Of Chickens and Eggs: an MSP’s take on the CMMC proposed rule for the DIB
If your business is not a member of the Defense Industrial Base (DIB), and you don’t do work on a contract basis as part of the supply chain to the Department of Defense, you can stop reading now. Seriously. Despite the article’s title, this missive is full of acronyms and explanations of compliance requirements and has nothing to do with breakfast. And did I mention acronyms? I will wait.
Okay, since it is just “us” now, I will share a few high-importance details from the proposed CMMC rule, and specifically how you will work with companies like mine. Managed Services Providers (MSPs), Managed Security Service Providers (MSSPs), and other external service providers (ESPs) have been included in the CMMC fray, and it will impact your business.
Answered questions, with a side of questions
Over the last several years, we have had a lot of questions concerning our clients’ obligations because of the coming Cybersecurity Maturity Model Certification (CMMC). At long last, many of those questions are getting answered; the DoD released the proposed rule on December 26, 2023.
CMMC is the verification mechanism through which the DoD is assured that the contractors and subcontractors they work with have information systems in place to protect the sensitive data they hold. It was created because the DoD discovered that many operational and cybersecurity practices within the DIB were weak making our nation vulnerable to attack. The CMMC rule closes loopholes that have allowed plans of action purposed to remediate the weaknesses to remain open for long periods of time.
Most of our questions have been regarding the more advanced cybersecurity and operational requirements for DIB businesses that process, store, or transmit Controlled Unclassified Information (CUI) and who will need to secure a CMMC Assessment provided by an authorized CMMC Third Party Assessment Organization (C3PAO) at Level 2. Level 1 DIB businesses are required to protect Federal Contract Information (FCI) and are allowed to sell-assess their environment. Both levels 1 and 2 require that a company executive sign an affirmation that they have accurately assessed and are operating under the controls.
The significant update is that businesses classified as Level 1 and Level 2 in the Defense Industrial Base (DIB) sector will face upcoming challenges related to choosing their service providers.
It turns out, the DoD references many of the functions that MSPs perform within the definition of an External Service Provider: “external people, technology… that an organization utilizes for provision and management of comprehensive IT and/or cybersecurity services… CUI or Security Protection Data (e.g., log data, configuration data) must be processed, stored, or transmitted on the ESP assets to be considered an ESP.”
Accordingly, we, the MSPs and MSSPs of the world that serve the DIB, will need to achieve our CMMC certification too! Not only that, but any ESP will need to certify at or above the level of the contractor they support is required to certify. While we have been expecting this and implementing the requirements in our own business, most MSPs or other ESPs have not.
Why does this matter to you? When your company uses an MSP or other external service providers, they are included as “in scope” for your organization’s System Security Plan; they will be included in your assessment. Meaning- you can’t pass your CMMC Assessment unless and until your ESP has passed their assessment and have a final certification as your provider. You will not be able to work for the DoD until all your ESPs have their certification. Let’s just say, there is some debate on how this chicken-and-egg-timing will work itself out… and there are still other considerations as far as timing.
This also means that your team will need to carefully vet the capabilities of every external service provider hired to work for you… and their tools.
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