The Importance of a Cyber Assessment
February 9, 2023How Do I Ensure My Business Is CMMC Compliant?
May 2, 2023The Defense Industrial Base (DIB) has seen a variety of changes during the past few years, and with digital threats more ominous than they have ever been in the past, it is critical for all organizations that use or have access to sensitive information to prioritize its security. That is where the Cybersecurity Maturity Model Certification, usually shortened to CMMC, is critical.
This is a program that has been specifically designed to enforce the protection of sensitive and controlled unclassified information that the Department of Defense might share with its contractors and subcontractors. CMMC provides partners with a variety of rules and regulations that they need to follow to ensure CMMC compliance and proper security protocols.
With CMMC 2.0, CMMC certification is essential because it provides a clear process for how partners, contractors, and subcontractors should protect information that is exchanged between the Department of Defense and its various contractors and subcontractors. It is critical for your organization to make sure that it has a strong cybersecurity program in place to protect this type of information, as failure to do so helps our country’s adversaries and puts the men and women risking their lives to defend our freedom at greater risk.
Why Is CMMC Important?
There are a variety of reasons why CMMC is so important, but the biggest reason is that it has been specifically designed to protect information shared within the United States DIB and to protect the parts, components, and systems that are required for us to put forth a strong national defense.
CMMC will ensure that your cybersecurity plan involves continuous monitoring and upgrading to thwart anyone who might be acting with malicious intent. If you follow appropriate cybersecurity risk management protocols as spelled out by CMMC, you can validate the practices and safeguards that have been put in place to ensure that all companies meet the necessary cybersecurity requirements. It is particularly important for protecting controlled unclassified information (CUI) and federal contract information (FCI).
If you do not comply with CMMC, there are several negative consequences that you might experience. Some of the biggest examples include:
- You will not be permitted to bid on contracts, which means that you could end up losing revenue.
- You will be increasingly vulnerable to various cybersecurity threats. You could face significant malware attacks, including ransomware or fall victim to thieves stealing your money through business email compromise.
- You could also face massive fines through the Department of Justice’s Civil Cyber Fraud Initiative.
With the introduction of CMMC, the nature of the industry has changed significantly. While you previously had to follow the guidelines spelled out in DFARS 252.204-7012, there were no concrete consequences if you did not follow its rules. You had to know about the controls that were available, but you did not necessarily have to follow them.
Now, with CMMC, you must do everything necessary to protect confidential information. You will be assessed and audited prior to the contract being awarded, so you should ensure you are in proper compliance.
CMMC is a massive shift from how things were done in the past. It’s no longer a set of guidelines, it’s a set of rules that are necessary to follow if you want to bid on work. You can’t pick and choose which controls you comply with – you must follow all that are specified in your contract.
How Does CMMC Apply To My Business?
Even though CMMC has been specifically designed to apply to businesses that are directly related to the Department of Defense, its impacts expand far beyond prime contractors. Those prime contractors are required to flow down CMMC requirements to subcontractors that they work with, so the ripple effects of CMMC are significant.
Essentially, CMMC can apply to anyone producing products, designing products, or customizing products that are related to a project from the DoD, including numerous businesses throughout the manufacturing sector. By 2026, all contractors and subcontractors will have to comply with CMMC if they want to work on a project furnished by the DoD in any way. Ultimately, it will not matter what your industry is. If the product involves CUI or FCI, you must comply with CMMC if you want to work with the Department of Defense.
There are numerous categories of CUI that require CMMC certification. A few examples include:
- Critical Infrastructure
- Defense
- Export Control
- Financial
- Immigration
- Intelligence
- International Agreements
- Law Enforcement
- Legal
- Natural and Cultural Resources
- North Atlantic Treaty Organization (NATO)
- Nuclear
- Patent
- Privacy
- Procurement and Acquisition
- Proprietary Business Information
- Provisional
- Statistical
- Tax
- Transportation
If you work with CUI that falls under any of these categories, you will be required to adhere to all CMMC compliance measures if you want to participate in the project.
What Does the CMMC Process Look Like?
If you want to make sure that you are compliant with all rules and regulations put forth by CMMC, there are several steps you need to follow to conduct an assessment. They include:
- Prepare for the Assessment: You will need to request an assessment from a C3PAO, who will look at how your contractual arrangements will impact the nature of your cybersecurity measures. You will need to prepare some documents and templates related to the assessment and complete the pre-assessment planning process.
- Conduct the Assessment: Next, the C3PAO will conduct the assessment. They will collect and examine any evidence included in the test, analyze the results of your tests, score the results of those tests, and record their final findings.
- Report the Results: Once the C3PAO are finished with the assessment, they will need to report the recommended assessment results. They will submit, package, and archive all necessary assessment documentation, dispose of any assessment artifacts, and submit an appeal if necessary.
Completing this assessment process can take a long time, and you need to put yourself in the best position possible to be successful on the first attempt. That is why you need to partner with an expert who can work with you closely, identify potential vulnerabilities before the assessment, improve your cybersecurity measures, and ensure you pass the assessment and are ready to compete for future business contracts.
How To Get CMMC Accreditation
It can be a challenge to get CMMC accreditation, but this is not necessarily something that you need to go through on your own. For example, you can work with a Registered Provider Organization (RPO) who can help you decide which level you’re trying to achieve based on your business model, what you need to do to get there, and how you can streamline your daily operations to ensure you are compliant without slowing down your business.
In particular, your RPO can help you with scoping. This is the process of discriminating the strategy you will use to reach your compliance goals. There are numerous elements of your company that will need to be audited, and an RPO can help you determine which of these elements should be audited and how you can improve these elements individually.
Different Maturity Levels Apply To Different Projects
The procurement officer will seek out companies with various maturity levels for specific projects. The bar might be higher or lower for certain types of projects that are being released. The CMMC maturity levels include:
- Level 1: Perform Basic Cyber Hygiene: This level has 17 controls in place for protecting data. You will need to ensure that your network is private, implement individual user accounts, and use appropriately strong passwords.
- Level 2: Managing Good Cyber Hygiene: This level has 110 controls. While you will certainly need to follow the rules, you will also have to show that you are taking the necessary steps to implement certain requirements. You will need to have a policy available for each domain and you will need to document all of these policies accordingly.
- Level 3: Optimizing Advanced Cyber Hygiene: This level has additional controls, and it includes some additional attention and requirements related to continuous optimization. You will need to be proactive about certification maintenance to get to and stay at this level.
You need to work with an expert who can figure out which level is most appropriate for your needs.
Becoming CMMC Compliant With Gray Analytics
If you want to put your company in a position to bid for Department of Defense contracts, you will be required to comply with all CMMC certification measures. It can be difficult to understand each individual practice and what you need to do to pass your assessment, but this is not a problem that you need to address on your own.
At Gray Analytics, we have a significant amount of experience working with businesses of all backgrounds, and we can partner with you to figure out what you need to do to achieve the appropriate level for your needs. We have the necessary training, tools, and expertise, and we can customize your plan to meet your needs.
Contact us to speak to a member of our team, and learn more about how we can help you with all CMMC compliance issues.