Is your organization prepared to satisfy the demanding cybersecurity requirements of the Department of Defense (DoD)?  

With cyberattacks on the rise by over 25% in the last few years and sensitive federal information more vulnerable than ever, the need to comply with Cybersecurity Maturity Model Certification (CMMC) is greater than ever. 

All of the standards in the CMMC framework have requirements that are aligned with NIST SP 800-171 and 800-172 for safeguarding Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). The CMMC architecture is designed to examine and promote cybersecurity practices at three distinct levels, each of which relies on the preceding to fight increasing threats. 

Level 1 focuses on basic cyber hygiene, and Level 2 introduces advanced security measures for organizations that handle CUI. At the highest level — Level 3 — proactive threat detection and mitigation strategies are involved. 

That said, the stakes are high as non-compliance results in the loss of contracts and reputation and leads to legal penalties. Thus, you first need to understand DoD’s technical requirements and then align them with your organizational needs. Doing so not only meets DoD’s mandates but you also build up defenses against sophisticated cyber threats. 

However, with three levels of certification and different ways to assess, how do you decide which approach is appropriate for your requirements? 

We have broken down the intricacies of CMMC assessments into actionable steps for you to grasp what you are contractually obligated to and evaluate your current cybersecurity readiness to ensure your readiness for compliance. 

Understanding CMMC Levels 

Before selecting an Assessment, familiarity with the CMMC framework is quintessential. The model comprises three CMMC levels, each tailored to address different cybersecurity needs and risks:

1. Level 1: Foundational

• Purpose: Addressable for contractors that handle Federal Contract Information (FCI). This level focuses on the basic safeguarding measures for general contractors to limit cybersecurity risks. 

• Requirements: The first level entails compliance with 17 basic security controls stated in FAR 52.204-21. These controls aim to build a basic layer of protection for FCI. 

• Key Practices: 

• Protect user accounts with strong password policies. 
• Preventing unauthorized access to physical devices by securing them. 
• Follow the principle of least privilege and limit access to sensitive data.

2. Level 2: Advanced

• Purpose: Level 2 provides risk mitigation based on the 110 controls defined in NIST SP 800-171 aimed at organizations with CUI. 

• Requirements: It helps fill the void between basic cyber hygiene and advanced -threat protection and encompasses measures to protect information against sophisticated attacks. 

• Key Practices: 

• Detecting anomalies through continuous system monitoring and logging.  
• Creation of incident response plans to minimize the damage caused by security breaches. 
• Restricting who can view or modify CUI by implementing access controls. 
• Disguise data from prying eyes in transit and at rest by encrypting it. 

3. Level 3: Expert

• Purpose: Level 3 is the pinnacle of CMMC compliance tailored for organizations dealing with very sensitive CUI. This level introduces advanced cybersecurity measures based on NIST SP 800-172 to combat high-level and persistent threats. 

• Requirements: In the cybersecurity realm, organizations must present proactive, adaptive strategies to ensure their systems are resilient against evolving threats.  

• Key Practices: 

• Advanced threat hunting to find and eliminate vulnerabilities and exploit them before they occur.  
• Robust encryption protocols to secure data integrity and confidentiality. 
• Enhanced network segmentation to isolate critical assets and prevent lateral movement by attackers. 
• Multi-factor authentication (MFA) to ensure only authorized personnel can access sensitive systems. 

The requirements get progressively more challenging at each level. So, moving through these levels strengthens organizations’ cybersecurity posture while meeting DoD’s requirements for protecting information deemed critical.  

The choice of the level at which data protection is taken is dependent upon the type of data being handled, contractual obligations and the extent to which the organization has reached overall cybersecurity maturity. 

Steps to Determine the Best CMMC Assessment 

1. Assess Your Contractual Obligations

The first step is to diligently read through all your DoD contractual obligations. This includes figuring out if your organization deals with Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), as well as the level of sensitivity of the information. The type of data you process decides the CMMC level required for compliance. 

Questions to Ask: 

• Does your contract specify a required CMMC level? 
• Are you handling CUI, and if so, what type and level of sensitivity does it involve? 
• What happens if you do not honor contractual obligations?

2. Evaluate Your Current Cybersecurity Posture

Perform a complete gap analysis by comparing your current cybersecurity practices to the real requirements of the CMMC level you intend to achieve. This will point out deficiencies in your cybersecurity structure and areas that need re-work.  

Tools for Gap Analysis: 

• CMMC Accreditation Body provided self-assessment checklists. 
• Automated compliance tools like RiskIQ or Exostar to help streamline evaluations.  
• Third-party cybersecurity firms conduct audits for an unbiased assessment. 

