Preparing for CMMC Compliance

A Practical Guide for Contractors

Posted by:

Tim Marley

Introduction

Compliance with the Cybersecurity Maturity Model Certification (CMMC) or “CMMC compliance”, is a critical requirement for contractors working with the Department of Defense (DoD). With the increasing threat of cyberattacks, the DoD has implemented CMMC to ensure that contractors and their supply chains meet stringent cybersecurity standards. Whether you’re a small business or a mid-tier contractor, understanding and preparing for CMMC compliance is essential for securing and maintaining DoD contracts.


In this post, we’ll explore what CMMC entails, focus on the two lower tiers of compliance (Level 1 and Level 2), and provide actionable steps to help your organization prepare for a successful CMMC audit. If you’re working for a contractor or trying to understand where your business fits into the CMMC landscape, this guide is for you.

Background

The CMMC compliance framework was created to enhance the cybersecurity posture of companies in the Defense Industrial Base (DIB), ensuring that DoD contractors meet rigorous security standards. It is designed to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) from cyber threats. With three levels of certification, CMMC ensures that contractors have the necessary security practices in place.

Level 1 (Foundational)

Focuses on basic cybersecurity practices. Ideal for contractors that only handle FCI.

Level 2 (Advanced)

Incorporates a higher set of practices, including many based on NIST SP 800-171. This level is for contractors dealing with CUI.

Contractors must demonstrate compliance with these levels to participate in DoD contracts. However, the path to compliance can be complex, especially for those new to cybersecurity standards or unsure of where they fit within the CMMC framework.

Threats & Risks

  • Non-Compliance with CMMC: Failure to achieve CMMC compliance can result in lost contracts, reputational damage, and potential legal consequences for DoD Contractors.
  • Non-compliance can also expose your organization to increased cybersecurity risks.
  • Inadequate Understanding of Requirements: Many DoD contractors struggle to fully understand which level of CMMC compliance they need to achieve, leading to either over-preparation or gaps in their audit readiness and security posture.

Prevention/Mitigation Strategies

  • Gap Analysis: Conduct a thorough gap analysis to compare your current cybersecurity practices against CMMC requirements. This helps identify areas where improvements are needed.
  • Prioritize Critical Controls: Focus on implementing the critical controls required for Level 1 or Level 2 compliance. For Level 1, this includes basic safeguarding of FCI, while Level 2 requires more advanced controls to protect CUI.
  • Documentation and Policy Development: Ensure that all cybersecurity practices related to CMMC compliance are well-documented, supporting your audit readiness efforts. This includes policies, procedures, and evidence of ongoing compliance efforts. Documentation is key during the audit process.
  • Training and Awareness: Invest in regular cybersecurity training for your team to ensure that everyone understands the importance of compliance and their role in maintaining it.

Actionable Recommendations

  • Start Early: Begin your CMMC compliance journey as early as possible. The sooner you identify and address gaps, the better prepared you will be for an audit.
  • Engage with Experts: Consider working with a cybersecurity consultant who specializes in CMMC readiness. They can provide guidance tailored to your specific needs and help you navigate the complexities of the framework.
  • Utilize Available Resources: Leverage tools and resources from the DoD and NIST, including templates, guides, and checklists, to assist with compliance.

Industry Insights

Backlog and Delays

“The Defense Department faces a huge backlog of third-party assessors seeking accreditation. Given its estimate that 76,598 companies will need such a third-party certification, it seems likely that many companies will not be able to obtain third-party certification within the three-year timetable for implementation specified in the proposed rule.”

Plan Of Action and Milestones (POAM)

“Under certain circumstances, the proposed rule permits contactors that are not yet fully compliant with existing requirements to submit a “Plan of Action and Milestones.” But contractors be warned: such a plan is not permitted for Level 1 self-assessments, and even at Levels 2 and 3, a minimum overall assessment score must be reached before a plan is allowed.”

False Claims Act

“The significance of these challenges cannot be overstated because the proposed rule requires a “senior official” of each company subject to the CMMC program to annually affirm compliance. For Levels 2 and 3, affirmation is further required after every assessment, as well as at closeout of a plan of action and milestones. Every affirmation will carry with it a degree of risk under the False Claims Act, with that statute’s treble damages constantly hovering over every defense contractor subject to a CMMC assessment as a condition for award.”

