On October 16, 2024, the United States Department of Defense (DoD) released its Final Rule for the new Cybersecurity Maturity Model Certification (CMMC) framework, known as CMMC 2.0.
The new CMMC program became operational sixty days after its initial publishing, signaling the DoD’s commitment to safeguard its vendor networks.
CMMC 2.0 highlights revised controls that Defense Industrial Base (DIB) companies must satisfy to attain CMMC certification. It’s a significant leap towards proofing the defense supply chain against unforeseen but potentially disruptive cyber-attacks.
As CMMC compliance will now be mandatory for DIBs, aspiring defense vendors must undertake rigorous assessments to bolster their cybersecurity posture. These audits are necessary for systems that handle Controlled Unclassified Information (CUI) or Federal Contract Information (FCI).
Expectedly, compliance with CMMC’s new rule updates comes at a cost. Certification fees can range from $3,000 to over $100,000, depending on multiple aspects.
Fortunately, DIBs can implement certain tactics to manage CMMC’s fees and accelerate the compliance certification process. Below, we explore those strategies.
The new CMMC framework features three levels, down from five. They include;
Level 1 is CMMC’s basic level, focusing on DIBs that handle FCI but not CUI.
It allows organizations to conduct annual self-assessments to ensure compliance with 17 Federal Acquisition Regulation (FAR) FAR 52.204-21 protocols.
CMMC’s Level 2 is mandatory for defense contractors handling CUI and FCI. It aligns with the National Institute of Standards and Technology (NIST) 800-171’s 110 security controls.
Unlike Level 1, which allows for self-assessment, Level 2 compliance audits must strictly be undertaken by accredited CMMC Third-Party Assessor Organizations (C3PAOs).
Level 3 is CMMC’s highest compliance level. It’s designed to safeguard the most sensitive defense information and avert emerging federal cyber threats. This cybersecurity maturity model includes all Level 2 requirements and additional controls.
To meet the stringent standards, a government-appointed agent must conduct all Level 3 CMMC compliance certifications.
Unfortunately, there’s no cut-and-dried answer to this question. CMMC certification fees vary depending on multiple factors, including a vendor’s size, required assessment scope, and current cybersecurity posture.
It’s also worth noting that CMMC certification costs broadly fall under the below categories;
CMMC preparation costs are expenses an organization seeking assessment (OSA) incurs while getting ready for CMMC evaluations. A common expense here is gap assessment, ranging from $15,000 to $35,000 for a 250-person company. There are also CUI scoping and risk assessments, which average 30,000 – $50,000.
Assessment costs go into funding actual CMMC audits. They vary significantly, depending on the assessment scope. For instance, Level 1 assessment may cost you a few hundred dollars if undertaken with your in-house IT team. Most Level 2 assessments start from around $30,000 for mid-sized firms, while Level 3 can cost up to $200,000.
These are expenses incurred implementing CMMC’s required security controls. Implementation costs are highly variable, ranging from $20,000 to $100,000. Actual expenses mainly depend on your existing cybersecurity position.
CMMC certification services don’t end upon the issuance of a compliance certificate. There’s ongoing maintenance to contend with, which also attracts fees. Maintenance costs range from $5,000 to $30,000 annually. Actual fees depend on the CMMC level, your organization’s size, and emerging cybersecurity threats.
Not every process in your organization’s cybersecurity ecosystem is worth auditing. While it’s recommended to undertake comprehensive evaluations annually, determining the best CMMC assessment depends on the actual systems that handle CUI or FCI.
A self-assessment spearheaded by your internal cybersecurity team can help uncover the processes directly impacted by CUI and FCI. You can then allocate resources that specifically target such tasks. However, remember that you can only self-assess for CMMC Level 1. An authorized CMMC third-party assessor organization must undertake Level 2 compliance audits.
Recent cyber-attacks targeting the Department of Defense mainly were vendor-focused breaches. This was a significant shift from tradition, where hackers previously waged direct attacks on the federal agency’s central information databases.
As a DoD contractor, it’s not enough to pursue compliance in your internal cybersecurity systems. You must ensure that your organization’s third-party vendors, particularly suppliers and contractors, are equally CMMC compliant.
You can implement several vendor risk management controls to foster compliance across your third-party vendors, such as signing contractual cybersecurity agreements. This reduces cyber threats along your supply chain, which could raise the CMMC compliance costs and impede the certification process.
