Posts by LauraMusser

Where do I start with CMMC compliance?

Posted on Dec 22, 2023

At long last, the CMMC proposed rule will be released on December 26, 2023! 

If you have not prepared to pass the CMMC Assessment, there is no time like the present! (And if we may be so bold, we suggest preparing for the journey with some music to get you in the right frame of mind!)

Where does a contractor in the Defense Industrial Base start?

Rally the troops, and choose a leader: CMMC compliance is a team effort. A common misconception of the CMMC program is that it contains all technical controls and requires little coordination with staff not directly involved with IT. However, the CMMC program controls involve much more than technical configurations: human resources, building security, administration and operations, accounting, and even external service and cloud providers may be inscope. 

Leadership starts at the top. Management must make clear that conforming to the requirements of CMMC is a priority. Kick off an all-hands meeting to align and educate the entire organization and include goals, defined roles and responsibilities, and communication channels. It is key to have one person designated to serve as the lead to coordinate your team’s efforts. In one company that MNS Group works with, the head of business development led the compliance implementation for the company. Why that role to lead the effort? Lost opportunity. This individual had a lot to lose if the company did not become compliant in time to win the contracts that provided the bulk of his department’s income, and he possessed the skills to educate, encourage, and track the various departments to contributions. Whoever in your organization secures the honor, they will require the support of the management team.

The good news is that if you are working with MNS Group, we are able to assist your team with our CMMC Certified Professionals and Assessors (CCPs and CCAs), with implementation and support toward compliance.

Determine the level you need to comply with.

Your contract and the type of information your company handles determines the level and number of controls your organization must meet. Every defense contractor will need to meet at minimum Level 1. The CMMC 2.0 model consists of three distinct levels, each representing a different set of cybersecurity practices and processes:

Level 1 – Foundational: This level is focused on the protection of Federal Contract Information (FCI) and encompasses the basic safeguarding requirements for this information as outlined in Federal Acquisition Regulation (FAR) 52.204-21. It includes 17 practices that are fundamental to cybersecurity, largely aligning with basic cyber hygiene practices. At this level, companies are required to perform annual self-assessments.

Level 2 – Advanced: Level 2 aligns with the protection of Controlled Unclassified Information (CUI) and is based on a subset of the security requirements specified in NIST SP 800-171. Level 2 applies to you if your company handles CUI; you are already subject to DFARS 252.204-7012 requirements and have been since late 2017. This level includes a total of 110 practices and focuses on the implementation of intermediate cyber hygiene practices to protect CUI. Level 2 requires companies to undergo an independent third-party assessment every three years to ensure compliance.

Level 3 – Expert: This level is intended for companies that are part of the defense industrial base and are handling critical national security information. Level 3 is based on a subset of the security requirements from NIST SP 800-172, along with additional practices and processes from other sources to protect CUI and reduce the risk from Advanced Persistent Threats (APTs). Compliance with Level 3 requires a government-led assessment every three years. The final rule is expected to have greater detail on this level.

Target your efforts based on the level at which your organization must comply. 

Scoping

If your company handles, creates, stores, or transmits CUI- who handles it? Where is it accessed, processed, or stored? The environment where CUI exists helps determine your scope. A System Security Plan (SSP) documents what controls are in place. The smaller the environment, the less expensive compliance efforts will be. Some companies find that an enclave for the CUI is a smart solution.

An enclave is a way for organizations to limit the endpoints that need to be secured, making compliance efforts more streamlined, resulting in less expensive and sometimes faster compliance. All contractors to the DoD will have Level 1 controls in-scope applied organization-wide, even if your CUI is confined to an enclave.

Bracing for Impact: The Finalization of CMMC Rules and What It Means for DoD Contractors

Posted on Dec 4, 2023

As the finalization of the Cybersecurity Maturity Model Certification (CMMC) rule looms near, DoD contractors are on high alert. With CMMC 2.0, the Department of Defense (DoD) aims to streamline and strengthen cybersecurity requirements. This shift to a three-level model demands a strategic approach from contractors to ensure compliance and safeguard sensitive information.
Although the final CMMC rule has not been officially released yet, recent developments have brought significant updates. As of November 21, 2023, the Office of Information and Regulatory Affairs (OIRA) website shows an important change in the status of the eight components and the overarching Framework of the Cybersecurity Maturity Model Certification Program (CMMC). Previously marked as “Pending Review,” these elements have now been updated to “Consistent with Change.” This shift suggests that the CMMC program, along with its eight foundational policy elements, is advancing towards publication.