System Security Plan

“Obtaining a third-party certification of compliance may not necessarily provide a “safe harbor” because companies must continually remain compliant with the required cybersecurity standards. Companies that are subject to the DFARS cyber rule, then, should consider engaging a consultant to develop the System Security Plan they use to perform their NIST SP 800-171 self-assessment, even if it is unclear whether they will eventually be required to obtain a third-party certification.”1

Burdensome

“It’s going to be burdensome, and it’s still going to be for most organizations, overhead costs that they’re going to have to bear,” Schneider said. “Certainly the program office has talked about the fact that they anticipate that these costs will be rolled in to rates from vendors, but how much do you roll in on your rate versus your competitor, when many things end up being a lowest cost technically acceptable? That is a concern that I think everyone’s going to need to be paying attention to.”2

Deadlines

“So, DoD is, you know, their goal is to get this out in October. They’ve said that they intend to make this rule effective in fiscal 2025. That starts on October 1st of this [2024] year.”3

A Small Contractor’s Journey to CMMC Level 2 Compliance

Peerless Tech Solutions, a managed service provider and federal contractor, undertook a significant project in late 2019 to achieve Cybersecurity Maturity Model Certification (CMMC) compliance. With the CMMC framework becoming essential for maintaining DoD contracts, Peerless aimed to align its practices with the required standards, particularly at the higher maturity levels.

Initial Gap Analysis:

  • Conducted an internal review to identify existing cybersecurity practices and how they aligned with CMMC requirements.

Phased Implementation:

  • Focused on addressing critical gaps identified in the initial analysis.
  • Prioritized enhancements in both internal processes and external service offerings for government contractor clients.

Engagement with Stakeholders:

  • Collaborated closely with internal teams to educate them on CMMC requirements and the importance of compliance.
  • Worked with external vendors and partners to ensure all aspects of their operations were aligned with CMMC standards.

Key Metrics:

  • Achieved 77.7% compliance with CMMC Maturity Level 3 controls during the initial phases.
  • Developed a clear roadmap to achieve full compliance by the end of 2021.


Peerless Tech Solutions’ journey toward CMMC compliance highlights the importance of a structured approach to aligning with new regulatory standards. By starting with a comprehensive gap analysis and engaging in a phased implementation plan, they were able to make significant progress toward meeting the stringent requirements of CMMC. Their experience underscores the necessity of early preparation, continuous education, and collaboration with all stakeholders to achieve successful audit readiness.

For more details on Peerless Tech Solutions’ journey toward CMMC compliance, refer to the full case study in the ISACA Journal here.4

Future outlook

As the CMMC framework continues to evolve, contractors will need to stay informed about changes and updates. The DoD is expected to refine and expand CMMC requirements, making continuous compliance a necessity. Emerging threats, particularly in the areas of supply chain security and insider threats, will also drive the need for more robust cybersecurity practices.

Conclusion

CMMC compliance is more than a contractual obligation; it’s a vital part of securing your place in the defense supply chain. By focusing on CMMC compliance and audit readiness DoD contractors can not only meet the necessary requirements but also enhance their overall cybersecurity posture.

Start your compliance journey today by conducting a gap analysis, prioritizing critical controls, and engaging with experts who can guide you through the process. Remember, achieving CMMC compliance is a marathon, not a sprint—but with the right strategy, you can cross the finish line with confidence.

Next Steps

Don’t leave your CMMC compliance to chance. Contact Prism One today for a consultation on how we can help you achieve CMMC compliance and audit readiness, securing your future as a DoD contractor.

References
  1. https://www.nationaldefensemagazine.org/articles/2024/1/12/proposed-cmmc-rule-spells-out-liability-risks-for-noncompliance ↩︎
  2. https://federalnewsnetwork.com/cybersecurity/2024/05/cmmc-is-coming-but-concerns-for-small-businesses-persist-under-revamped-rule/ ↩︎
  3. https://federalnewsnetwork.com/cybersecurity/2024/03/contractors-make-the-case-for-flexibility-in-a-forthcoming-defense-department-cybersecurity-program/ ↩︎
  4. https://www.isaca.org/resources/isaca-journal/issues/2021/volume-3/a-journey-toward-cmmc-compliance ↩︎

Timothy J. Marley, CPA, CISSP, CISA, CISM, CIA, CDPSE

Founder and Principal Consultant, Prism One

Timothy J. Marley, founder and principal consultant of Prism One, is a seasoned cybersecurity executive with over two decades of experience in information technology, risk management, and compliance. Tim’s extensive expertise helps organizations navigate the complex landscape of cybersecurity and risk management.

Tim’s mission is to empower organizations to build resilient security postures in an ever-evolving threat environment. At Prism One, he continues to provide tailored, high-quality cybersecurity solutions to meet the unique needs of each client.

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