Identifying the Top 3 CMMC 2.0 Challenges

The Pentagon plans to publish a cybersecurity rule during the first quarter of 2023 that will quickly be inserted into military supply chain contracts. Once the deadline passes, organizations that benefit from lucrative U.S. Department of Defense (DoD) contracts and subcontracts could be sidelined. Unfortunately, that means time is of the essence in terms of Cybersecurity Maturity Model Certification (CMMC 2.0) compliance. Inevitably, there will be some things that are confusing with the CMMC 2.0 release, so to prepare we’ve outlined the Top 3 CMMC 2.0 Challenges. 

Small, mid-sized, and large companies working in the military-industrial base can anticipate some headwinds in meeting the standards set under CMMC 2.0. The federal government has upped the ante, so to speak, because foreign hackers have managed to penetrate systems with the most determined cybersecurity defenses. For example, a Russian-backed hacking group infiltrated the U.S. Treasury and the U.S. Department of Commerce in 2020 through would many consider a backdoor.

Sophisticated and well-funded by rogue nations, hackers work tirelessly to identify vulnerabilities in the military supply chain. By piecing together sensitive data, or planting malicious software, America’s national security policies and procedures can be exploited. That’s why CMMC 2.0 is being implemented, and everyone needs to harden their cybersecurity posture. Organizations that have yet to onboard a CMMC Third Party Assessment Organization (C3PAO) can anticipate challenges resulting from the following.

1: Delaying A CMMC 2.0 Assessment

One of the most significant challenges organizations face is mainly self-inflicted. The notion that the DoD plans to release its rulemaking early in 2023 gives a handful of business leaders a false sense they have plenty of time. Nothing could be further from the truth.

It’s important to understand that some networks require only minor enhancements to achieve CMMC 2.0 compliance. A C3PAO could very quickly vet the system and identify easily correctable vulnerabilities. By that same token, companies tasked with meeting the stringent guidelines outlined in Level 2 and Level 3 of the model could require significant upgrades and a cybersecurity policy that meets DoD standards. Implementation could take months, and staff members may need cybersecurity awareness training.

More business professionals need to realize that a limited number of C3PAOs are available to perform assessments, make recommendations, and help the in-house IT team adjust. As the CMMC 2.0 standards in contracts grow closer, waiting lists are expected, and some companies will miss the deadline. If your organization hasn’t undergone a rigorous cybersecurity assessment, consider yourself tardy.

2: Thinking About CMMC 2.0 Challenges As A Checklist

The federal government continues to change and enhance wide-reaching regulations so often that private-sector people feel they are a nuisance. It’s difficult to disagree with that experience, given CMMC 2.0 comes on the heels of the initial CMMC 1.0 getting scuttled before it was even implemented. It may be human nature to grow weary of changing regulations but treating CMMC 2.0 as a type of checklist will likely lead to failed compliance. Instead, consider what each cyber hygiene level involves.

• Level 1: This basic cyber hygiene level tasks businesses with implementing 17 controls to protect Federal Contract Information (FCI).
• Level 2: This advanced cyber hygiene protocol requires organizations to implement and maintain 110 cybersecurity controls to prevent the theft of Controlled Unclassified Information (CUI). These controls were developed by the National Institute of Technology and Standards (NIST).
• Level 3: Considered expert cybersecurity, companies must meet 110 NIST controls and a subset of enhanced protections. These are subject to regularly scheduled audits by a certified third-party assessment firm.

Despite what some might consider bureaucratic clumsiness, cybersecurity mandates such as the Health Insurance Portability and Accountability Act (HIPAA), the 1999 Gramm-Leach-Bliley Act, and the 2002 Homeland Security Act protect everyday people from hackers stealing valuable and sensitive digital information. The rollout of CMMC 2.0 will provide enhanced security for the men and women in the armed forces, as well as everyday civilians.

Few operations can update antivirus software and check the proverbial box for the DoD. The CMMC 2.0 mandate requires regular reviews, recertification, and changes are likely to continue.

‍3: Not Having A Comprehensive Cybersecurity Strategy For CMMC 2.0

To remain in the DoD supply chain, wide-reaching organizations need a System Security Plan (SSP) that meets NIST guidelines. An SSP goes much further than hardening a network’s cybersecurity measures. Instead, it looks at how CMMC-related defenses are implemented and their effect on other systems in their orbit. The basic concept is that a hacker could spend a great deal of time and energy targeting a seemingly peripheral small business because its syncs with a bigger national security fish that houses useful CUI or FCI.

Businesses can expect that CMMC 2.0 auditors will deeply dive into a business’s written SSP and compare it to actual best practices. To say more than a few small and mid-sized companies do not have an up-to-date and fully functioning SSP would be something of an understatement. That’s why SSP development and implementation are significant challenges to meeting the fast-approaching CMMC 2.0 mandate.

Prepare for the CMMC 2.0 Deadline by Scheduling a Gap Assessment

Executing a gap assessment is a crucial step in achieving CMMC 2.0 compliance. This process involves collecting wide-reaching security data regarding your current security posture. Once this data is gathered, an experienced C3PAO firm analyzes every facet of your cybersecurity. Business leaders receive a report and expert advice about curing vulnerabilities and how to mitigate or remediate them. This step can position you for CMMC 2.0 compliance and avoid being sidelined.

Sedulous Consulting Services is an approved C3PAO candidate and managed IT/Cybersecurity firm. Our dedicated and experienced team members can comprehensively conduct a gap assessment and help your business overcome any CMMC 2.0 challenges ahead. Contact Sedulous Consulting Services today.