3. Understand Third-Party Assessment Requirements

All formal assessments must be conducted by CMMC Third Party Assessment Organizations (C3PAO) to obtain Level 2 and Level 3 certifications. These organizations are accredited by the CMMC Accreditation Body (CMMC-AB) and play a significant role in ensuring compliance.   

Key Considerations: 

• Check on the credentials and accreditation of the C3PAO. 
• Evaluate how the organization has handled businesses of your size and profile.  
• Try to evaluate how well they know your industry and the cybersecurity challenges associated with it.

4. Knowing Your Timeline for Compliance

Due to contractual deadlines and the complexity of implementing required controls, the timeline for implementation of CMMC compliance can vary. Furthermore, there are specific deadlines within the contracts for certification, and not meeting these means penalties and loss of business opportunities. 

Therefore, to know your timeline for compliance, you need to find answers to these questions: 

• When does your current contract need to be CMMC compliant? 
• What are the penalties associated with being late to achieve certification? 
• During a pre-assessment phase, how long will it take to close identified gaps?

5. Choose Between Self-Assessments and Formal Assessments

Organizations pursuing Level 1 certification can do self-assessment, whereas Levels 2 and 3 require formal assessment by accredited C3PAOs. 

Benefits of Self-Assessment: 

• Less resource intensive and cost effective. 
• Great for small businesses or as prep for higher-level certificates. 

Benefits of Formal Assessment: 

• Provides independent validation of compliance. 
• Needed to meet Level 2 and Level 3 contractual obligations. 
• Increases credibility with clients and partners.

6. Consider Your Organization’s Resources

The degree to which CMMC compliance can be achieved is contingent on an organization’s size, structure and existing cybersecurity capabilities. 

Small Organizations: 

• May require external consultants to address knowledge gaps. 
• Can benefit from simpler compliance tools tailored for small businesses. 

Large Organizations: 

• Often have IT and cybersecurity teams of their own. 
• Need comprehensive assessments that look at a myriad of departments and locations. 

With a plan to follow the steps outlined above, organizations can traverse CMMC certification by satisfying compliance requirements and abiding by long-term cybersecurity goals. 

Preparing for a CMMC Assessment 

To achieve CMMC compliance, careful preparation is necessary making the assessment successful and seamless. Thus, proactive steps must be taken by organizations to fill security gaps, align processes and build robust security frameworks.

1. Develop a System Security Plan (SSP)

The cornerstone of your CMMC assessment is a System security plan (SSP). It describes the whole security landscape of your organization, clarifies its cybersecurity policy, and gives details on controls that are in place. 

Key Components of an SSP: 

• Detailed description of the hardware, software, and network configurations used in your IT environment. 
• Description of the security controls put in place to protect FCI and CUI. 
• Detailed procedures for incident detection, response, and recovery. 
• Explanation of risk management strategies to counter vulnerabilities and threats.

2. Conduct a Pre-Assessment

A pre-assessment helps you determine weak points in your cybersecurity posture prior to going through the formal CMMC evaluation process. Thus, with this proactive approach, you can remedy deficiencies and boost your defense mechanism. 

Options for Pre-Assessments: 

• IT or compliance team annual internal audits. 
• Experienced consultants providing third-party readiness assessments. 
• Benchmarking your readiness with the CMMC Assessment Guide. 

Which option you choose among these depends on your cybersecurity requirements and preferences. Thus, thoroughly analyze all these options and choose the one that best meets your needs. 

3. Implement Required Controls

Based on the findings from your pre-assessment, you need to complete the implementation of potential security controls to attain your desired CMMC level. Moreover, these controls should be tested thoroughly to ensure they operate and control risks significantly. 

4. Train Your Staff

Since cybersecurity is a shared responsibility, employee awareness about cybersecurity is instrumental in adhering to CMMC compliance. Thus, you must train your team on CMMC policies, procedures, and best practices. This, as a result, will help you secure the new culture of the team. 

Key Training Topics: 

• Phishing attacks: How to recognize and respond to them? 
• Sensitive Data: How to properly handle and store it?  
• Security Breach: Ways to share security incidents promptly and effectively. 

If all of these areas are addressed, your organization will position itself well for the formal CMMC assessment prior to achieving certification efficiently. 

Get CMMC Compliant with Ease  

To select the most appropriate CMMC assessment for yourself, you should know what the CMMC framework is and how your cybersecurity posture is measured, and you should match it with contractual requirements. 

That said, a structured approach and utilizing the available resources can enable your organization to achieve compliance efficiently and effectively. Ultimately, it’s vital to note that CMMC certification is not about fulfilling DoD requirements but an investment in securing your organization against cyber threats and improving its overall resilience.