Guide to CMMC: The Cybersecurity Maturity Model Certification

Maturity Model: What is it?

It helps a business comprehend its potential to adapt and progress in a certain domain. The more mature a business is, the more adequate flexibility and adoption will be there. CCMC has categorized digital security requisites and procedures for easy processing. For different maturity stages, prerequisites are set differently. 

The model helps business ventures set security benchmarks at each maturity level. This streamlines everything and is of great help to keep security deployments well-aligned with organizational needs.

‍

What Is CMMC?

It is a globally recognized framework crafted specifically for US Defense contractors. CMMC brings together multiple standardized practices and requisitions that are crucial while measuring security-centered maturity. Its key focus is on the defense supply chain. 

CMMC (Cybersecurity Maturity Model Certification) was created by OUSD(A&S) and offered to the world as a fully consolidated standard for security for DoD contractors. It doesn’t talk about one concept or control requirements. Instead, it merges multiple concepts, e.g., NIST SP 800-171, NIST SP 800-53, ISO 27032, and ISO 27001, so that digital security is coordinated and detailed.

For a very long time, the defense’s supply-chain faced certain loopholes that were causing intentional and unintentional information leaks.

The Defense’s DIB (Industrial Base) realized the need for one standardized protocol to ensure that no government data is leaking on its proprietary networks. However, it was not easy because the security domain is changing at a rapid pace. Hence, the challenge was to make sure that the framework was upgraded, keeping the digital security changes in mind. 

CMMC addressed this issue very well as describes the standardized security implementation design, which is scalable and stays resilient even if digital vulnerabilities are developing. DIB is the mentor association for CMMC. 

‍

Why Is CMMC Important?

‍

Before CMMC, there was no standardized procedure to establish contractors' level of trustworthiness regarding cybersecurity. DoD contractors used to provide the inputs of self-verification and self-audits in their support. This lack of a standardized format for gauging DoD contractors was the key reason behind many successful data breaches and data loss.

The DFARS, publication by DoD, discussed the importance of adherence to NIST’s SP 800-171.

The launch of the CMMC assessment provides fully verified and standardized compliance for DoD contractors. It was easy to decide the maturity level of the contractors and decide whether they are worth trusting. 

CMMC framework is very useful to keep cyber vulnerabilities at bay as CMMC-compliant vendors are forced to adopt robust controls in the supply chain that eliminate the risks. 

It’s a highly viable solution to safeguard CUI existing in the DoD vendor’s network. 

As this certification comes with 3 years validity, DoD vendors have to remain mobile and stay updated with the industry’s standards concerning business/data security. This is a sign that the vendor is always using modern and recent digital security controls. 

‍

What Is The CMMC Framework?

Not a very old framework, CMMC came into being in 2020, and currently, its 1.0 version is active. It has the following components:

1. 17 CMMC Domains

As mentioned above, the CMMC is all about its domains. 14 of its domains come from NIST 800-171 & FIPS Publication 200. See the complete list here: 

1. Access Control
2. Physical Protection
3. Personal Security 
4. Identification & Authentication 
5. System & Information Integrity 
6. Recovery
7. Asset Mngt
8. Configuration Mngt 
9. Situational Awareness 
10. Maintenance
11. Awareness & Training
12. Security Assessment 
13. Incident Response 
14. Risk Mngt 
15. Audit & Accountability
16. Media Protection
17. System & Communications Protection 

2. 5 CMMC levels

CMMC considers 5 stages while analyzing the dependability of a vendor. It’s because of the fact that every level asks for different maturity levels. Let’s decode these CMMC levels next:

• Level 1 is performance-based and assesses the early level of security hygiene and dependability
• Level 2 is about documentation-based audits and examines the mid-level cybersecurity dependency
• Level 3 is fully-managed and signifies that the vendor adopts nice digital hygiene practices
• Level 4 is based on reviews and establishes the fact that the concerned vendor is highly proactive
• Level 5 is the last maturity level and assesses the most advanced cybersecurity controls

3. CMMC Requirements

Let’s understand what it takes to be CMMC Security certified at each level. 

NIST vs. CMMC

CMMC heavily relies on what NIST 800-171 controls. Hence, many think that being CMMC compliant means NIST compliant. However, this is not true, as CMMC and NIST are two different entities with some common grounds.

NIST is not a certification, whereas CMMC certainly is. NIST is a globally recognized quality standard. It speaks of quality enrichment and security maturity regarding processes and products.

CMMC’s core focus is on cybersecurity. Other processes and services are not under consideration in this credential. It was developed by DoD and is mainly related to the DoD contractors. So, if a contractor has to work with DoD, being CMMC certified is a must.

