CMMC Compliance & Required Compliance Levels
In the past few years, the Department of Defence has been hard at work in setting up a robust cybersecurity maturity model process. It will ensure that every contractor for the Defense Industrial Base (DIB) can meet all the requirements to handle controlled unclassified information.
This process is known as Cybersecurity Maturity Model Certification (CMMC) and has gone through various evolutions since its introduction early last year. To this day, it is still evolving — its main purpose is to ensure that defense contractors are meeting cybersecurity hygiene. In this way, the most sensitive defense information can be protected and kept safe.
Cybersecurity Maturity Model Definition
As mentioned, the United States Department of Defense (DoD) has been preparing the CMMC for close to two years. Since the program’s announcement on January 31, 2020, the goal has always been to measure the readiness, capability, and how refined cybersecurity is with their defense contractors. On the higher levels, it provides a collection of frameworks, processes, as well as inputs from the existing cybersecurity standards seen in DFARS, FAR, and NIST.
When it comes to a tactical level, the main purpose behind getting a certification is to enhance the security maturity and data safety of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). These are both within the use and possession of their Federal contractors and therefore need an extra level of security. Everyone who supports the defense mission must understand how these changes will impact both operations and businesses.
How CMMC Impacts Your Business
For federal contractors who conduct business with the Department of Defense, CMMC is a new requirement that needs to be met. Because the DoD certification is estimated to come into effect within the next four years, there is still time for businesses to comply with the model and meet required maturity levels. This will ensure that every non-federal information system will meet DFARS requirements for storing and processing FCI and CUI.
A third-party auditor will be required by CMMC to certify DIB systems that work with FCI or CUI. As such, now is the time to take advantage of the managed service capabilities that Brightflow can provide. When planning your CMMC roadmap, be sure to consider Brightflow Technologies to help prepare your business for the Level 3 CMMC compliance audit.
Differences Between CUI & FCI
Both FCI and CUI are related kinds of government information, but it will help to understand what sets them apart when trying to get a CMMC. FCI generally refers to any information generated or given by a contractor associated with the delivery of a service or product as part of a contract. It does, however, include transactional information required for payment or details that the government may have released to the public.
Additionally, the Committee on National Security Systems Instruction (CNSSI) also specifies further details in FAR 4.1901. It states that “any representation or communication of knowledge such as data, facts or opinions in any form or medium, including numerical, textual, graphic, narrative, cartographic, or audiovisual” is included.
On the other hand, CUI is any kind of information that any government agency possesses or generates. As such, safeguards are required before a contractor can access it. This may take on different forms such as a regulation, law, policy, or permit. Furthermore, CUI can be categorized into two kinds, based on how strong the safeguards are needed to protect them, also known as CUI Basic and CUI Specified.
While CUI Basic still needs to be protected, the government doesn’t provide exact specifications on how to do this. In contrast, CUI Specified needs protection through specific safeguarding methods given by the government. Unless an executive agency generates, possesses, or uses them, neither kind of information can be given to a non-executive branch of the government.
Why is CMMC Being Implemented?
As hackers and inside threats become more complex and sophisticated, protecting information systems through cybersecurity maturity has become the top priority of national defense. Economic security has also moved forward, with a wide range of standards, frameworks, policies, and contractual requirements. As a result, accrediting all the various systems in place to store and process sensitive data isn’t something that we should take lightly.
The resources and time needed to complete the authorization and assessment process are generally measured in months, which decreases the need to deploy new solutions but increases the operational risks. This is just as true for non-federal and federal systems — this is why many companies in the DIB pour time and resources into making sure they are compliant with guidance from the DoD.
Unfortunately, this guidance can sometimes be vague and at times, disparate, which leads to inconsistent standards across the DIB. In the end, this results in decreased confidence and situational awareness when analyzing operational risks. Once these challenges were recognized, the need for a succinct approach made way to the development of the CMMC and the accreditation of non-federal information systems.
As of November 4, 2021, the Federal Register revoked the standards specified in the old CMMC guide. It used to implement five levels before it was cut by two levels, and now only uses three levels. Version 2.0 of the CMMC guide has implemented the following changes:
The Elimination of CMMC Level 2 and 4
Unfortunately, CMMC level 2 was never helpful, to begin with; the DoD has stated in public that they didn’t see a reason why level 2 was ever required on a contract. In this new CMMC version, the removal of levels 2 and 4 can provide a clearer and more streamlined process while removing unnecessary parts.
The Removal of All Maturity Processes
The first version of the CMMC certification guide required the implementation of Maturity Processes which only led to more effort being exerted by businesses. However, they didn’t have to do this — in the first year after its release, the DoD failed to provide an example of a passing maturity procedure, plan, or policy. Because these processes were poorly defined, it became the #1 reason why C3PAOs failed their CMMC level assessment.
As a result, the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) required step-by-step procedures for every Assessment Objective in the CMMC Assessment Guide. Unfortunately, when a company that’s supposed to be fully prepared such as C3PAOs can’t pass their CMMC assessment due to a lack of process maturity, then defense contractors won’t stand much of a chance.
Getting Rid of Practices Unique to CMMC
Making this change only requires the controls in NIST SP 800-171 for CMMC Level 3 certification. This means great news since it aligns CMMC assessment with other regulations that require 800-171 controls and provides insight into what is expected.
