Cybersecurity Maturity Model Certification
What is CMMC?
The Cybersecurity Maturity Model Certification (CMMC) is a new cybersecurity framework by the US Department of Defense (DoD) for the DoD supply chain and its contractors. The goal of the new CMMC compliance requirement is to protect Federal contract Information (FCI) and Controlled Unclassified Information (CUI).
This new umbrella standard includes requirements from NIST SP 800-171, the Federal Acquisition Requirements (FAR) document 52.204-21, and beyond. In the latest iteration CMMC 2.0 which was announced November 4th 2021 there are three levels of CMMC compliance. Each level requires more practices and controls than the previous. Most organizations will have to comply with either Level 1 or Level 2.
Who Needs CMMC Certification?
Only contracts for Commercial off-the-shelf (COTS) products will be exempt from CMMC compliance requirements.
Any company and its subcontractors that bid on a DoD contract that contains Federal Contract Information (FCI) and/or Controlled Unclassified Information (CUI) will be required to be CMMC compliant.
Which Level of CMMC Will We Need?
The CMMC level mandated will be stated in the contract information. The majority of contracts will require a Level 1 or Level 2 compliance.
You will need CMMC Level 1 implementation and certification if your company will receive exclusively FCI under the contract.
CMMC Level2 will be required as a minimum if your organization will receive CUI in addition.
For more details about the different CMMC Level and the assessment requirements see:
CMMC Assessment Readiness Support
Depending on the CMMC Compliance Requirements you will need to comply with, the implementation and compliance status will be verified via an self assessment that needs to be submitted to the SPRS, a Certified 3rd Party Assessor Organization (C3PAO), or DoD officials. While the outside assessments will be valid for three years, any self assessment will have to be conducted annually and need to be accompanied by an annual affirmation from a senior company official that the company is meeting requirements.
Identify security gaps against the 17 Controls (Level 1) outlined in the CMMC Model and provide recommended solutions based on Federal Acquisition Regulations and NIST SP 800-171 r2. Assist in the development of a System Security Plan and associated roadmap to becoming CMMC certified.
Shore Up Documentation
Develop the necessary policies and procedures, incident response runbooks, and best practices to ensure each member of your team owns their respective documentation and is prepared for questions during the CMMC Assessment.
Level 9 Corporation’s Registered Practitioners can actively work with you from pre-assessment to documentation support to remediating the identified gaps in your environment to quickly get you ready for the CMMC Assessment.
When Will CMMC Assessments Be Required?
The DoD has started rolling out CMMC 1.02 compliance requirements for a few pilot contracts beginning of 2021. However, due to the significant changes in the latest CMMC 2.0 iteration the DoD suspended any CMMC requirements for new contracts until the rulemaking process for CMMC 2.0 is completed. In May 2022 CMMC director Stacy Bostjanick announced that the Pentagon plans to publish the CMMC ‘interim rule’ in early 2023, with initial requirements showing up in DoD contracts starting in May 2023.
In the meantime, DFARS 252.204-7012 and -7019 are still in effect and require each organization to have a NIST SP 800-171 Assessment performed, the resulting score submitted to the SPRS, and a System Security Plan (SSP) as well as a Plan of Actions & Milestones (PoA&M) document in place. New DoD contracts might have minimum requirements for the organization’s NIST SP 800-171 assessment score. Although the CMMC compliance requirements are still several months away, we highly recommend that companies who plan to bid on DoD contracts start preparations for their CMMC assessment now. The early adopters of CMMC will have a clear competitive advantage – especially considering that implementation will take several months and compliance is required at the time of contract award.
Currently, the DoD is discussing different incentives for those companies that become compliant before CMMC is mandatory. After years of delays, the CMMC rulemaking process seems to be on track and the latest update by CMMC director Stacy Bostjanick indicated that it is progressing faster than initially announced. Considering the upcoming May 2023 date (revised from July 2023) for CMMC contract requirements we expect a rush with availability of the C3PAOs becoming a bottleneck. In other words – it’s time to get ready sooner than later.
How Long Does It Take to Implement CMMC?
The implementation time-frame depends on these main factors:
The size and scope of your system
The current state of your NIST SP 800-171 implementation
The level of certification you are required to comply with
For example, after an initial Gap Analysis, it will take most organizations 6-12 months to achieve CMMC Level 2 compliance and to be ready for the certification assessment. CMMC Level 1 compliance can be accomplished in a much shorter time-frame. For an overview of the preparation and certification process including some time estimates see CMMC Compliance Process and Timeline.
What Is the CMMC Cost?
The cost of achieving CMMC compliance depends on the same factors as listed above.
You have to consider expenses for these steps:
Determining level of compliance
CMMC Assessment by a CMMC Third-Party Assessor Organization (C3PAO) if you are required to do so (CMMC Level 2 and Level 3)
We advise companies wishing to work with the DoD in the future to expect some ongoing expenses in addition to the initial cost of becoming compliant.
CMMC Compliance & Existing Cybersecurity Requirements
While there is a lot of buzz about CMMC, the reality is that it adds hardly any new requirements. We think it would be helpful to take a step back and summarize all the existing cybersecurity requirements for contractors in the DoD supply chain.