When it comes to safeguarding critical information across its critical infrastructures and supply chain, the United States Department of Defense (DoD) is known to leave no stone unturned. The agency’s commitment to upholding integrity in handling sensitive information was evidenced by the release of the Cybersecurity Maturity Model Certification (CMMC) Final Rule.  

On October 15, 2024, the DoD published the Final Rule for the new CMMC framework after months of anxious wait. This move will see mandatory CMMC compliance for Defense Industrial Base (DIB) companies, including prime contractors and subcontractors.  

The new CMMC framework took effect sixty days after the publication of the Final Rule, a relatively limited window for DIB companies seeking compliance. But with the clock fast ticking, defense contractors must move swiftly to satisfy CMMC’s requirements or risk losing out on lucrative tenders (among other privileges).  

Fortunately, the CMMC compliance process can be straightforward if you tag professional assistance.  

This post unpacks a step-by-step guide on how to fulfill the protocols in the new CMMC framework. 

What Are The Perks Of CMMC Compliance?  

Complying with the DoD’s CMMC framework provides immense benefits to both the federal agency and its contractors. By appreciating the significance of adhering to relevant cybersecurity protocols, an Organization Seeking Assessment (OSA) can undertake a robust CMMC assessment from a point of knowledge.  

Notably, CMMC fosters proper handling of sensitive federal information. The framework mostly seeks to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). More on CUI and FCI will be discussed in the subsequent section.  

Below are other core benefits of enforcing CMMC compliance:

1. Enhancing National Security

Without proper safeguards, sensitive defense information can easily slip into malicious hands. Unauthorized entities can use such information to access and expose highly confidential military secrets, potentially jeopardizing national security. 

2. Qualifying Defense Tenders

Fulfilling all relevant controls in the new CMMC framework will now be a critical eligibility criterion for prospective defense suppliers. While sifting through volumes of bidders, the DoD will instantly disqualify companies that do not submit satisfactory proof of compliance. 

3. Establishing Regulatory Standards

Standardization isn’t only limited to the manufacturing industry. The concept applies to national security, too. By imposing mandatory CMMC compliance, the DoD can level the playing field across its supply chain network. 

4. Fostering Cybersecurity Accountability

Besides the economic and logistical benefits, CMMC compliance also encourages cybersecurity accountability. Routine audits can help OSAs learn more about their cyber hygiene. It provides a proactive approach to averting threats while encouraging individual companies to play a part in minimizing cyber-attacks in their supply chains. 

A Step-by-Step Guide to CMMC Cybersecurity Compliance

1. Review Your Company’s CMMC Compliance Requirements

While CMMC compliance is mandatory for all defense contractors, the requirements vary depending on the type of sensitive information a company handles. That brings us back to critical unclassified information and federal contract information. 

Both CUI and FCI denote information created by or handled on behalf of the US government, which requires proper safeguarding. The core difference is that FCI isn’t intended for public release, whereas CUI may be shared with the general public.  

Examples of critical unclassified information include; 

• Export control information 
• Financial data  
• Nuclear reactors 
• Agricultural information 

 Meanwhile, federal contract information mainly entails: 

• Layouts of military installations 
• Information about defense staffers, such as their residence or operational bases 
• Emails exchanged with the DoD 
• Performance reports 
• Organizational schedules 
• Proposal responses 
• Process documentation

2. Understand the CMMC Compliance Levels Applicable To You

Defense contractors are subjected to different CMMC compliance levels. Again, that depends on the type of information handled.  

Working with an independent cybersecurity professional can help determine the CMMC assessment most applicable to your business. Originally five, the new CMMC framework now has three maturity levels.  

They include; 

Level 1 (Foundational Level:  Self-Assessment) 

CMMC Level 1 is the easiest to comply with, as it doesn’t require third-party assessments. Instead, contractors only need to self-audit and confirm compliance with the 15 controls.  

Level 1 protocols target low-risk threats, such as firewalls and anti-virus software. The idea is to create a basic cybersecurity hygiene before implementing additional controls in the subsequent levels.  

However, vendors must perform annual self-assessments and affirm their strict adherence to all 15 controls. It’s also worth pointing out that Level 1 only emphasizes securing FCI data. 

Level 2 (Advanced Level: Self-Assessment and Third-Party Assessments) 

Level 2 is mostly designed for defense contractors that handle CUI data. Vendors seeking CMMC compliance under this level must implement 110 security controls defined in the National Institute of Standards and Technology (NIST) 800-171 standards.  

Level 2 focuses on more sophisticated threats, including phishing attacks. These standards seek to enforce stronger access control, enhanced data encryption, and efficient incident response.  

The DoD may occasionally require certain Level 2 contractors to make annual self-affirmations on their continued compliance with the 110 controls. However, as a general rule, vendors must perform triennial cybersecurity audits facilitated by a certified CMMC Third-Party Assessor Organization (C3PAO).  

