CMMC (Cybersecurity Maturity Model Certification) is a system of compliance levels that helps the government, specifically the Department of Defense, determine whether an organization has the security necessary to work with controlled or otherwise vulnerable data. Companies interested in working with the DoD must be CMMC compliance rated and follow specific CMMC regulations. Generally, this is done by building and following a CMMC compliance requirements framework and using CMMC best practices.
Let’s look at CMMC compliance, who needs it and where your organization might fall.
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WHAT IS CMMC COMPLIANCE?
The CMMC, or Cybersecurity Maturity Model Certification, is a framework developed by the United States Department of Defense (DoD) to enhance the cybersecurity practices and controls of organizations within the defense industrial base (DIB). The DIB includes a vast network of contractors, suppliers and service providers that work with the DoD and handle sensitive information, making them potential targets for cyberattacks.
The CMMC ensures that contractors and suppliers protect sensitive information and maintain a strong cybersecurity posture. It builds upon existing standards and practices, such as NIST SP 800-171 and NIST SP 800-53, and introduces a tiered certification model with three cybersecurity compliance maturity levels.
From 2019 to 2021, CMCC compliance requirements had five tiers. In 2021, the CMMC 2.0 release greatly simplified requirements with the goal of:
- Protecting sensitive military intelligence
- Enforcing cybersecurity standards across the DIB
- Ensuring accountability with CMMC compliance
- Creating better collaboration between vendors and the government
- Maintaining public trust
Organizations must consult the existing framework and documents to determine where a company falls within CMMC compliance requirements. It can be an extensive process; many organizations need the help of an expert partner to discover where they are on the CMMC security levels and whether there are gaps in their system or improvements they can make.
At its core, CMMC compliance requirements determine how mature an organization’s cybersecurity initiatives are. This evaluation includes whether the organization can maintain its security and improve by making it more efficient and better optimized. It also includes whether an organization is proactively or reactively manage its security and how rigorous its security measures are.
WHAT IS CMMC CERTIFICATION? WHO NEEDS IT?
CMMC certification is required for organizations operating with DoD information. If the organization operates with non-classified DoD information, it may only need a Level 1 clearance or below. If the organization is operating with high-value information, it will likely need a clearance of Level 2 or higher. However, classifications requirements are established by the government project itself.
WHAT ARE CMMC SECURITY CERTIFICATION LEVELS?
Initially, there were five total levels of CMMC certification, with Level 1 as the most basic and Level 5 being the highest. As part of CMMC 2.0, these levels have been reworked, and there are 3 current levels of CMMC certification for any business that looks to work as a federal contractor to achieve.
Level 1 – Foundational is what most companies should already have achieved; this includes basic security systems, password hygiene and antivirus protection software. There are 17 CMMC compliance requirements at this level, making Level 1 the most foundational form of security. At this level, organizations can self-report annually on their CMMC compliance.
Level 1 CMMC certification is generally for DoD vendors that handle Federal Contract Information. These vendors are external to the generally accepted critical government infrastructure.
Level 2 – Advanced builds from Level 1. There are 110 CMMC compliance requirements at this level. This level focuses on physical access control, cybersecurity incident response, risk management and system integrity.
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Level 2 CMMC certification is for vendors handling Controlled Unclassified Information (CUI). Organizations accepted into the Level 2 CMMC security framework are considered part of the critical infrastructure for government IT operations.
Level 3 Expert CMMC certification is the highest level and includes proactive methods to detect and mitigate threats before they begin, as well as systems and processes in place to audit infrastructure, identify gaps and fix them. Level 3 CMMC compliance requires rigor around sophisticated detection and mitigation abilities. There are also system hardening requirements.
Levels under the CMMC build upon each other. So, Level 3 companies will fulfill Level 3, Level 2 and Level 1 requirements. Organizations seeking Level 3 CMMC compliance are assessed by the government’s Defense Contract Management Agency.
Whether they work with the government or not, most organizations should strive for at least Level 2 compliance because this makes for a much more secure business overall. They can get help through an audit from a managed services provider. Following CMMC compliance requirements is a solid approach for applying data protection strategies to handle increasingly complex and aggressive cybersecurity threats.
WHAT ARE THE CMMC COMPLIANCE REQUIREMENTS?
The CMMC compliance requirements are heavily based around the NIST (National Institute of Standards and Technology), specifically, its SP 800-171 set of guidelines, which governs everything from section 3.5, Identification and Authentication, to chapter 3.10, Physical Protection, and much more.
To summarize the requirements:
- Level 1 CMMC compliance requires meeting 15 requirements in SP 800-171
- Level 2 requires meeting 110 requirements as determined by a third-party assessment (and Level 1 requirements)
- Level 3 requires exceeding 110 SP 800-171 requirements as determined by a government-led assessment, as well as meeting Level 1 and 2 CMMC compliance requirements
For DoD contractors, there are several general steps necessary to achieve compliance. Here are a few of the rigorous requirements.
