Defense Industrial Base (DIB) contractors have faced escalating cybersecurity risks in recent years. In a proactive attempt to prevent major security breaches, the Department of Defense (DoD) developed the Cybersecurity Maturity Model Certification (CMMC).
The main goal of CMMC is to safeguard controlled unclassified information (CUI) across the DoD supply chain. CUI is defined as any data or information created or possessed by the government or another entity on the government’s behalf.
What Is CMMC Compliance?
CMMC is a unifying standard initially released by the DoD in 2020. The certification model aims to improve cybersecurity practices within the DIB ecosystem and ensure that contractors accurately implement the appropriate cybersecurity processes and practices to protect CUI and federal contract information (FCI).
Version 2.0 of the CMMC is categorized into three certification levels. These include:
- Level 1 – CMMC Level 1 is the “Foundational” level and consists of 17 practices and requires an annual self-assessment.
- Level 2 – CMMC Level 2 is the “Advanced” level and consists of 110 practices that align with NIST SP 800-171. Maturity Level 2 requires an annual self-assessment for certain programs and a third-party assessment for critical national security data.
- Level 3 – CMMC Level 3 is the “Expert” level and consists of 130 practices based on NIST SP 800-172 and requires a government-led assessment.
The need for CMMC has become increasingly necessary due to advancements in technology that allow cybercriminals to gain access to sensitive government information. When CMMC practices are properly implemented, DIB contractors can effectively guard against ransomware, phishing attacks, cyberattacks by foreign governments and other situations that could put them at risk.
How CMMC Compliance Impacts Federal Contracts
Many organizations are wondering how exactly CMMC compliance will impact federal contracting in the foreseeable future. While the details of the Cybersecurity Maturity Model Certification are still being finalized, there are some things that DIB contractors should know when it comes to CMMC compliance.
First, contractors will need to start preparing now to ensure that they are ready when they are required to meet CMMC requirements to win federal contracts. According to the most recent guidelines from the DoD, CMMC 2.0 is expected to take between 9 and 24 months of rulemaking. During this time, contractors should use the resources available to them to implement NIST 800-171. This will help improve the self-assessment score that they post to the Supplier Performance Risk System (SPRS).
Secondly, CMMC 2.0 requires annual affirmation provided by a senior company official. In addition, the Department of Justice (DOJ) recently announced its intent to hold individuals or entities accountable that knowingly misrepresent their cybersecurity practices. It is the responsibility of organizations to evaluate their process for completing this annual affirmation and determine who will sign the document. This affirmation is a statement that verifies that the self-assessment results reported to the SPRS are accurate.
Other areas that contractors must consider that could impact federal contracting relate to plan of action and milestones (POA&Ms) and waivers. Once CMMC 2.0 has been implemented, the DoD will allow companies to receive contract awards with a POA&M in place to complete their CMMC requirements. With CMMC 2.0, the DoD will also allow a limited waiver process to exclude certain CMMC requirements. All waiver requests will require senior DoD leadership approval and have a minimal duration.
By 2026, all contractors with the federal government will be required to meet the requirements of at least CMMC Level 1. Until this time, only DoD contractors will be required to have CMMC Level 1, 2, or 3, based on their unique contract. Currently, there are only a handful of DoD contracts that require some level of CMMC but more contracts will become available in upcoming months.
Contractors that wish to be rewarded with federal contracts can benefit from performing self-assessments. These assessments help companies identify potential gaps between their current security posture and what is needed to pass the full assessment by a certified third-party assessment organization (C3PAO). Organizations that perform thorough and periodic self-assessments will often find more success when implementing security programs.
How a Managed IT Service Provider Can Help
Preparing for CMMC compliance can be a resource-intensive and tedious process that often requires the assistance of a CMMC expert. Working with a managed IT service provider who is familiar with CMMC and its maturity levels can provide contractors with strategic and highly reliable audit preparation.
A managed IT service provider can also help companies submit a strong risk score to the DoD. With a strong score, contractors can feel confident about continuing their contracts and position their company favorably for future government work.
Schedule a Consultation with SeaGlass Technology
SeaGlass Technology has helped countless DoD contractors gain a deeper understanding of the security risks they face and how best to guard against these threats. Schedule a consultation today to learn more about how CMMC compliance can impact federal contracting.