Achieving CMMC Compliance Success: Navigating CMMC 2.0 Compliance

At a glance

• The main takeaway: Whether you are a prime contractor, subcontractor, consultant, supplier, or even indirectly providing services to the DoD, compliance with CMMC is mandatory when you are handling FCI or CUI.
• Impact on you: By achieving CMMC compliance, contractors help protect sensitive data, maintain trust with partners, and secure their position within the defense supply chain.
• Next steps: CMMC compliance requires meticulous planning, strategic execution, and careful attention to detail. Aprio is here to help.

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The full story:

Cybersecurity has been a critical concern for many years, gaining traction with the rising frequency and complexity of cyberattacks. These attacks often have devastating and costly repercussions. The Department of Defense (DoD), a prime target for cyberattacks and data breaches, developed the Cybersecurity Maturity Model Certification (CMMC) program to protect national security. The CMMC program enforces stringent cybersecurity standards for all contractors within the defense industrial base, regardless of their size or the nature of their products or services.

Whether an organization is a prime contractor, subcontractor, consultant, supplier, or even indirectly providing services to the DoD, compliance with CMMC is mandatory if their work involves handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). The CMMC framework aims to protect sensitive government information from cyber threats and helps ensure that contractors are compliant with security standards. By achieving CMMC compliance, organizations can safeguard their data, maintain trust with partners, and secure their position within the defense supply chain.

Steps to Achieve CMMC Compliance

1.    Identify your certification level.

The CMMC framework uses a three-tiered model, with increasing security level requirements at each tier. The level at which a company falls is determined by the type of information it stores, processes, or transmits from the DoD.

Level 1 is designated for organizations that handle FCI. If a company stores, processes, or transmits FCI, it will likely fall under Level 1. This level does not require an audit by a Certified Third-Party Assessor Organization (C3PAO) and only involves an annual self-assessment.

Level 2 is for organizations that handle CUI. Most contractors will fall under this level. Level 2 requires an audit by a C3PAO every three years, along with an annual affirmation.

The key differentiator between Level 1 and Level 2 is whether the organization handles CUI. If unsure, companies should check if any data received from their prime contractor, or the DoD, is marked as CUI or ITAR. Although these physical markings can be inconsistent, reviewing existing contracts for clauses like DFARS 7012 or NIST 800-171 can provide clarity. Additionally, cybersecurity questionnaires or attestations may contain relevant clauses. If none of these indicators are present and the contractor does not anticipate handling CUI in the future, Level 1 may be sufficient. Ultimately, the contract will provide definitive guidance.

Level 3 encompasses all requirements of Level 2, plus additional controls. This level is reserved for the highest priority critical defense programs and affects only about 1% of contractors. Instead of being audited by a C3PAO, organizations at Level 3 are audited by the government every three years.

2.    Assess your current CUI ecosystem to identify the boundary.

Organizations, particularly those among the 80,000 contractors at Level 2, must identify where their CUI assets reside and how they move through their environment. This process involves mapping out the flow of information and pinpointing areas that require enhanced security measures. By defining a clear boundary, organizations can ensure all CUI is protected. A clearly defined boundary helps in implementing targeted security controls and reduces the risk of data breaches.

3.    Implement or validate technical controls.

CMMC 2.0 outlines 110 controls and 320 objectives that organizations must implement or validate. These controls cover various aspects of cybersecurity, including access control, incident response, and risk management. Aligning your policies, procedures, and technical controls with CMMC requirements is essential for compliance. Organizations should regularly review and update their controls to address emerging threats and vulnerabilities.

4.    Use current artifacts like SSP and policies to meet CMMC requirements.

The System Security Plan (SSP) and other documentation play a vital role in demonstrating CMMC compliance. Organizations should leverage existing policies and procedures to meet CMMC requirements. Proper documentation not only aids in compliance but also facilitates the assessment process. Maintaining comprehensive and up-to-date documentation ensures that organizations can provide evidence of their security practices during audits.

5.    Engage a C3PAO for assessment.

C3PAOs are responsible for conducting CMMC assessments. Engaging a C3PAO involves preparing for the audit by ensuring all controls are in place and evidence of compliance is readily available. Organizations should be prepared to pass the C3PAO audit to achieve certification. This preparation includes conducting internal audits, addressing any gaps, and ensuring all documentation is complete and accurate.

6.    Maintain continuous compliance.

Continuous monitoring and maintaining compliance are key to long-term success. Organizations should implement strategies for regular training, updates, and monitoring to ensure ongoing adherence to CMMC requirements. This proactive approach helps mitigate risks and maintain a robust cybersecurity posture. Regularly reviewing and updating security practices ensures that organizations remain compliant with evolving standards.

Common CMMC Compliance Challenges

Defining the CMMC Boundary

Identifying and securing CUI can be complex, especially in hybrid environments where information flows regularly between different systems and contractors. Organizations must establish clear boundaries to ensure all CUI is protected. This involves conducting thorough assessments and implementing the appropriate security measures to safeguard sensitive information.

Organizations also need to determine which external service providers must meet CMMC requirements. Prime contractors are responsible for identifying which subcontractors fall within their boundary and informing them of their need for certification. Ensuring the entire supply chain is actively involved in CMMC compliance helps prevent gaps or leaks that could otherwise compromise the system’s integrity.

Providing Evidence of Compliance

CMMC compliance is not just about having policies and procedures in place or implementing a few security controls. Organizations must provide evidence that they are following these requirements and meeting the intent of the 110 controls and their 320 objectives. Many organizations lack the knowledge and experience to understand the objectives and nuances within CMMC, making the provision of artifacts challenging.

Disorganization is also a common issue, with evidence often spread across different departments, people, and systems. Additionally, many companies do not have established processes for evidence management, or their existing processes may not meet new CMMC requirements. It is not uncommon for organizations to overhaul their policies and procedures to align with CMMC standards.

Collecting and organizing evidence of compliance can be daunting, but proper evidence management is essential for a successful assessment. Implementing systematic approaches to collect, store, and present evidence helps streamline the audit process and ensures that organizations can effectively demonstrate their compliance efforts.

Ensuring Audit Readiness

Preparing for the C3PAO audit requires thorough readiness. Organizations should ensure they have all necessary documentation and controls in place. Engaging with a readiness partner who can provide additional support and guidance helps ensure audit readiness. A partner like Aprio can help you identify potential gaps, address weaknesses, and enhance your overall security posture.

The bottom line

Achieving CMMC compliance is a critical step for organizations within the defense industrial base. It requires meticulous planning, strategic execution, and careful attention to detail.

Aprio is here to help you chart a clear path towards CMMC compliance. Our Achieving CMMC Success: A Clear Path to Compliance Webinar delves into foundational information on CMMC certification levels and practical strategies for CMMC 2.0 compliance success. It offers valuable insights and real-world applications to help organizations take actionable steps towards compliance. Watch the on-demand CMMC webinar today.

Related Resources/Assets/Aprio.com articles/pages

• Achieving CMMC Success: A Clear Path to Compliance On-Demand Webinar
• CMMC Services and Solutions for Government Contractors Sheet
• Government Contracting Consulting & Advisory Services Page