CMMC Compliance – A Quick Overview

last edit: 09/25/2023

What Is the CMMC?

The Cybersecurity Maturity Model Certification (CMMC) is a new cybersecurity framework by the US Department of Defense (DoD) for the DoD supply chain and its contractors. The goal of the new CMMC compliance requirement is to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).

The latest iteration CMMC 2.0 was announced November 4th 2021 and includes three levels of CMMC compliance. Each level requires more practices and controls than the previous. At Level one it includes basic requirements from the Federal Acquisition Requirements (FAR) document 52.204-21, whereas NIST SP 800-171 requirements (from DFARS 252.204-7012) are in place for Level 2. At Level 3 additional security controls are required. Most organizations will have to comply with either Level 1 or Level 2.

Who Needs CMMC Certification?

Only contracts for Commercial Off-The-Shelf (COTS) products will be exempt from CMMC compliance requirements.

Any company that bids on a DoD contract that contains Federal Contract Information (FCI) and/or Controlled Unclassified Information (CUI) will be required to be CMMC compliant at the time of contract award. This requirements flows down to the subcontractors.

Which Level of CMMC Will We Need?

The CMMC level mandated will be stated in the contract information. The majority of contracts will require a Level 1 or Level 2 compliance.

As a general rule:

  • If your company will receive exclusively FCI under the contract, then your will need to meet CMMC Level 1 compliance requirements.
  • However, if your organization will receive CUI in addition, then CMMC Level 2 will be required as a minimum.

For more details about the different CMMC Level and the assessment requirements see: CMMC Compliance Levels in CMMC 2.0.

CMMC Assessments

Depending on the CMMC Compliance Requirements you will need to comply with, the implementation and compliance status will be verified in different ways:

  • Level 1: A self assessment will need to be submitted to the Supplier Performance Risk System (SPRS). A Senior Official or Principal who is responsible for the CMMC compliance program within the organization and who can be held responsible under the False Claims Act. These assessments will have to be performed annually.
  • Level 2: A Certified 3rd Party Assessment Organization (C3PAO) will perform an independent assessment. The finding will be submitted to the Cyber-AB which will issue the certification. CMMC Level 2 certifications will be valid for 3 years but a requirement for an annual self assessment is expected. A small number of organizations at Level 2 might be allowed to perform self assessment as described for Level 1.
  • Level 3: As for Level 2, a Certified 3rd Party Assessment Organization (C3PAO) will perform an independent assessment to check for the compliance to the Level 2 controls. In addition to the C3PAO, auditors of the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) will assess the additional controls that are exclusive to Level 3. The resulting certification will be valid for three years.

When Will This Be Required?

The DoD had started rolling out CMMC compliance requirements for a few pilot contracts beginning of 2021. However, due to the significant changes in the latest CMMC 2.0 iteration the DoD suspended any CMMC requirements for new contracts until the rulemaking process for CMMC 2.0 is completed. The CMMC rule was submitted to the Office of Information and Regulatory Affairs (OIRA) in July 24th 2023. Based on this, the publication of the CMMC rule is expected October 2023 with initial requirements showing up in DoD contracts starting in Q1 2024 to Q1 2025.

In the meantime, DFARS 252.204-7012 and -7019 are still in effect and require each organization to have a NIST SP 800-171 Assessment performed, the resulting score submitted to the SPRS, and a System Security Plan (SSP) as well as a Plan of Actions & Milestones (PoA&M) document in place. New DoD contracts might have minimum requirements for the organization’s NIST SP 800-171 assessment score.

After years of delays, the CMMC rulemaking process is in its final phase and the time to prepare is now: CMMC Level 2 implementation takes organizations an average of 12-18 months. Even assuming a that contracts will not include CMMC requirements until Q1 2025, time is running out to prepare. In addition, we expect a rush of companies trying to become certified with availability of the C3PAOs becoming a bottleneck. In other words – it’s time to get ready sooner than later.

Companies that want to get ahead of the curve can opt for Joint Surveillance Assessments. These assessments on a voluntary basis started late August 2022 and are performed by a C3PAO and DIBCAC. The DoD stated the intention to convert these “NIST SP 800-171 high” assessments with a perfect score of 110 points into a CMMC Level 2 certification upon publication of the final CMMC rule.

How Long Does It Take to Implement CMMC?

The implementation time-frame depends on these main factors:

  • The level of certification you are required to comply with
  • The current state of your NIST SP 800-171 implementation
  • The size and scope of your system.

For example, after an initial Gap Analysis, it will take most organizations 10-18 months to achieve CMMC Level 2 compliance and to be ready for the certification assessment. CMMC Level 1 compliance can be accomplished in a much shorter time-frame. For an overview of the preparation and certification process including some time estimates see CMMC Compliance Process and Timeline.

What Is the CMMC Cost?

The cost of achieving CMMC compliance depends on the same factors as listed above. You have to consider expenses for these steps:

  • Support by companies like Ecuron for help with implementation
  • CMMC implementation cost
  • CMMC Assessment by a CMMC Third-Party Assessment Organization (C3PAO) if you are required to do so (CMMC Level 2 and Level 3)

We advise companies wishing to work with the DoD in the future to expect some ongoing expenses in addition to the initial cost of becoming compliant.

CMMC Compliance & Existing Cybersecurity Requirements

While there is a lot of buzz about CMMC, the reality is that it adds hardly any new requirements. We thought it would be helpful to take a step back and summarize all the existing cybersecurity requirements for contractors in the DoD supply chain.

Our latest report gives a high-level overview of these existing FAR & DFARS requirements, how they relate to each other and to CMMC 2.0. The report is available for download at https://www.ecuron.com/dib-report/.

Cybersecurity Requirements for DoD Contractors - Report

How We Are Prepared To Help You

Ecuron is a CMMC Registered Provider Organization - CMMC-RPOEcuron has been receiving CMMC Registered Professional training from the Cyber AB (formerly called the CMMC Accreditation Body) to be among the first companies qualified to help you to become CMMC compliant. As a CMMC Registered Practitioner Organization™ (CMMC-RPO) and with engagements in more than 12 states under our belt, Ecuron is specialized in services designed to take you from your current status to full CMMC compliance in the most efficient way. We do not conduct the final CMMC Assessments.

Depending on your organization’s current cybersecurity status and the CMMC Level required, implementation of the new standard can take from a few weeks to a several months. Starting now will save you valuable time and will get you ahead of the competition.

We offer CMMC Consulting Services to get you CMMC compliant in 4 Steps:

  1. CMMC Gap Analysis / CMMC Gap Assessment
    See where your organization stands and what it takes to achieve compliance
  2. CMMC Implementation Help
    Based on the results of the first phase we will help you to close existing gaps by implementing suitable controls and any missing requirements. This includes developing and writing the extensive documentation required.
  3. CMMC Pre-Assessment
    Think of it as a mock audit. We will verify that everything is in place, mature, and can be proven to an auditor. If we find issues we will help you fix them. If your company needs to be assessed by a C3PAO or DoD official we will recommend to schedule the actual audit once we are confident that you are ready for the CMMC Assessment.
  4. CMMC Assessment Support
    If your company needs to be assessed by a C3PAO or DoD official we help you prepare for the audit, gather & organize evidence for a smooth assessment . We will be at your side throughout the process.

To discuss your CMMC requirements and schedule a complimentary 30 min consultation, email us at cmmc@ecuron.com, use the form below, or give us a call.

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last edit: 09/25/2023


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