Cybersecurity is increasingly becoming a matter of national security, as protecting sensitive digital information, especially by implementing best practices by third-party contractors, is vital.
This article explores how the Cybersecurity Maturity Model Certification (CMMC), a program designed by the Department of Defense (DoD), ensures that defense contractors don’t compromise national security.
What Is CMMC Compliance, and Why Is It Essential For Defense Contractors?
CMMC is a cybersecurity standard implemented by the US Department of Defense to protect sensitive data within its supply chain. It is a framework consisting of several cybersecurity standards and best practices consolidated into a single set of cohesive standards.
The importance of CMMC compliance for defense contractors lies in the nature of the information they handle. Defense contractors often handle sensitive data, such as Federal Contract Information (FCI) and Controlled Unclassified Information (CUI), which, if compromised, could pose a risk to national security.
By creating a cybersecurity standard, the DoD is aiming to mitigate these risks. Compliance with the CMMC ensures that a defense contractor has adequate cybersecurity measures in place to protect sensitive data. Furthermore, only those contractors who are CMMC compliant will be eligible for DoD contracts in the future, ensuring that all aspects of the DoD’s operations are secure.
Therefore, CMMC compliance is necessary not only for data security but also for defense contractors' continued business success.
Critical Steps Businesses Should Include In a Comprehensive CMMC Compliance Checklist
- Understand Your Data: Identify all the Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) within the organization and how it is stored, processed, and transmitted.
- Identify Your Organization's Maturity Level: Select the correct CMMC maturity level based on the sensitivity of the data your organization regularly handles. All defense contractors must meet at least Level 1 requirements, whereas contractors handling CUI must aim for Level 2 or higher.
- Perform a Gap Analysis: Analyze your organization's current cybersecurity practices against the requirements of the chosen CMMC level to identify the gaps.
- Develop a Remediation Plan: Based on the gap analysis findings, develop a strategic action plan to address the identified gaps.
- Implement Required Controls: Implement measures to close identified gaps. This might include technical controls like adding new security solutions, and procedural controls like developing new policies or training programs.
- Document Your Process: Maintain accurate and detailed records of all relevant security procedures, processes, and controls for CMMC assessment, especially those regarding any incidents and their mitigation responses.
- Train Your Staff: Ensure all employees understand the importance of CMMC compliance and are trained in new procedures and security measures.
- Perform Regular Audits: Conduct periodic internal audits to test the efficacy of the implemented measures and ensure continuous compliance.
- Prepare for Assessment: Prepare to undergo a CMMC Third Party Assessment Organization (C3PAO) evaluation by gathering necessary documentation and reviewing processes and controls beforehand.
- Monitor and Adjust: Regularly monitor your security environment, update processes and controls when necessary, and adjust your strategy to keep up with the changing cybersecurity landscape.
- Use a Compliance Management Tool: Consider deploying dedicated compliance management software to streamline and automate many routine compliance tasks, enabling you to make continued compliance easier. Such tools can provide useful features like gap analysis, workflow creation, status tracking, and compliance reporting.
- Consider Getting Expert Help: Seek guidance from a security professional or a Managed Security Service Provider (MSSP) familiar with the security solutions they provide and the CMMC framework to help guide your organization through the compliance process.
Remember, the goal of CMMC compliance is to maintain a robust cybersecurity posture continually, not just to achieve compliance or pass an audit.
The Specific Documentation and Practice Requirements Needed at Each CMMC Maturity Level
The CMMC features three updated certification levels, each with defined practices and specific documentation requirements.
Level 1: Foundational Cyber Hygiene
- It includes 17 practices primarily designed to safeguard Federal Contract Information (FCI).
- Documentation Requirements: No specific documentation is required at this level. Organizations must merely demonstrate their performance in basic cyber hygiene practices, such as using antivirus software and employing current software/operating systems.
Level 2: Advanced Cyber Hygiene (Equivalent to NIST 800-171)
- This level encompasses 110 practices designed to protect Controlled Unclassified Information (CUI).
- Documentation Requirements: Organizations need to establish and maintain policies that guide implementing all 110 CMMC practices from Level 2 (aligned with NIST 800-171). A System Security Plan (SSP) and a Plan of Action & Milestones (POAM) must be created.
Level 3: Expert Cyber Hygiene (Subset of NIST 800-172 and other cybersecurity best practices)
- This level involves cyber protection enhanced further to include 63 additional practices beyond Level 2, totaling 173 practices.
- Documentation Requirements: Alongside the SSP and POA&M, organizations need to show proof of comprehensively managing their plan and documentation. This involves maintaining or capturing specific actions, reviews, security measures, and metrics outlined in the CMMC model guide.