NIST is created by experts at National Institute Of Standards & Technology. It is not an organization-specific framework.

CMMC is not fully-dependent on NIST. While a vendor is moving from Level 3 to the upper levels, NIST comes into play. The considered control is NIST 800-171. Also, CMMC features some controls from CUI.

‍

Who Needs CMMC Certification?

The shortest answer will be – People in online rsecurity industry, especially contractors and sub-contractors. 

It’s a selection criterion for DoD when it’s selecting vendors to join its supply chain and deal with Controlled Unclassified Info (CUI) and Federal Contracting Info (FCI). 

Contractors from all the DIB categories have a chance to increase their market worth with this certificate. Other than this, CMMC compliance also enables subcontractors to build trust throughout the market. 

‍

CMMC Compliance - How To Get Certified?

The evaluation process and certificate are monitored by CMMC’s Accreditation Body, which is a non-profit entity. Starting from the training to the CMMC renewal, everything is handled by this body. 

Interested contractors can apply for the CMMC via this body only. Also, such contractors and businesses will look forward to taking the help of RPOs to demonstrate their readiness for CMMC. RPO (Registered Provider Organizations) will also help them with CMMS readiness. 

CMMC AB also looks after the training & accreditation of Certified Assessors (CAs) and C3PAOs (3rd party CAs). Both these professionals are crucial for CMMC audits/assessments. CAs conduct the fair/independent evaluation for the DIB contractors and share the final  report with C3PAOs.

C3PAOs then read the report and find out which all controls and requirements the contractor met. However, C3PAOs won’t make any suggestions for organizations/contractors. Its job is to perform only unbiased assessment. It generates the final assessment report of the contractor and forwards it to the CMMC - AB.

CMMC-AB, based on the recommendation of C3PAOs, awards the certification. Once earned, it remains valid for 3 years. Contractors have to reapply and go through re-assessment to be certified for the next 3 years.

CMMC - The 5-Level Process of Certification

• Level 1 

A DoD contractor becomes CMMC Level 1 certified when a fully independent assessor affirms that the concerned contractor/company is meeting all the L1 requirements. The adopted means by the assessors are multiple audits, demonstrations, and interviews.

At L1, there are 17 parameters deciding whether or not the organization is equipped enough to safeguard the information/data according to FCI.

• Level 2 

At L2, contractors have to prove that most recommended cybersecurity practices, according to NIST SP 800-171 Rev2 controls, are adopted. In total, there are 46 controls defined for this level. 

• Level 3

CMMC L3 arrives one all the prerequisites, explained in Levels 1, 2, and 3, are fully fulfilled. Here, the requirements are defined according to NIST 800-171. Alongside this, some are extracted from CUI.

The auditor collects proof of the presence of these practices’ adoption and documents them. CMMC assessment could be on a particular network or a system at a time.

• Level 4 

Almost all the leading and advanced cybersecurity practices are under consideration at L4. To pass this stage, contractors/organizations have to pass the audit for the implementation of 26 NIST SP 800-171 Rev B controls.

• Level 5 

L5 of CMMC certification is the final destination that asks vendors to adhere to the 171 practices combined. Both the CIS and NIST 800-171 controls decide these practices. As so many practices are there to achieve, this is the hardest level to earn.

‍

CMMC - The Advantages 

CMMC marks aspirants’ ability to adhere to globally recognized and viable cybersecurity practices. Benefits of this credential are:

• DoD agencies and related bodies prefer hiring CMMC-certified contractors/subcontractors because they know that such contractors are equipped with the knowledge required to keep critical data protected. With the mention of this certification, contractor winning becomes easier than ever.
• Other than winning the trust and grabbing deals, another benefit of being a CMMC-certified contractor is to be competent to deal with any novel or well-worn security threat. CMMC is very flexible. It boosts a business’s maturity level, making them able to deal with any breach or risk.
• The strict adherence to CMMC authorizes contractors to prevent involving security assessment organizations, which will further save operational overheads.
• As there will be a fully independent evaluation of security standards, it will be possible to review each contractor or sub-contractor from a unified standard.

‍

Impacts of CMMC

The way CMMC redefines a contractor's trustworthiness and its understanding of digital security, it obviously has a huge impression on DoD’s contractors and other affiliated entities. Some of the most notable CMMC impacts are quoted next.

• A sound security ecosystem

Before CMMC, cybersecurity was never a selection criterion for DoD contractors. After its launch, contractor evaluation now depends on their security arrangements greatly. This also means that incidents of data leak during goods and service delivery will be way too reduced. 

