Understanding CMMC Compliance for DoD Contractors
The Cybersecurity Maturity Model Certification (CMMC) is an important regulatory framework created by the U.S. Department of Defense (DoD) to help protect sensitive information in the defense supply chain.
As cyber threats become more sophisticated, CMMC compliance for DoD contractors is now a top priority. The DoD expects all contractors and subcontractors to demonstrate strong cybersecurity practices, ensure contractors utilize cybersecurity practices as part of the contract, continue to use them over the life of the contract, and ultimately pass third-party organizations’ (C3PAO) assessments, as applicable. CMMC compliance for DoD contractors will soon be a requirement, with the DoD’s guidance on those deadlines expected in 2025.
What Is CMMC 2.0 and Why Does It Matter?
CMMC 2.0, which was announced in 2021, also consolidates the five-level model into three levels; and further aligns the three levels associated with existing Federal security standards, including NIST SP 800-171 and NIST SP 800-172.
The objective of CMMC is to ensure that the defense contractor ecosystem, regardless of size, is meeting the necessary security requirements to protect both Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
Key Changes in CMMC 2.0
- Level 1: Focuses on basic FCI protection and requires annual self-assessment.
- Level 2: Demands compliance with all 110 controls of NIST SP 800-171, with third-party certification for most contracts.
- Level 3: Adds advanced controls from NIST SP 800-172 and requires government-led assessments.
Who Needs to Comply with CMMC?
If your company handles FCI or CUI, it needs to reach the appropriate CMMC level in the task agreement. This includes both prime contractors and subcontractors.
The defense industrial base is expansive, and even small suppliers have compliance obligations and cannot introduce risk to the supply chains.
Impact on DoD Contracts
If you cannot comply with the requisite CMMC requirement(s), you could potentially lose contract opportunities and face liability or litigation.
The DoD will communicate the requisite CMMC level in each Request for Proposal (RFP), and the prime vendor is responsible for ensuring that their subs are compliant as well.
CMMC Compliance Deadlines: The 2025 Rollout
As of late 2024, the DoD had released final rules on CMMC 2.0, which is to be rolled out in phases starting in 2025. Below is a brief overview of what contractors need to know:
Phase 1 (2025): New contracts will require either a Level 1 or Level 2 self-assessment.
Phase 2 (2026): More advanced contracts including Level 2 (and some Level 3) contracts will require a third-party certification.
Phase 3 (2027): Top-level devices in the certification will mitigate the standards as required for Level 2 certifications for contract renewals or contract extensions.
Phase 4 (2028+): All eligible DoD contacts.
What Next? Steps In Preparing for CMMC Compliance
1. Conduct a Gap Analysis
Begin with a NIST SP 800-171 self-assessment to determine gaps in your security posture and submit your score to the DoD’s Supplier Performance Risk System (SPRS).
2. Remediate Security Gaps
Produce a remediation plan detailing any controls that you may be missing. You may choose to pursue certification but must ensure some of the areas, specifically the higher levels must all be met before being able to contract.
3. Prepare Documentation
You will be required to maintain a System Security Plan (SSP) and if necessary a Plan of Action & Milestones (POA&M). There will be self-assessments and a third-party assessors that will be taking a very serious look at your documentation.
4. Schedule Assessments
- Level 1: Annual self-assessment and affirmation in SPRS.
- Level 2: Third-party assessment by a CMMC Third-Party Assessment Organization (C3PAO) or self-assessment if allowed.
- Level 3: Government-led assessment by the Defense Contract Management Agency (DCMA).
The Role of MSPs and IT Service Providers
Many small- and mid-sized contractors do not have the in-house talent pool to meet the capabilities of CMMC. Managed Service Providers (MSPs) and IT Service Providers have several ways to fill this gap for contractors by implementing and managing security controls, conducting a readiness assessments, policy and documentation, and on-going compliance maintenance.
- Implementing and managing security controls
- Conducting readiness assessments
- Assisting with policy and documentation
- Providing ongoing compliance maintenance
Partnering with experienced providers ensures continuous compliance and reduces the risk of non-conformance.
Staying Ahead: Best Practices for 2025 and Beyond
- Stay informed on CMMC updates and deadlines.
- Engage with qualified MSPs or consultants early.
- Regularly review and update your security practices.
- Ensure all subcontractors meet the required CMMC level.
Overall, CMMC compliance is now part and parcel to doing business with the DoD. If you are able to understand the requirements, can engage early, and utilize professional support, contractors will be able to future their role in the defense marketplace and properly safeguard sensitive matters related to national security.
Contact RCOR today and let our team help you on CMMC compliance journey. We can help navigate the landscape of CMMC requirements and you support with the assessments. Let RCOR do the heavy lifting so you can concentrate on building your business and securing your DoD contracts.