Small businesses working in the military supply chain are being urged to begin the process of meeting federal cybersecurity mandates as final rulemaking nears completion.
The U.S. Department of Defense (DoD) has been diligently working on an updated version of the Cybersecurity Maturity Model Certification (CMMC) that reduces cyber hygiene levels from five to three. Being hailed as CMMC 2.0, much of the framework is already available for small businesses to integrate into the defenses. High-profile military contractors and organizations handling sensitive digital assets can anticipate additional stringent measures that could exceed the control outlined in the initial version.
The good news for small businesses that primarily handle Federal Contract Information (FCI) or relatively routine Controlled Unclassified Information (CUI) is that you can get ahead of the anticipated CMMC compliance logjam. At the same time, the federal government completes its rulemaking process.
What CMMC Level Applies to Small Businesses?
The Pentagon indicated that small businesses providing essential products, materials, and services to contractors in the military-industrial base may have the option to self-assess their cybersecurity. But the complicated nature of the CMMC framework and identifying which level and controls apply to your operation can be something of a Herculean task. Unless you possess in-depth cybersecurity knowledge and an intimate understanding of federal regulations, we advise entrepreneurs and other decision-makers to enlist a third-party CMMC expert’s support promptly.
The first step in preparing for the CMMC rollout involves understanding which cyber hygiene applies to your company. The federal government isn’t making CMMC 2.0 user-friendly. Professionals won’t have simple metrics to follow, such as the number of employees, annual revenue, or even categories based on products, services, or materials.
To determine which of the three cyber hygiene levels applies to your organization, a managed IT professional with cybersecurity expertise will likely need to review the mandate and weigh its contents against the type of digital information you store or transmit. You see the problem if that seems like a steep hill to climb.
The Pentagon expects small businesses with few employees and a limited IT budget to determine the type of FCI or CUI they possess or transmit. Modestly sized subcontractors and supply chain operations will likely fall into one of the following two CMMC levels.
• Level 1: The DoD considers Level 1 cyber hygiene “foundational,” and small businesses are tasked with meeting 17 protocols that have already been published as part of the NIST 800-171 regulations. Level 1 controls are designed to protect FCI because foreign threats try to piece together this information to learn about the larger national security strategy. Although FCI is not necessarily sensitive, basic cyber hygiene generally deters hackers.
• Level 2: The Pentagon considers Level 2 cyber hygiene “advanced,” which involves upwards of 110 NIST protective measures. The Level 2 focus remains on CUI, and a great deal of uncertainty surrounds its CMMC compliance. According to early reports, the DoD plans to allow some outfits to self-assess while others need to bring in a Third Party Assessment Organization (C3PAO), such as ours. Determining where your small business falls can be complicated. And a misstep could result in getting sidelined from profitable DoD supply chain work.
• Level 3 CMMC compliance is primarily designed to protect susceptible digital assets stored and transmitted by military contractors and their closest subcontractors. That determination is based on the type of information they handle and requires a diligent assessment of the digital assets. But the elephant in the room revolves around the critical next step small businesses need to take to meet the CMMC requirements right now.
How Small Businesses Can Stay Ahead of the CMMC Mandate
It’s important to note that companies currently engaged in lucrative DoD work are expected to maintain appropriate cybersecurity defenses. The federal government has made it abundantly clear its dissatisfaction in recent years stems from companies failing to meet long-standing expectations. The decision to implement CMMC 1.0 and 2.0 stems from the fact too many contractors and subcontractors got hacked, and the Pentagon discovered their lackluster defensive posture after the fact.
So moving forward, businesses must file self-assessment results with the Pentagon’s Supplier Performance Risk System. Subpar scores are likely to be flagged, and small, mid-sized, and large corporations will be tasked with implementing corrective measures swiftly. If an outfit continues to miss the mark, business professionals can anticipate temporarily shutting out of the military-industrial base.
Of course, risking your livelihood by waiting until the mandates go into full effect can be avoided. So we urge small businesses that help military defense agencies and soldiers do their job to enlist the support of a C3PAO now.
By implementing an FCI and CUI review, you can get ahead of the curve by knowing precisely which CMMC level applies to your operation. Then Sedulous can bring a cost-effective cybersecurity assessment to bear that tests your defenses, ability to deter hackers and keep pieces to the national security puzzle out of the hands of bad actors.
Strategies such as penetration testing, gap assessment, and providing your staff with basic cybersecurity awareness training can harden your defenses. Remember that most data breaches involve clever hackers tricking employees into clicking on a malicious link, downloading a tainted file, or innocently revealing login credentials.
Contact Sedulous Consulting Services For A CMMC Compliance Assessment
Based in Triangle, Virginia, Sedulous Consulting Services ranks among the first 100 organizations to qualify as a Third-party Assessment Organization. We work diligently with small business leaders in the supply chain to assess cybersecurity vulnerabilities, secure their networks, and maintain CMMC compliance. If your company enjoys profits from a military contract or works in the supply chain, contact Sedulous Consulting Services.