CMMC Level 1
Create and maintain:
- An incident response document and process
- A vulnerability management document and process
- A patch management system
- Access controls to IT systems and data
- Physical controls for these systems
- Secure communications
- And more
CMMC Level 2
Monitor and control:
- System vulnerabilities
- Attempts to gain unauthorized access to systems and data
- Communications at the applications, network and system layers
- Cybersecurity training for end-users with access to these systems
- IT systems even during acquisition, development and maintenance
- And more
CMMC Level 3
Implement and maintain:
- Company-wide up-to-date cybersecurity protocols
- Identity and access for devices, systems, and end-users
- An effective detection and mitigation program
- Continuous monitoring of all digital systems and data
- And more
WHAT IS CMMC CERTIFICATION? HOW DO YOU GET IT?
How does you get CMMC certification for an organization?
Generally, there are seven critical steps for beginning the process of CMMC certification:
- Select the CMMC level you’re applying for
- Identify current assets affected by CMMC requirements
- Identify additional IT resources necessary to achieve your desired level of compliance
- Select a technical design for your CMMC cybersecurity architecture
- Find a managed service provider able to conduct a CMMC audit
- Prepare the necessary documents for CMMC
- Complete and submit the CMMC assessment
Companies are not allowed to self-certify for CMMC at the highest levels. Instead, government contractors and those working with government entities must undergo a third-party certification process. The unbiased third party audits a company’s current security measures and methods and identify what level of maturity and preparedness they meet.
Because CMMC certification cannot be self-certified and requires a third-party analysis, most companies will undergo a thorough audit before they attempt to certify. A managed services provider called a C3PAO, can help a company go through the CMMC framework, determine whether cybersecurity improvements could occur and organize the certification process itself. Once the certification process is complete, a managed services provider can also create a game plan for improving the level of certification – if needed.
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As requirements have recently changed, CMMC certification is one of the most popular types of security certification for a company to pursue. With CMMC certification, a company can pursue government contracts and deal with privileged information.
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WHAT IS A C3PAO AND WHY DO I NEED ONE FOR CMMC COMPLIANCE?
A C3PAO, or Certified Third-Party Assessment Organization, is an independent entity authorized and certified by the Cybersecurity Maturity Model Certification Accreditation Body (CMMC-AB) to conduct assessments and audits of organizations seeking CMMC compliance. C3PAOs play a crucial role in the CMMC framework, as they evaluate the cybersecurity practices and controls of defense contractors and suppliers within the defense industrial base (DIB).
The main responsibilities of C3PAOs include:
- Conducting CMMC Assessments: C3PAOs perform assessments and audits of organizations to determine their compliance with CMMC requirements. They evaluate an organization’s cybersecurity practices, controls, and maturity level to ensure they meet the specific CMMC level required for their contracts.
- Providing CMMC Certification: Based on their assessments, C3PAOs issue certifications to organizations, confirming their level of CMMC compliance. This certification is important for organizations to bid on or participate in DoD contracts.
- Impartiality and Objectivity: The government requires C3PAOs to be independent and objective in their assessments, ensuring that the evaluation process is unbiased and accurate.
- Reporting and Documentation: C3PAOs generate assessment reports and documentation that outline an organization’s compliance status, any deficiencies found, and recommendations for improvement.
C3PAOs are instrumental in helping the DOD and the defense industry establish and maintain a strong cybersecurity posture. Their assessments assure the DoD and other government entities that organizations in the defense supply chain are implementing the necessary security controls to protect sensitive information and are following the guidelines outlined in the CMMC framework.
WHAT IF YOU DON’T WORK WITH THE GOVERNMENT?
If you’re interested in working with the government, your organization may still need CMMC compliance. CMMC compliance requirements will vary depending on the contract, with many projects requiring only Level 1 or Level 2 compliance. Other contracts require up to Level 3. And, understandably, the contracts that require higher CMMC certification levels are also the contracts that are most likely to be lucrative.
But not working with government or DoD contracts doesn’t necessarily mean you don’t need CMMC compliance. The basic principles of CMMC compliance relate to proactive and consistent security best practices. Every organization should be able to achieve CMMC compliance, if only for their own peace of mind.
ACHIEVE CMMC WITH RED RIVER
Are you interested in finding out whether your business meets CMMC compliance? Do you need some help with CMMC regulations or conducting a CMMC audit? Red River can help. Red River meets three critical qualifications for ensuring you meet or exceed current CMMC compliance requirements:
- Red River is a Level 3 CMMC compliant company
- We were recently awarded a 10-year, $13 billion contract with the DoD
- We are a C3PAO
Red River offers clients seeking CMMC four critical services:
- Auditing current security standards against your CMMC compliance goals
- Planning and roadmapping security improvements that eliminate infrastructure disruptions while achieving CMMC compliance requirements
- Implementing the cybersecurity changes to achieve and meet CMMC compliance deadlines
- Maintaining CMMC after you’ve achieved this milestone
Contact us today to find out more.
Q&A
Are there CMMC compliance deadlines?
CMMC depends on the bidding and contracting process. Generally, organizations should start their work toward CMMC compliance up to a year or more before submission. CMMC 2.0 has a phased rollout of these new requirements through October 2025. However, some DoD contractors require vendors to demonstrate their compliance with these new rules now. This reality means that if you are currently doing business with the federal government, the time to pursue CMMC 2.0 requirements is now.
Can I self-certify for CMMC Level 1? According to the Chief Information Officer of the U.S. Department of Defense, organizations can self-certify at this level. A subset of Level 2 also allows self-certification, but most Advanced and all Expert CMMC certifications require review and certification by government entities.
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