The long-awaited Cybersecurity Maturity Model Certification (CMMC) has effectively arrived, and the federal government is encouraging voluntary assessments from a Third-Party Assessment Organization ahead of full implementation. The U.S. Department of Defense (DoD) completed a major rule-making phase on Sept. 15, which is expected to fast-track CMMC 2.0 into government contracts which that CMMC Compliance Requirements are important to understand.
That being said, the three levels of cyber hygiene mandated by CMMC 2.0 can prove challenging for small and medium-sized businesses. The stringent regulations have companies that enjoy revenue as contractors and subcontractors implementing cybersecurity controls numbering from 15 to 134. Organizations will also face hurdles in terms of developing a policy that articulates best practices and educates employees about cybersecurity awareness.
Proactive business professionals are taking steps now to avoid getting put on waiting lists when a bottleneck of companies reaches out to comply during the eleventh hour. Sedulous Consulting Services qualified as a Third-Party Assessment Organization early in the process so that our CMMC experts could help shepherd businesses through the process. In The How-To Guide to CMMC Compliance Requirements, we provide insight and tips on CMMC 2.0 Compliance Requirements.
What are the CMMC 2.0 Requirements?
There are different types of compliance requirements assigned to organizations based on the information they store and transmit. These typically include Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). The former poses a limited national security risk and companies that manage FCI can expect less rigorous — although complex — cyber hygiene requirements.
By contrast, CUI tends to involve a wide range, and some pose a significant threat should the data fall into the hands of a rogue nation. Determining which of the three CMMC 2.0 levels an organization must comply with remains the first hurdle. Following an assessment regarding the FCI and CUI your operation handles, the following requirements may be applicable.
- Level 1: Considered “Basic” cyber hygiene by the DoD, companies that primarily handle FCI fall under its requirements. The level1 CMMC mandate is expected to include 15-17 security controls and 6 covering domains. The controls breakdown relates to the following: Access (4), Identification and Authentication (2), Media Protection (1), Physical Protection (4), System and Communication Protections (2), and 4System and Information Integrity (4).
- Level 2: Touted as “Advanced” cyber hygiene, companies working with a combination of FCI and CUI can anticipate meeting 110 control and 14 domain requirements. Some rank among the most determined forms of cybersecurity, and they pertain to the following: Access Control (22), Awareness Training (3)Audit and Accountability (9), Configuration Management (9), Identification and Authentication (11), Incident Response (3) Maintenance (6), Media Protection (9), Personnel Security (2), Physical Protection (6), Risk Assessment (3), Security Assessment (4), System and Communications Protection (16), and System and Information Integrity (7).
- Level 3: Direct military contractors and those who handle high-level CUI can expect to meet “Expert” cyber hygiene requirements. The cybersecurity of DoD contractors is expected to be hard enough to identify, deter, and repel threats from enemy nations. This will entail more than 130 defense items that include the following: Access Control (8), Asset Management (1), Audit and Accountability (7), Awareness Training (1), Configuration Management (3), Identification and Authentication (4), Incident Response (2) Maintenance (2), Media Protection (4), Personnel Security (6), Physical Protection (6), Recovery (3), Risk Assessment (3), Security Assessment (2), Situational Awareness (1), System and Communications Protection (15), and System and Information Integrity (3).
Businesses on tight IT budgets might have considered in-house assessments as a cost-effective way to comply. Given the number of cybersecurity controls and the complexity of these defenses, it may be prudent to work with a third-party cybersecurity firm with CMMC expertise.
Key Steps to Achieving CMMC Compliance Requirements
Meeting the federal mandate allows businesses to remain in the military-industrial base and generate profits from the often lucrative DoD contracts. The compliance process can be relatively seamless when performed by a CMMC professional. These are the general steps needed to meet the inbound CMMC regulations.
- Identify Data: Review the information your organization stores or transmits and determine whether it is FCI or CUI. If it’s CUI, further analysis may be necessary to align it with one of the three cyber hygiene levels.
- Readiness Assessment: Conduct a thorough audit of your network to identify cybersecurity vulnerabilities. Document the findings and create a plan to cure the gaps.
- Test System: Enlist the support of a Third-Party Assessment Organization to conduct a trial run before the CMMC requirements come online. This provides an opportunity to take corrective measures and earn certification ahead of schedule.
- Cybersecurity Plan: Updates your organization’s best practices, response strategies, and technologies required to meet CMMC demands. It’s also crucial to incorporate cybersecurity awareness training to educate frontline employees about existing and emerging threats.
The DoD has made it abundantly clear that all 300,000 businesses in the military-industrial base will meet the CMMC requirements or find themselves out of the loop. Taking proactive measures before the regulations are part of the process better positions your operation to bid on contracts and generate revenue as a subcontractor.
Contact Sedulous Consulting Services For CMMC 2.0 Compliance
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 and mid-sized businesses to assess their cybersecurity vulnerabilities, secure their network defenses, and meet the stringent CMMC 2.0 requirements. If your company enjoys profits from a military contract or works in the supply chain, contact Sedulous Consulting Services.
