CMMC Compliance

Cyber security is vital in an increasingly connected world, and this is particularly true regarding systems that are used by contractors and subcontractors for the United States Department of Defense. Given the nature of the work that the Department of Defense does, the highest levels of information security procedures must be implemented. This is why contractors and subcontractors who intend to work with the Department must consider the importance of CMMC certification in the work that they do.

The Department of Defense has released CMMC 20 requirements which are the latest iteration of the cybersecurity model used by the Department over many years. Staying within compliance with these regulations is the only way that a given contractor or subcontractor can hope to get or maintain work with the Department of Defense. Let's take a look at what the CMMC requirements are and what they mean.

What is CMMC Compliance?

CMMC compliance in full refers to the things that contractors and subcontractors must do to maintain their contracts with the Department of Defense. It is necessary to meet all of the various requirements laid out by the DoD to keep their information safe and secure. The CMMC 2.0 requirements reduced the CMMC compliance levels from five to three. Those levels are:

• Level 1 (Foundational) - This level only applies to companies that are tasked with the protection of Federal Contract Information (FCI). It is a requirement that these companies keep contract and contractor information secured.
• Level 2 (Advanced) - This level of CMMC compliance refers to the level of security necessary for contractors that deal with Controlled Unclassified Information (CUI). It is important to note that with the new CMMC 2.0 requirements, the old requirements of CMMC 1.0 have been discarded and replaced with a full set of 110 security controls created by the National Institute of Technology and Standards to help protect CUI material.
• Level 3 (Expert) - This level is used by contractors and companies that deal with DoD's highest-priority CUI materials. Its purpose is to reduce the risks associated with Advanced Persistent Threats (APTs). The DoD is still working on finalizing some of the procedures that must be used at Level 3, but there are at least 130 security controls that must be followed at this level.

Knowing which level of CMMC compliance applies to your situation and what you can do to maintain contracts or gain new contracts with the Department of Defense. Establishing a complete CMMC compliance checklist is a great way to ensure that you have met all of the requirements of each level of CMMC compliance mentioned here.

When is CMMC Compliance Required?

There is a lengthy review process related to any changes that the DoD makes to CMMC compliance rules. The reason for this is to give all relevant parties the time that they may require to meet the new compliance standards. The Department of Defense notes that it has already released certain pieces of information about the relevant rules for CMMC 2.0. However, they also point out that the requirement to meet these new standards does not begin until the DoD has fully completed the rulemaking process for these new regulations. That can take up to 24 months to finalize, and that is the kind of timeline that the Department is looking at right now.

Contractors can already obtain certain pieces of information about what the CMMC 2.0 requirements are going to look like. Those who want to stay ahead of the curve and maintain their contracts should try to stay ahead of the CMMC 20 timeline. In other words, those contractors should make efforts now to get themselves set up and ready to comply with the new standards as those new standards are released. Waiting until the last moment and trying to comply with everything only after the rulemaking process is complete is not the way to go.

Is CMMC Compliance Mandatory?

The Department of Defense has plenty of contractors who would be more than happy to work with them. The Department has its pick of the crop so to speak, and there is no reason at all why they would ever choose to partner with a contractor that refuses or neglects to comply with their standards. Therefore, CMMC compliance is mandatory.

The CMMC compliance requirements impact more than 300,000 individual businesses and contractors. Most of those companies and contractors will only need to meet a relatively low level of compliance to continue to do business with the DoD, but it is still important to do so. Any company or individual contractor found to be out of compliance with the CMMC requirements risks getting eliminated from current and future contracts with the Department. The Federal Government simply cannot run the risk of working with companies or contractors that do not take the security of their information extremely seriously. Therefore, every contractor and business with contracts with the DoD should consider CMMC compliance mandatory.

What is the CMMC Compliance for Defense Contractors?

Defense contractors are some of the most obviously impacted by CMMC requirements. These contractors work directly with the Department of Defense, and their entire business relies heavily upon the contracts that they establish with the DoD. Therefore, it is abundantly clear that every defense contractor must take the process of becoming CMMC compliant extremely seriously. Failure to get the proper level of CMMC compliance is simply unacceptable when it comes to defense contractors.

A few things that defense contractors should know about the latest CMMC requirements include:

• Organizations Must Make Their Network Compliant - It is necessary for any organization (including defense contractors) that wishes to do business with the DoD to make their network compliant with the latest CMMC standards. At a bare minimum, the organization must make the parts of its network that deal with sensitive material compliant with the latest CMMC standards. In most cases, it is easiest for those organizations to make their entire network compliant with these regulations.
• DoD Solicitations Now Include CMMC Requirement Information - As of 2020, DoD solicitations for contracts include information about the latest CMMC requirements and how organizations can meet the standards laid out within these regulations. That is a big deal because it completely lays out the requirements that a defense contractor must meet to even be considered for the DoD project. No one can claim that they didn't know what they needed to do to gain access to the project.
• Third-Party Assessments Might Be Necessary - It will be increasingly difficult for defense contractors to obtain contracts with the DoD without a certified third-party assessor reviewing their commitment to compliance. The assessor can verify that the contractor that it has reviewed has met all of the necessary CMMC compliance requirements to satisfy the demands of the Department of Defense.

Can You Self-Certify CMMC?

Organizations can self-certify their CMMC requirements up to a certain level. They are able to do so up to the Level 1 of compliance. Organizations and individual contractors that require a higher level of compliance than that will need to seek the services of a third-party assessor. However, many organizations and individual contractors only require the bare minimum level of CMMC security requirements for the work that they do. As such, it is entirely possible that many organizations may opt to self-certify to take care of their basic security requirements.

What is CMMC vs NIST?

The main difference between CMMC requirements and NIST requirements comes down to what type of data the organization is dealing with. CMMC requirements are for those who are dealing with public information such as the kind of data that the government stores. NIST requirements are for organizations and individual contractors who deal with private data and information.

Both sets of standards are designed to keep sensitive information from falling into the wrong hands. There are plenty of cyber criminals out there who might be more than happy to snap up information that they have no right to view if they can possibly do so. As such, it is nice to know that there are serious standards established for both types of data.

How Trava Can Assist You With Your Regulatory Journey

There is no question that obtaining the proper security clearances necessary to get contracts with the DoD is a burden. However, it is a necessary burden because those contracts are so valuable and so important to the work of many organizations. That is why Trava is so dedicated to helping clients work through the process of obtaining the necessary CMMC compliance to continue to do business with the Department. When you partner with us, you can rest assured that we will guide you through what might otherwise be an extremely challenging process. If you are committed to obtaining the contracts that you deserve and that you need to sustain your business, then you need to reach out to our team today to get the assistance you require to meet every CMMC requirement that is relevant to your organization's business.