Over the last several years, the U.S. Department of Defense (DoD) has been working to develop the Cybersecurity Maturity Model Certification (CMMC) to standardize cybersecurity preparedness for more than 300,000 contractors across the defense industrial base (DIB). The CMMC will soon become a requirement for any defense contractor or other vendor that is working with or wishes to work with the DoD.
The main goal of the CMMC is to safeguard Controlled Unclassified Information (CUI) in the DoD supply chain. CUI refers to any data or information that is created or stored by the government or another entity on behalf of the government. The CMMC framework incorporates many practices, processes, and approaches to standardize the assessment of a defense contractor’s capabilities.
Meeting CMMC compliance requires DoD contractors to go through several essential steps. Here is a look at recommended practices to become CMMC compliant.
1. Identify The CUI Environment
To become CMMC compliant, a contractor must first identify the CUI environment specific to the contract. This is where CUI is processed, transmitted, and stored. The CUI environment defines the systems, processes, and services in scope for NIST 800-171. Each business is unique; therefore, CUI is generally defined by the U.S. Government’s contracting official for the prime contractor. A prime contractor is required to identify CUI in all contracts to subcontractors.
2. Determine What Controls Are Applicable
Businesses will need to determine what services, systems, and processes are needed to comply with NIST 800-171. There are a total of 62 Non-Federal Organization (NFO) and 110 CUI controls, but not all may apply to every CUI environment. When dealing with simple or flat networks, all controls may be applicable across the organization. In segmented CUI environments, most controls may apply to subnetworks.
3. Create Standards, Policies, And Procedures
The next step to becoming CMMC compliance-ready involves developing standards, policies, and procedures to address applicable cybersecurity compliance requirements. Consider all applicable regulations, laws, and contracts that the business must comply with, including domestic and international cybersecurity laws. Also, determine if there are any industry-specific regulations, privacy laws, or contract requirements from partners that require compliance. Contractors must perform due diligence to ensure that they have the proper documentation to prove compliance.
4. Implement NIST 800-171 Controls
In this step, the processes and technology come together to create an operational cybersecurity program. Organizations must address and implement NIST 800-171 controls to put the developed standards and policies to use. The parties responsible for certain CUI controls will need to be identified and the roles and responsibilities of these individuals or teams must be defined. This helps guarantee that no aspects of the implementation are overlooked or performed inaccurately due to misunderstandings.
5. Document and Assess The CUI Environment
Next, defense contractors should document the CUI environment and assess its controls and potential deficiencies. Now, organizations can develop a Plan of Actions & Milestones (POA&M) and a System Security Plan (SSP). Over time, these “living documents” will continue to receive changes and updates that may impact the CUI environment.
6. Manage Risk Across Business And Technology Processes
In this next step, contractors can use the controls to assess their risk across business and technology processes. Risk models may include a variety of options, such as NIST 800-37, ISO 31010, FAIR and OCTAVE. There is no perfect risk methodology but businesses can choose a methodology that best supports how the company functions. The goal for any organization should be to reach a comfortable level of risk.
7. Gather Metrics To Find Areas Of Improvement
The final step in becoming CMMC compliance ready involves gathering metrics. Metrics can be useful to give businesses a general idea of the performance of controls. In the long-term, metrics can be used to perform a trend analysis that business leaders can leverage to identify areas of improvement. Gaining insights into controls can be accomplished in a variety of ways, such as by defining Key Risk Indicators (KRIs) or Key Performance Indicators (KPIs).
Importance Of Becoming CMMC Compliant
By 2025, all DoD contractors will need to meet CMMC requirements. Contractors that currently work with the DoD or wish to start working with the DoD will need to get started on their CMMC certification.
Companies that undergo the certification can attain other key benefits, such as enhanced protection of CUI and intellectual property (IP) within the DIB. Becoming CMMC certified also results in a risk reduction against harmful cyber threats. It is also a cost-effective way for small businesses to implement lower CMMC levels.
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Vulnerabilities within business systems have contributed to some of the most publicized corporate breaches in history. The release of the CMMC has helped countless businesses start the journey of achieving a high level of protection against cybercrimes. For more information about how to become CMMC compliance-ready, contact SeaGlass Technology.