Your Roadmap to CMMC Compliance
Cybersecurity Maturity Model Certification, or CMMC, compliance is necessary for all businesses, big or small, engaging with the Department of Defense (DoD). However, the actual manual is over a hundred pages long and not written to be consumer friendly. Cutting through the complex language and understanding what you need to do for your company and contracts can be overwhelming. We have put together an easy-to-understand roadmap to help you reach CMMC compliance going forward.
Understanding CMMC Compliance and Assessments
In order to maintain contracts with the DoD, companies need to meet CMMC compliance requirements. However, meeting the requirements of these assessments and audits is not always straightforward. Organizations need to understand how they work with the DoD, what data they possess, such as Federal Contract Information (FCI) versus Controlled Unclassified Information (CUI), where their current policies fall short, and what actions are needed to become compliant. Getting up to speed can generally be done in three phases:
Phase 1: The Readiness Assessment
With a focus on gap analysis, a third-party vendor can review your current approach to CMMC compliance. Your compliance partner will help you determine which of the three CMMC levels your business falls into. They include:
- Level 1 Foundational
- Requires annual self-assessments and proper cybersecurity practices
- Level 2 Advanced
- Requires companies to meet 110 controls from the NIST 800-171 and undergo tri-annual CMMC Third-Party Assessor Organization (C3PAO) audits or self-assessments
- Level 3 Expert
- Requires companies to meet assessment requirements still to be announced, and undergo government-run audits
By understanding your level, your partner can help determine what you need to do to become compliant going forward, while also identifying which current practices in your organization are working and which are not. Common areas that are assessed during this phase include:
- The responsibilities and roles of IT and management
- Access control
- Relationships with current vendors
- Business continuity plans
- Staff training measures
- Incident response policies
Phase 2: The Implementation
During the next phase, your CMMC partner will review the findings of the assessment with you. Gaps will be addressed and there will be an ongoing discussion about prioritizing implementations based on cost-effectiveness as well as control weight. A game plan will be created for moving forward and new policies and security measures will be implemented to get your organization up to speed with audit requirements depending on your business’s unique needs.
Many companies need to implement more advanced physical access controls, media protection processes, system boundaries, and employee cybersecurity and policy training.
Phase 3: The Policies and Documentation
Implementing the CMMC practices alone is not enough. Organizations need to back up their current and newest policies with written documentation. A comprehensive policy library will help to support CMMC controls while also providing evidence that your business has a strategy for meeting compliance requirements.
Documentation can include, but is not limited to:
- Network and system architecture, maintenance, integrity, and boundaries
- Data management
- Processes, policies, and procedures
- Personnel and access controls
- Strategies for employee training
- Cybersecurity risks and management
- Incident response plans
- Communications
- Artifacts, or evidence of adhering to audit requirements
Common Pitfalls and How To Avoid Them
There is no denying it: CMMC compliance is complex. It is easy for businesses to misunderstand a requirement or fail to adequately implement a process or control. Failure to implement, however, can be extremely costly and could cost you contracts. Common pitfalls you will want to be aware of and avoid include:
Not Meeting Basic Cybersecurity Controls
Companies often make the mistake of believing that because they have performed a self-attestation of NIST 800-171 implementation, they automatically meet most, if not all, CMMC 2.0 requirements. Businesses may also have been led to believe that their current approach to cybersecurity is enough. This is not always the case. Your CMMC partner should be able to identify the gaps in your current strategy and help you build a roadmap towards full implementation, up to and including C3PAO Level 2 assessment. Your partner should also alert you right away of any pressing disconnects between your cybersecurity policies and the standard requirements outlined within CMMC 2.0. Course correcting on these immediately is necessary.
Misunderstanding the Value of Expertise
Navigating the CMMC ecosystem can be overwhelming. It is not something any employee tasked with general IT oversight is able to tackle. Working with qualified professionals can help ensure your business has a strategy in place for CMMC preparation while taking a more guided approach to compliance.
Solely Relying on Internal Resources
Relying solely on your internal resources to minimize costs related to CMMC compliance, assessments, and audits can backfire. While it may save you money in the early days, it could prove to be extremely expensive in the long run, especially if your organization fails to obtain certification and loses the opportunity to bid on new contracts. Relying on unqualified and inexperienced assistance for CMMC preparation can be a very costly mistake.
CMMC compliance is not a one-and-done item on your checklist. The framework is something you will need to continuously uphold going forward, showing evidence throughout the one- or three-year cycle in order to maintain your contracts. Ongoing education and verification will help to ensure your business meets compliance today and with future revisions of CMMC. With the right strategy and Network Coverage as your compliance and cybersecurity partner, you can map a trajectory of successful CMMC certification.