One such example from the Federal level is a notice from the Information Security Oversight Office (ISOO). In it, is an explanation that only NIST SP 800-171A should be used when assessing non-federal organizations holding CUI.
CMMC Level 5 is Still Being Developed
Currently, CMMC Level 5 certification is still in its infancy, with plenty of areas for development. Unfortunately, this means that it won’t be enforced any time soon. The lack of training, the lack of assessors, and even the assessment criteria itself mean that we won’t be experiencing Level 5 certification soon.
On the bright side, there have been talks that DIBCAC will be focusing on the assessments for CMMC Level 5 as a result of their prioritization of contracts. According to other news releases, this seems to be working out as planned, so we may get to see the formation of CMMC Level 5 certification sooner than we thought.
CMMC Compliance with Brightflow Technologies
The DoD will provide the specified levels required for the certification in Requests for Proposals (RFPs) and Requests for Information (RFIs) provided to contractors. Most, if not all businesses will want to become certified for either Level 1 or Level 3 compliance to satisfy most of these authorized requirements. In the next few years, every organization will want to bid for services within the DIB ecosystem as the new framework becomes fully developed and adopted.
When this happens, you will need to be CMMC certified within the suitable level to get access to the services they offer. Each certification will be expected to remain valid for three years before the need for a reassessment. This is where Brightflow comes in — we assist businesses to achieve their desired CMMC compliance, specializing in Level 3 compliance. Here is how we can help:
- We have Registered Practitioners that will assess your company’s readiness for the CMMC Level 3 audit
- We provide extensive knowledge and experience of DoD processes under the CMMC to deliver phased, tailored, and proactive solutions to keep clients aligned with today’s CMMC security controls and compliance
- Our team can build and implement a path to level 3 CMMC Compliance
- We can correct any vulnerabilities found by our Registered Practitioners prior to the CMMC audit
- We are ready to establish documentation and implement CMMC compliance levels 1 – 3 and cybersecurity strategies so that your company will be audit-ready
What Does the Required CMMC Level 3 Maturity Model Certification Mean?
Your CMMC certification level is important and goes hand-in-hand with your cyber hygiene level. As mentioned above, in order to meet the requirements for a level 3 certification, your company will need a well-designed cybersecurity program, even if it is just starting. You don’t just need to establish and maintain a plan, but you also need to show that you can manage your cybersecurity. Furthermore, you will need to provide all the resources needed to implement your plan as well as any associated activities.
There are a few elements you will need to consider for this security certification, which includes the following:
- Project plans
- Communication with internal stakeholders
Moreover, level 3 security certification is concentrated on the safety and protection of CUI, encompassing each and every security requirement as specified in NIST SP 800-171. It also involves another 20 different practices that will help to mitigate various threats.
In addition, contractors with a DFARS clause inside their contract will be required to pass level 3 security requirements at the very least. You should also keep in mind that DFARS clause 252.204-7012 will apply, and will specify more conditions to be met apart from the security requirements listed in NIST SP 800-171 such as reporting incidents.
Are You a C3PAO Looking for a Registered Practitioner?
BrightFlowcan help to prepare your organization prepare for certification through our Registered Practitioners. Our security team will review your company’s infrastructure and policies to help you prepare for any audits. We’ll also highlight any security vulnerabilities that are currently in your cybersecurity strategy that could potentially lead to a failed audit.
While only the “prime” DoD contractors are needed to implement CMMC, it’s only a matter of time before everyone in the whole DIB will be required to have CMMC certification. By picking the right registered practitioner, you’ll get one step ahead of everyone, and you can get started with implementations much quicker. With BrightFlow, you can take advantage of our industry experience and make sure that you pass your CMMC assessment without any bumps in the road.
If you’re looking for more details on CMMC, get in contact with Brightflow today to schedule your free certification consultation. Our dedicated team can also take you step-by-step through the CMMC, so you can easily keep your status as a contractor for the DoD.
Cybersecurity for Your Business
Business data, whether within the government or not, is now more valuable than ever before. This is why cybersecurity is a necessity for any business to operate efficiently and is also vital when it comes to guarding your clients’ information. CMMC goes beyond following the usual best practices in IT or the latest technology available in your company — it focuses on staying ahead of the disasters and threats that have the potential to bring everything in your company crashing down.
Brightflow protects your company from a plethora of cybersecurity threats in various ways, such as:
- Sharing our wealth of knowledge regarding how you can keep information protected
- Providing you with a comprehensive assessment of how prepared your company is for the audit
- Providing feedback on weak areas to strengthen your system
- Help implement cybersecurity strategies that will help your company become ready for audits
We also advise that using a layered security model will be much better in the long run when creating your cyber security procedures. This effective model gets everyone involved — starting from the internet and ending with your employees. You can count on us to guide you and to determine just how well the IT security protocols are working in your company.
Let BrightFlowSet You on the Path to CMMC Compliance
Brightflow Technologies is the top choice for companies who wish to prepare for any level of compliance. Being ready for CMMC is a must for any company that provides services for the DoD. By using industry-leading solutions as well as the latest automation technology, Brightflow can help your organization. Together, we can realize just how efficient multi-cloud usage can be while staying compliant with the CMMC process.