The Department of Defense (DoD) plays a pivotal role in safeguarding the national security of the United States. In today's digital age, this mission extends to the realm of cybersecurity. To ensure that DoD contractors are adequately protecting sensitive information, the DoD has introduced the Cybersecurity Maturity Model Certification (CMMC) 2.0. This groundbreaking framework aims to bolster cybersecurity within the defense industrial base. In this comprehensive guide, we'll explore CMMC 2.0, delve into what an audit checklist might look like, discuss how defense contractors can start the cmmc certification process, and examine how CMMC aligns with the National Institute of Standards and Technology (NIST) Special Publication 800-171.
Understanding the CMMC Framework
Cybersecurity Maturity Model Certification (CMMC) is a comprehensive framework that sets out to strengthen cybersecurity practices across the defense industrial base. It applies to all organizations, ranging from prime contractors to subcontractors, involved in government contracts, specifically those that handle Controlled Unclassified Information (CUI). CMMC 2.0 is the latest iteration of this certification, incorporating improvements based on feedback and lessons learned from CMMC 1.0.
In CMMC 1.0, the DoD's first attempt at cybersecurity maturity model, the DoD outlined a 5 Level process maturity model framework:
Level 1 (Basic Cyber Hygiene): Focuses on safeguarding Federal Contract Information (FCI) and requires organizations to document their cybersecurity policies and procedures.
Level 2 (Intermediate Cyber Hygiene): Introduces the protection of CUI and necessitates the establishment of a plan for cybersecurity improvement.
Level 3 (Good Cyber Hygiene): Continues CUI protection with a focus on the documentation, communication, and enforcement of cybersecurity policies and practices.
Level 4 (Proactive): Elevates the organization's security practices, emphasizing the review, management, and enforcement of security policies and procedures.
Level 5 (Advanced/Progressive): Achieving the highest level of maturity, Level 5 centers on optimizing security practices and implementing advanced security measures.
CMMC 2.0 introduces a more streamlined process, adding flexibility to the certification and compliance journey, emphasizing the maturity of cybersecurity practices. CMMC 2.0 utilizes a specialized cybersecurity maturity level approach that consists of three maturity levels, each with associated practices and processes that organizations must implement to achieve compliance:
Level 1 (Foundational): Level 1 focuses on basic cybersecurity hygiene and is meant to establish foundational cybersecurity practices. CMMC 2.0 Level 1 maps to the previous Level 1 requirements from CMMC 1.0. At this level, organizations are expected to adhere to a set of practices that provide a basic level of security. These practices are often similar to those found in NIST SP 800-171, which is a widely recognized cybersecurity framework. Level 1 includes practices such as ensuring the use of strong passwords, implementing basic access controls, and maintaining an inventory of hardware and software. An annual self assessment is required for Level 1.
Level 2 (Advanced) : Level 2 is an intermediate stage that builds upon the foundational practices of Level 1 and requires organizations to establish a more robust and comprehensive cybersecurity program. This level introduces a broader set of security practices and controls, which are often more advanced than those in Level 1. Organizations at Level 2 need to demonstrate the ability to protect controlled unclassified information (CUI) effectively. Practices at this level may include implementing incident response plans, performing regular security assessments, and enhancing access controls. Triannual third party assessments and an annual self assessment is required for Level 2.
Level 3 (Expert) : Level 3 represents the highest level of maturity in the CMMC framework and is designed for organizations with highly advanced and proactive cybersecurity practices. CMMC 2.0 Level 3 maps to the previous requirements of Level 5 from CMMC 1.0. At this level, organizations are expected to have a well-optimized and highly proactive cybersecurity program that can adapt to evolving threats. Level 3 includes a wide range of security practices, including continuous monitoring, advanced threat hunting, and the ability to adapt quickly to emerging cyber threats. Level 3 organizations are also expected to have a mature incident response capability and a strong focus on overall cybersecurity program management. Triannual government led assessments are required for Level 3.
The CMMC Compliance Checklist
As organizations work towards CMMC 2.0 certification, they need a clear roadmap to ensure they can achieve the desired cmmc level of compliance. While the specifics of the audit process are managed by certified third-party assessors, organizations can prepare for self assessment themselves by using an audit checklist. Below is a simplified audit checklist that maps to the CMMC 2.0 maturity levels:
Level 1 (Foundational)
Document cybersecurity policies and procedures.
