CMMC Readiness and Implementation

Controlled Unclassified Information (CUI) is sensitive data that needs protection but isn’t classified. This includes things like personal details (PII), proprietary business info, and other crucial government data. Keeping CUI safe is vital for national security and continued government operations. The Cybersecurity Maturity Model Certification (CMMC) helps organizations make sure they’re following the right cybersecurity practices to protect CUI from unauthorized access and breaches. 

The Cybersecurity Maturity Model Certification (CMMC) 2.0 framework is being rolled out gradually. There’s no single start date, but the Department of Defense (DoD) has been adding CMMC requirements to contracts since late 2021. The full implementation should be completed by 2025.  

The latest news regarding CMMC 2.0, can be found on the DoD’s website: https://dodcio.defense.gov/CMMC/About/  

It’s best to start working on compliance now to be ready for contract opportunities. Early preparation helps avoid last-minute stress and ensures you stay eligible for DoD contracts. Begin by evaluating your current cybersecurity practices, spotting any gaps, and putting the necessary controls in place to meet the required CMMC level. 

CMMC, DFARS, and ITAR all set rules for security and compliance for U.S. government contractors, but each has a different focus:

1. CMMC (Cybersecurity Maturity Model Certification):
   • Focuses on cybersecurity practices.
   • Applies to defense contractors handling Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
   • Ensures organizations meet specific cybersecurity maturity levels to protect sensitive data.
   • Requires compliance with NIST SP 800-171 standards for protecting CUI.
2. DFARS (Defense Federal Acquisition Regulation Supplement):
   • A set of regulations supplementing the Federal Acquisition Regulation (FAR) specific to defense contracts.
   • Includes clauses like DFARS 252.204-7012, which mandates safeguarding CUI and reporting cyber incidents.
   • Also requires compliance with NIST SP 800-171 standards for protecting CUI.
3. ITAR (International Traffic in Arms Regulations):
   • Governs the export and import of defense-related articles and services.
   • Ensures defense-related technology doesn’t fall into unauthorized hands.
   • Applies to any organization involved in manufacturing, exporting, or brokering defense articles and services.
   • Requires that protected data doesn’t leave the continental U.S. and is usually accessible only to U.S. persons.

Depending on your contracts and the information you handle, you might need to follow one or more of these frameworks. Knowing the differences helps ensure you stay compliant and secure.

You don’t strictly need a government cloud environment for CMMC compliance, but it is recommended to use a GCC High environment for CMMC Level 2 organizations, especially if you need to comply with ITAR. 

DoD contractors must ensure their cloud service provider meets the security requirements for handling CUI as outlined in CMMC. Many providers offer environments designed to comply with federal standards, making it easier to achieve and maintain CMMC certification. Make sure any cloud services used are set up and managed according to CMMC guidelines to protect sensitive data properly. 

Going it alone with CMMC compliance can be tough because the framework is complex and detailed. Without expert help, you might miss critical security controls, risking non-compliance and losing contracts. Professionals can thoroughly assess your current cybersecurity, find gaps, and efficiently implement necessary measures. They also assist with documentation, audits, and continuous monitoring, saving you time and resources while ensuring strong protection of CUI. Partnering with experienced professionals increases your chances of successfully achieving and maintaining CMMC compliance. 

When considering the ROI on your cybersecurity and compliance investment, it’s smarter to use a team with a proven success record rather than hiring full-time staff and buying costly solutions that might not work. 

DFARS Section 252.204-7012 (DFARS 7012) requires DoD contractors using external cloud service providers to store, process, or transmit CUI to ensure these providers meet FedRAMP Moderate baseline requirements. FedRAMP (Federal Risk and Authorization Management Program) ensures that cloud services used by the federal government have strong security measures. By complying with FedRAMP, contractors meet the strict cybersecurity standards outlined in DFARS 7012, protecting sensitive defense information. This regulation highlights the importance of using verified and secure cloud services to safeguard national security interests. 

While NIST SP 800-171 provides specific security controls for CUI protection, CMMC is a certification process evaluating the maturity level of an organization in meeting those requirements. CMMC also includes practices related to incident response planning, execution, and reporting. 

The differences among Microsoft Commercial, Government Community Cloud (GCC), and GCC High are as follows:

1. Commercial:
   • Meets FedRAMP Moderate criteria.
   • Uses the global Microsoft network, so data hosting locations and access by foreign nationals are unspecified.
2. GCC:
   • Similar to the Microsoft Commercial cloud but with specific identity measures and US hosting requirements.
   • Not adequate for ITAR because foreign nationals could have infrastructure access.
3. GCC High:
   • A separate cloud environment with US-based personnel and hosting.
   • Required for organizations with ITAR requirements.
   • Lacks some features of the commercial cloud.

For CMMC compliance, if you don’t have ITAR-related requirements, the Commercial or GCC versions may suffice. However, if you need to comply with ITAR, you must use GCC High.

To get CMMC certified, you need the following three things:

1. SPRS Score: Submit your Supplier Performance Risk System (SPRS) score, which reflects your compliance with NIST 800-171 requirements, to the Department of Defense.
2. SSP (System Security Plan): Develop and maintain a comprehensive System Security Plan (SSP) that outlines your current cybersecurity practices and how you address CMMC requirements.
3. Assessment Score: Undergo an assessment by a certified third-party assessor to evaluate your compliance with the CMMC requirements and achieve the necessary assessment score for certification.

These components ensure your organization’s readiness and compliance with CMMC standards.