• Truthful and verified claims 

As CMMC compliance demands unbiased audits, it compels contractors/sub-contractors to remain honest in the pitching or tender. The quotes are more likely to feature only authentic claims about the cybersecurity culture of the vendor. When such transparency is maintained, the workflow is less likely to feature reduced legal hassles.

• More quality-driven contractors in the market

CMMC categorizes vendors/contractors into the five-maturity level, and each level comes with certain compulsions that they have to abide by. DoD has a very strict attitude towards the maturity level and decides them for every contract.

To complete the competitions, more and more DoD vendors will try to become certified, and sub-standard vendors will be more likely to go extinct over a period.

• More focus will be on auditing 

Independent and unbiased 3rd party audit is an integral part of CMMC compliance and DoD is dependent on certified auditors or auditing agencies to check any contractor’s credibility. Hence, we get to see more auditors and industry advisors in the near future.

There are more than 300,000 companies that are direct or indirect parts of the DoD’s supply chain. All these vendors will need an expert to align their IT infrastructure’s security with the anticipations of DoD and consultants, auditors, and advisors will play a key role here.

‍

CMMC Audit Preparation

As mentioned above, CMMC auditing is necessary for DoD vendors to affirm the adherence with NIST SP 800-171 Rev B as well as Rev2 controls. Contractors have to provide substantial proof of their implementation. 

Here are a few tips to be prepared for CMMC audit preparation:

• Start on your own

If, as a contractor, you have Self Assessment NIST Handbook 162 then you need to go through this internal resource extensively. 

Remember that the covered controls here are NIST SP 800-172 Rev 2. NIST 800-171 acts like a CMMC foundation and if you manage to fulfill all of its standards, reaching CMMC Level 3 will be easy. However, you will need to make sure 21 more controls are implemented.

• Hire a CMMC consultant

We understand that it’s not easy to comprehend what NIST SP 800-171 Rev 2 or REV B control demands. For many, it’s too confusing. However, it shouldn’t be an excuse. Hence, the ideal option here is to hire a CMMC expert. Better to outsource because outsourcing is a time and money-saving process. 

You need to outsource this talent from trusted MSSPs that can guide you extensively through your CMMC journey and provide inputs on maintaining compliance in the future as well. However, you must keep in mind that outsourcing a CMMC consultant doesn’t mean that you’re a CMMC-compliant contractor or company. You still have to make efforts to meet quality standards.

• Perform result-driven gap analysis

It is the primary step to take toward becoming a CMMC-compliant contractor. With gap analysis, you will be able to find out how far you’re from the pre-defined CMMC prerequisites. As the process continues, MSSP will eliminate highly ineffective setups by paying close attention to the ongoing procedures and networks. 

If performed effectively, this analysis procedure can help you find out which incident response plans are in place, effective data record storage, effective implementation of security controls, and measurement of information access.

• Be ready with a remediation plan 

From the findings of the gap study, we recommend you create a remediation plan for the risks or loopholes spotted. You need to introduce solutions according to the severity of the issue and the spending capacity.

• Make sure monitoring and reporting are continuous

Even if you manage to own CMMC-compliant network systems, you’re suggested to have regular monitoring and reporting to all the tools you’re using to monitor the system's security.

• Maintain the documented proof of the controls application

Don’t forget to obtain the documented proof of the applications of NIST SP 800-171 Rec1 or REV B controls from the outsourced MSSP. This document will help you pass the CMMC auditing as it’s a mark of your authenticity. 

CMMC Compliance Checklist

Here is a quick CMMC compliance checklist to refer to.

• Make sure that you’re conducting enough cybersecurity awareness programs and training for the staff and concerned personnel
• Incidence responses should be well optimized
• Build a healthy and extensive communication system so that any threat or risk information is passed on quickly
• Try to keep your focus on NIST SP 800-171 compliant
• Don’t overlook the supply chain and try to spot the existing risks and make sure the evaluation is happening at regular interval 
• The use of 2FA and robust data-loss prevention tools are must
• Set up a self-audit schedule and conduct internal audits

The Future Of CMMC And The Final Word

CMMC is here to stay as penetration of cybersecurity is increasing. It is a device for DoD contractors to be more compliant with security essentials. Every year, new needs and benchmarks are introduced in this certification. That’s the reason why selection programs are increasingly going to refer to it.

Considering this, it’s not hard to believe that CMMC will soon become a non-negotiable aspect and selection criteria for contract selection. However, there is one fact about CMMC. It’s not a matured certification, and further refinements are required for sure. Contractors can consider professionals and take their assistance to prepare for this and confidently present their candidacy. With one certification, DoD contractors have a chance to brighten their scope of being selected.