap Analysis: Next, evaluate current cybersecurity practices against the appropriate level of CMMC requirements to identify areas needing improvement. Level 1 requires adherence to FAR 52.204-21 while Levels 2 and 3 align with NIST SP 800-171 Revision 2. Level 3 also requires additional security controls from NIST SP 800-172. It’s important to understand where your organization does and does not meet CMMC’s requirements before undergoing an official assessment.
- Develop a System Security Plan (SSP) and Plan of Action & Milestones (POA&M): Document existing security controls and outline plans to address identified gaps. This step is especially important for CMMC Levels 2 and 3. The SSP acts as documentation of how your organization meets the applicable CMMC security requirements while the POA&M serves as your guiding light for bringing any unmet requirements into compliance.
- Implement Necessary Controls: Once you’ve identified the gaps and created a plan of action, address any deficiencies by implementing required cybersecurity practices and processes. This will ensure you’re prepared for your official CMMC assessment.
- Undergo a Formal CMMC Assessment: Once the above steps have been completed, you’re ready to undergo an official CMMC assessment. Organizations pursuing Level 1 certification can complete a self-assessment, as can some organizations pursuing Level 2 certification. However, other Level 2 certifications require organizations to coordinate with an authorized C3PAO, while Level 3 assessments must be conducted by DIBCAC.
The Role of C3PAO and CMMC Audit Readiness Consultants
Engaging with an Authorized C3PAO CMMC audit readiness consultant can significantly enhance your organization’s preparedness, particularly if you’re pursuing Level 2 CMMC compliance.
Authorized C3PAO organizations can provide you with:
- Expert Guidance: Consultants provide insights into CMMC requirements and help interpret complex standards.
- Customized Roadmaps: Consultants also develop tailored plans to achieve compliance, considering your organization’s specific needs.
- Mock Assessments: Authorized C3PAO experts can conduct simulated audits to identify potential issues before the formal assessment.
- Documentation Support: C3PAO-certified organizations can also assist in creating and organizing necessary documentation, such as SSPs and POA&Ms.
- Training and Awareness: Finally, consultants can offer training programs to ensure staff understand and adhere to cybersecurity practices.
For instance, IS Partners is an Authorized C3PAO, providing comprehensive and fully customized CMMC Level 2 readiness assessments that help organizations identify security gaps, develop remediation plans, and prepare for CMMC audits. Our organization has a 95% client retention rate, leveraging over 20 years of experience in compliance across industries to deliver a tailored approach to audit preparation and certification.
Achieving CMMC certification is a critical step for DoD contractors and subcontractors. By understanding the assessment process and leveraging the expertise of C3PAOs and audit readiness consultants, organizations can navigate the complexities of CMMC compliance effectively. Proactive preparation not only ensures compliance but also strengthens your organization’s cybersecurity posture, making you a more reliable partner in the defense supply chain.
To learn more about how IS Partners can help you achieve CMMC Level 2 compliance, visit our CMMC compliance services page.
What Should You Do Next?
Determine your required CMMC level: Identify the specific CMMC level required based on the information your organization handles and your contractual obligations. This will dictate the necessary steps for compliance.
Conduct a gap analysis: Evaluate current cybersecurity practices against the relevant CMMC requirements to identify areas needing improvement. This helps create a roadmap for compliance.
Consider Engaging an Authorized C3PAO: If pursuing CMMC Level 2, engage with an authorized C3PAO like IS Partners for expert guidance, mock assessments, and support with documentation and training to ensure thorough preparation.
It is important for organizations to have internal subject matter experts or leverage a third party like ISP to guide the organization’s understanding of NIST compliance. ISP provides virtual CISO services and NIST compliance audits to help organizations get a better understanding of the efforts needed to align with NIST requirements. Organizations should also ensure strategic goals are set and importance is placed on compliance efforts.
Ready to secure your organization’s compliance with a tailored approach? Connect with us to set up a consultation today.
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