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Navigating the Muddy Waters of CMMC

Author: SEAN LEE, CISSP, MANAGING DIRECTOR

November 15, 2023

In the ever-evolving landscape of cybersecurity, regulatory compliance is a crucial aspect of ensuring your organization’s digital assets and sensitive data are protected from cyber threats. For those in the defense industrial base (DIB), the Cybersecurity Maturity Model Certification (CMMC) is a term that has likely become a prominent part of your discussions. We’re seeing a lot of confusion in the sector. We’d like to shed light on navigating the muddy waters of CMMC and helping your organization steer the course toward compliance.

Understanding the Significance of CMMC

As the threat landscape continues to expand, the U.S. Department of Defense (DoD) recognized the need for robust cybersecurity measures among its contractors and suppliers. CMMC is a direct response to these evolving threats, aimed at ensuring the security of controlled unclassified information (CUI) and other sensitive data. To that end, it identifies cybersecurity standards that any contractor serving the DOD must follow.

CMMC isn’t a one-size-fits-all solution. It’s a tiered framework comprising three levels, each with its specific requirements. The level your organization must achieve depends on the nature of the work you perform for the DoD.

CMMC Basics

The CMMC Final Rule is currently with the OMB and it is expected to be finalized in November. Here are the basics everyone needs to know:

  • CMMC will be required for all defense contractors

All DOD prime and subcontractors will have to comply with CMMC. Even if one subcontractor, no matter how small, on a contract doesn’t have their certification at the time of awarding the contract then the whole thing will be denied. 

  • CMMC will utilize NIST SP 800-171

The current version of NIST 800-171 r2 has 110 requirements. The Final Public Draft of the next version, NIST 800-171 r3, was published in November, with comments due in January 2024, which will add additional requirements to CMMC. Similarly, NIST 800-171A r3—the self assessment guide to NIST 800-171 r3—released its Initial Public Draft this November, and CMMC will eventually require perfect alignment.

Keeping Compliant With CMMC

Anyone subject to CMMC needs to make compliance their top priority, otherwise lucrative contracts with the DOD could disappear. Here’s what it takes to get and stay compliant:

  • Assess Your Current State

Before diving into the intricacies of CMMC compliance, assess your organization’s current cybersecurity posture. Identify existing strengths and weaknesses that need to be addressed.

  • Determine Your CMMC Level

Based on the work you do for the DoD, you must determine the appropriate CMMC level for your organization. The majority of contractors will fall into levels 1 through 3, each with a distinct set of requirements.

  • Develop a Roadmap to Compliance

Creating a roadmap that outlines the steps necessary to achieve compliance is essential. This roadmap should consider factors like personnel training, technology enhancements, and policy development.

  • Leverage Expert Guidance

Navigating the complexities of CMMC can be challenging. Engaging with experienced cybersecurity consultants who understand CMMC requirements and the nuances of your industry is invaluable.

  • Continuous Monitoring and Improvement

Achieving CMMC compliance is not a one-time effort. It’s an ongoing commitment to maintaining and improving your cybersecurity posture, given the evolving nature of threats and the framework itself.

The Good and Bad of CMMC Compliance

CMMC compliance comes with some challenges, but there are major benefits as well. You need to keep both in mind while planning for long-term compliance.

On the challenges side of the equation, meeting CMMC requirements may demand an investment in personnel, technology, and cybersecurity infrastructure and a careful balance between all three. CMMC compliance also necessitates robust documentation and reporting. Ensuring accuracy and consistency can be labor-intensive. Finally, the evolving threat landscape means that maintaining CMMC compliance requires adaptability and an ongoing commitment to best practices.

Overcoming those challenges makes compliance possible, but the benefits are bigger than just that. Being CMMC compliant can give your organization a competitive edge, as it demonstrates your commitment to cybersecurity and data protection. Achieving this certification opens doors to lucrative opportunities within the defense industry since many DoD contracts now require CMMC compliance. CMMC compliance also naturally results in a more robust cybersecurity posture, reducing the risk of data breaches and cyberattacks.

How to Feel Confident About CMMC Compliance

Navigating the muddy waters of CMMC may seem challenging, but it’s a journey that’s worth embarking on. The cybersecurity and compliance landscape is constantly evolving, and CMMC is the defense industry’s response to this changing environment. By understanding the significance of CMMC, developing a comprehensive compliance strategy, and engaging with expert guidance, your organization can not only meet these regulatory requirements but also elevate its overall cybersecurity posture.

At Summit Security Group, we specialize in helping organizations in the defense industrial base achieve CMMC compliance. Contact us today to learn more about how our expertise can guide your organization through the complexities of CMMC and ensure smooth sailing toward compliance.

 

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