Remember that the practices for each level include those from the preceding levels. So, an organization aiming for CMMC Level 3 must also adhere to practices required at Levels 1 and 2.
The CMMC 2.0 update prioritized scalability and cost-effectiveness, meaning most organizations handling CUI only need to achieve Level 2 compliance. In special cases, only a small percentage of the defense industrial base must pursue Level 3 certification.
What Common Mistakes Do Companies Make When Following a CMMC Compliance Checklist?
Companies often make the following mistakes when following a CMMC compliance checklist:
Misunderstanding the Requirements: Many companies interpret the CMMC controls differently, leading to discrepancies in their security measures. This can result in non-compliance during the assessment.
Undertaking DIY (Do-It-Yourself) Compliance: Many companies attempt to self-assess, resulting in incomplete or incorrect implementation of security practices. This can risk non-compliance during third-party evaluation.
Insufficient Documentation: Proper documentation of practices, controls, and assessment details is essential for CMMC compliance. Businesses often overlook the importance of maintaining comprehensive and detailed information for the audit.
Misidentifying Your Maturity Level: Organizations must accurately determine their required CMMC maturity level (1-3). Misjudging this can lead to implementing unnecessary measures or missing crucial security practices.
Ignoring Existing Security Measures: Companies often overlook their existing security measures, which might already comply with some CMMC requirements, leading to redundant efforts and unnecessary costs.
Assuming Compliance Is a One-Time Effort: CMMC compliance is a continuous process. Failing to monitor, assess, and update security measures periodically can lead to lapses in compliance.
Not Involving Higher Management: Often, cybersecurity is treated as an IT issue, and senior management is not involved. However, cybersecurity must be addressed at all levels, from the C-suite down, as it impacts the entire organization.
Failing to Integrate with Subcontractors: If a company's subcontractors have access to Controlled Unclassified Information (CUI), they must also be CMMC compliant. Not verifying subcontractors' compliance can risk the entire project's certification.
Neglecting Employee Training: Organizations sometimes underestimate the importance of ongoing staff training in maintaining strong cybersecurity. CMMC requires documented proof that companies have performed adequate training. This is often overlooked, leading to non-compliance.
Not Allocating Adequate Resources: Successfully achieving CMMC compliance typically requires an investment in resources, including time, personnel, and technology. Insufficient allocation can lead to non-compliance.
How Organizations Can Verify That Their Checklist Effectively Prepares Them For Certification
Organizations can effectively verify their preparedness for certification through several steps:
- Understand the CMMC Requirements: Be thoroughly familiar with the requirements of the specific CMMC level that applies to your organization. This includes understanding the security practices and processes expected to be implemented and maintained.
- Conduct Self-Assessments: Conduct regular audits and assessments of your cybersecurity infrastructure to see if it aligns with CMMC requirements. This will give you a clear idea of how prepared your organization is for certification.
- Implement POAM (Plan of Action & Milestones): A Plan of Action & Milestones (POAM) can help track the actions taken to address gaps identified during self-assessments or audits. Following a POAM ensures that all necessary steps are taken to reach compliance.
- Use CMMC Compliance Tools: Numerous tools available in the market can help manage and monitor compliance requirements. These tools can provide automated assessments, track compliance evidence, and alert organizations about potential non-compliance issues.
- Engage a C3PAO (CMMC Third Party Assessment Organization): Along with self-assessments, engaging with a C3PAO for a pre-assessment audit can help verify your organization's preparedness for the official CMMC assessment. C3PAOs are organizations accredited by the CMMC Accreditation Body (CMMC-AB) to conduct CMMC assessments.
- Proactively Address Gaps: Don’t wait until your assessment to resolve any gaps or weaknesses in your security infrastructure. Begin working on solutions as soon as problems are identified.
- Regularly Review and Update Policies and Procedures: Cybersecurity is not a one-time task, and neither is CMMC compliance. Ensure all policies and procedures are periodically reviewed and updated to match the current risk landscape and meet CMMC requirements.
Leverage Fortra Data Classification to Boost CMMC Compliance
Achieving and maintaining CMMC compliance requires partnering with experienced vendors that understand the CMMC compliance process. Fortra's data protection solutions, including Data Classification Suite (DCS), provide immediate value in your efforts to safeguard CUI and CMMC-regulated data.
Fortra's Data Classification Suite has a pre-built CUI template that allows organizations to drop and load CUI in a matter of minutes across the primary Microsoft Office tools, and all it takes is installing the DCS agent and training the key individuals handling CUI content. This then allows our powerful Data Loss Prevention solution to properly enforce CMMC policies, keeping your organization compliant.
Ready to see our solutions in action? Contact us today to chat with our experts about how Fortra Data Classification will make CMMC compliance a breeze.