All C3PAOs are authorized by the Cyber AB – CMMC’s official accreditation body.  

Level 3 (Expert: Government Assessment) 

CMMC Level 3 compliance is only required for defense contractors actively facing highly sophisticated cyber threats. It emphasizes maximum protection of sensitive CUI and FCI data, a breach of which could have devastating consequences on US national security.  

Level 3 incorporates all Level 2 controls plus additional requirements aligned with NIST SP 800-172.  

Most importantly, this level doesn’t require self-affirmation. All cybersecurity audits must be performed triennially by a government-appointed assessor.

3. Understand the Compliance Phases

While the new CMMC framework took effect on December 16, 2024, its full implementation will occur in various phases. Vendors must understand the CMMC rollout dates to keep up with compliance.  

The phases are as follows: 

Phase 1 

Phase 1 starts immediately. During this phase, the DoD will require prospective defense vendors to achieve Levels 1 and 2 compliance. 

Phase 2 

Phase 2 begins in December 2025. It will mark the introduction of the full Level 2 certification protocols, including the requirement for mandatory third-party audits. 

Phase 3 

The third phase in the CMMC compliance timeline will be rolled out in December 2026, after which vendors seeking Level 3 certification will need to undergo government-led cybersecurity audits. 

Phase 4 

The final phase in CMMC compliance will commence in December 2027. It shall mark the incorporation of language stipulating the relevant control measures for various CMMC Levels into defense contracts.

4. Conduct a Pre-Assessment

Pre-assessments are a critical part of achieving CMMC compliance. They’re essentially mock cybersecurity evaluations intended to simulate actual audits and can help check if your system aligns with the CMMC certification you seek.  

It’s important to schedule a pre-audit about two weeks prior to the actual evaluations. That window is long enough to address any vulnerabilities ahead of a more robust assessment yet short enough to ensure no significant threats emerge.  

You can conduct a mock audit internally or outsource C3PAOs. The latter option is preferable, as it guarantees more accurate and unbiased assessments.

5. Develop an SSP

A System Security Plan (SSP) is an essential document for defense contractors seeking CMMC compliance. It highlights all the security controls a company has implemented, focusing on those that align with CMMC.  

An SSP should include the following sections; 

• Introduction – An overview of the document’s purpose and assessment scope 
• System Overview – A highlight of the CUI and FCI assets targeted in the evaluation 
• System Boundaries – Defines the interconnection between the audited systems and external networks 
• Security Control Implementation – Details the security controls implemented by the vendor, including supporting tools, procedures, and technologies 
• Control Implementation Status – Specifies the extent to which each control is implemented 
• Control Responsibility – Indicates the individuals or teams responsible for implementing each control 
• Control Monitoring – Spells out the mechanisms to track the efficiency of each control 
• Incident Response and Reporting – Highlights the procedures for effective incident response, including contact information for responsible personnel 
• Continuous Monitoring – Details the mechanisms for assessing and resolving future threats 

Remember to update your SSP regularly, given emerging cybersecurity regulations and best practices. The document must align with your other cybersecurity templates, including the System Assessment Plan (SAP).

6. Schedule a Proper Assessment

As mentioned, you can self-assess and self-affirm your CMMC Level 1 compliance status. However, subsequent levels will require professional assistance.  

For Level 2 compliance, you’ll need to enlist the services of an accredited C3PAO. First, a C3PAO will review your organization’s cybersecurity documents, such as the SSP and SAP. This is a critical step in ensuring you understand your cybersecurity obligations.  

The agency will then scope your organization’s cybersecurity infrastructure to uncover threats and vulnerabilities. Finally, they’ll prepare an audit report indicating whether your business complies with CMMC’s controls applicable to the certification level you’re seeking.  

In the event of partial compliance, you may invoke a Plan of Action and Milestones (POA&M). POA&M is a CMMC provision that grants conditionally compliant vendors a reasonable grace period to address residual risks.  

Despite the outcome of the audits, a C3PAO will help you implement proper controls to protect your organization from cyber-attacks and ensure ongoing CMMC compliance.  

In the case of Level 3 assessment, OSAs will need to contact the DoD directly to have the agency appoint them an assessor.  

Accelerate CMMC Compliance with Professional Assistance 

Fulfilling CMMC requirements is mandatory for all DIB companies. Therefore, defense contractors must understand the CMMC standards relevant to their operations and pursue the necessary compliance.  

While DIBs can self-assess for CMMC Level 1, subsequent levels require the assistance of third-party auditors.  

It’s also important to emphasize the significance of keeping abreast of CMMC’s latest news. That way, you can capitalize on regulatory changes to maintain full compliance and gain a significant edge over fellow defense contractors.