Enlisting professional assistance may sound intimidating for DIB companies struggling with cash flow issues. However, certified assessors are your best bet when seeking CMMC certification services. They’re particularly recommended if you wish to lower the certification costs.
One way accredited CMMC third-party assessors save you money is that you only enlist their services on a need basis. Besides, these professionals are answerable to Cyber AB rather than the firms they actually audit. That means they’re more inclined to offer independent and verifiable audits than standard assessors.
A certified CMMC assessor isn’t driven purely by the bottom line. Instead, they discharge their mandate in strict adherence to the CMMC’s guidelines.
There may be costs involved in undertaking initial cybersecurity assessments in your organization. However, after preparing their preliminary reports, accredited C3PAOs will only charge for the actual systems subsequently audited.
However, proceed cautiously while looking for the best CMMC assessors.
A good place to kick-start your search is in the Cyber AB marketplace. Sample from several potential auditors and pick one with experience conducting multi-layered CMMC audits, including penetration testing and third-party risk assessments. The assessor should also be able to provide ongoing support to help you maintain compliance.
Since cost cutting is the principal idea, it’s also best to choose a C3PAO who’s transparent about their pricing and fees. This helps to avoid hidden or sporadic fees that may arise once the auditing project is underway.
CMMC audits can take anywhere from a few hours to several weeks, depending on the assessment scope. Having the process done manually can prolong it further and attract unnecessary expenses. A better alternative is to seek out an automated service.
Choose a software application that automates mundane tasks like data collection and retrieval. These programs can minimize the need to hire a large team of assessors, helping to manage the certification cost.
You may further cut back the CMMC certification expenses by integrating artificial intelligence (AI) into your operations. AI-driven programs can swiftly trawl your information systems for CUI and FCI data, eliminating most of the preliminary assessment costs.
CMMC auditors don’t work in isolation. Instead, a team of at least three personnel handles each project. Assessment teams typically comprise a lead assessor, a secondary assessor, and quality assurance personnel.
Since auditing your company’s cybersecurity maturity model is a joint effort, it’s best to collaborate with the assessment team on a dedicated platform. Consider a tool that streamlines all processes related to the project. Key considerations here include a navigable dashboard, centralized documentation, automated workflows, and real-time project monitoring.
An intuitive platform expedites the auditing process, ultimately reducing the assessment cost. Needless to mention, establish that your preferred assessor is familiar with (and approves of) the tool before engaging them.
There are tons of pre-filled CMMC compliance templates that you can leverage to save time and money. The policy documents cover the whole gamut of CMMC, from risk management to incident response, risk mitigation, audit & accountability, et cetera.
Carefully sample the templates and pick those relevant to your desired certification level. Using pre-made templates reduces the time required by independent assessors to document the audit reports, consequently saving you money. It also increases test accuracy by minimizing human errors and oversights.
Besides, the DoD has strict regulations mandating C3PAOs to compile CMMC audit reports in specific formats. Such formats are readily available in the various CMMC policy templates out there.
In addition to CMMC’s official premade documents, you can take advantage of templates prepared by former auditors and customize them to suit your organization’s needs.
One of the costliest CMMC auditing mistakes defense contractors make is signing up for CMMC assessments without a timeline in mind. There are two implications to that.
First, CMMC certification fees are typically proportional to the audit duration. Long-drawn assessments can be resource-intensive, wasting both your precious time and money. Besides, subjecting your organization to a prolonged CMMC assessment can reduce your operational efficiency by halting certain critical processes during the audit period. This could ultimately hurt the bottom line.
Therefore, be sure to define the CMMC audit timeframes before engaging a C3PAO. Implementing mitigation measures to maintain operational resilience is also prudent if the assessment takes longer than anticipated.
Attaining CMMC certification is now mandatory for all defense contractors, thanks to the DoD’s recently published final rule. The new requirement is part of the agency’s interventions to ward off emerging cybersecurity threats across its vendor supply chain.
While CMMC certification doesn’t come cheap, you can implement the above tips to manage the compliance costs. Remember that the key takeaway is to work with an authorized CMMC C3PAO. Ensure the assessor is listed on the Cyber AB website and enjoys an impressive cybersecurity auditing record.
More importantly, pick a CMMC evaluator who can customize their assessments to suit your organization’s budget and the intended assessment scope.
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