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).
This new umbrella standard includes requirements from NIST SP 800-171, the Federal Acquisition Requirements (FAR) document 52.204-21, and beyond. 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. 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.
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 CMMC Level 1 implementation and certification.
- 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.
Depending on the CMMC Compliance Requirements you will need to comply with, the implementation and compliance status will be verified via an self assessment that needs to be submitted to the SPRS, a Certified 3rd Party Assessment Organization (C3PAO), or DOD officials. While the outside assessments will be valid for three years, any self assessments will have to be conducted annually and need to be accompanied by an annual affirmation from a senior company official that the company is meeting requirements.
When Will This Be Required?
The DoD had started rolling out CMMC 1.02 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. In May 2022 CMMC director Stacy Bostjanick announced that the Pentagon plans to publish the CMMC ‘interim rule’ in early 2023, with initial requirements showing up in DoD contracts starting in May 2023.
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.
Although the CMMC compliance requirements are still several months away, we highly recommend that companies who plan to bid on DoD contracts start preparations for their CMMC assessment now. The early adopters of CMMC will have a clear competitive advantage – especially considering that implementation will take several months and compliance is required at the time of contract award.
After years of delays, the CMMC rulemaking process seems to be on track and the latest update by CMMC director Stacy Bostjanick indicated that it is progressing faster than initially announced. Considering the upcoming May 2023 date (revised from July 2023) for CMMC contract requirements we expect a rush with availability of the C3PAOs becoming a bottleneck. In other words – it’s time to get ready sooner than later.
Currently, the DoD is discussing different incentives for those companies that become compliant before CMMC is mandatory. Assessments on a voluntary basis started late August 2022.
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 6-12 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/.
How We Are Prepared To Help You
Ecuron 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 10 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 several weeks to a few 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:
- CMMC Gap Analysis / CMMC Gap Assessment
See where your organization stands and what it takes to achieve compliance
- 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.
- 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.
- 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 firstname.lastname@example.org, use the form below, or give us a call.
- CMMC Compliance Process and Timeline
- CMMC 2.0 vs 1.0
- CMMC Compliance Levels
- CUI Marking Guidelines
- NIST SP 800-171 Assessment
last edit: 06/01/2022