Conduct security awareness training for employees.
Use antivirus and anti-malware software.
Implement access control measures.
Create backups of critical data.
Level 2 (Advanced)
Develop a system security plan.
Establish an incident response plan.
Monitor system security alerts.
Conduct regular vulnerability assessments.
Implement secure configurations for hardware and software.
Enhance documentation and communication of policies.
Utilize encryption for data at rest and data in transit.
Enforce role-based access controls.
Establish secure network architecture.
Maintain and monitor audit logs.
Review, update, and communicate cybersecurity policies regularly.
Conduct penetration testing and annual self assessments.
Implement a security operations center (SOC).
Utilize advanced threat intelligence.
Continuously monitor and analyze audit logs.
Level 3 (Expert)
Optimize security practices and processes.
Implement a threat hunting program.
Utilize artificial intelligence and machine learning for threat detection.
Conduct continuous risk management.
Establish a culture of cybersecurity throughout the organization.
This checklist provides a simplified overview of the cybersecurity requirements for each maturity level. Achieving CMMC compliance demands a deep commitment to cybersecurity practices and a clear understanding of the specific controls and practices required.
How Do I Achieve CMMC Certification?
As a defense contractor or subcontractor, you are tasked to protect sensitive information and ensure personnel security as part of cmmc compliance. Achieving CMMC certification requires a systematic and dedicated approach. Most organizations will require the assistance of a third party, such as managed service providers (MSP) or managed security services providers (MSSP) who specialize in cybersecurity, to ensure the organization's security posture is implemented correctly.
Here are the key steps you should follow:
1. Self-Assessment:
Begin by conducting a thorough self-assessment of your organization's current security practices. Determine your starting point with respect to CMMC maturity levels.
2. Plan and Gap Analysis:
Develop a detailed plan for achieving the desired CMMC maturity level. Identify gaps between your current practices and the requirements of the selected level.
3. Security Controls Implementation:
Implement the necessary security controls and practices to bridge the identified gaps. This may involve updates to policies, procedures, and technological solutions.
4. Documentation:
Document all cybersecurity policies, procedures, and actions. Comprehensive documentation is critical to demonstrate compliance during the assessment.
5. Employee Training:
Conduct security awareness training for all employees to ensure they are informed and capable of adhering to the security measures.
6. Third-Party Assessment:
Engage a certified third-party assessment organization (C3PAO) to perform an independent assessment of your organization's security practices. They will evaluate your compliance with CMMC requirements.
7. Corrective Actions:
Address any deficiencies or non-compliance issues identified by the third-party assessment organization. Make necessary improvements to achieve compliance.
8. CMMC Certification:
Once your organization has meet the CMMC compliance requirements, you will receive your CMMC certification, demonstrating your commitment to cybersecurity maturity.
9. Ongoing Monitoring:
Maintain continuous cybersecurity monitoring and periodic third party assessments to ensure that your organization remains CMMC compliant.
Achieving CMMC certification is a significant endeavor that requires dedication and a commitment to continuous improvement. However, it is essential for defense contractors and organizations involved in DoD contracts to safeguard sensitive information and contribute to national security.
Mapping CMMC to NIST SP 800-171
CMMC and NIST SP 800-171 are intricately linked, as the former builds upon the latter. CMMC, in essence, extends and enhances the various security requirements and controls established in NIST SP 800-171. NIST Special Publication 800-171 outlines security requirements used for protecting Controlled Unclassified Information (CUI) and serves as the foundation for CMMC.
NIST SP 800-171 is comprised of 14 control families, each with its own set of security controls. These control families cover areas such as access control, incident response, physical protection, system and communications protection, configuration management and security assessment and authorization.
CMMC 2.0 takes these NIST SP 800-171 controls and aligns them with the five maturity levels described earlier. The intention is to ensure that organizations not only implement the necessary controls but also mature their cybersecurity processes over time. The alignment of CMMC with NIST SP 800-171 provides a clear path for organizations to follow, emphasizing a gradual progression towards a more robust cybersecurity posture.
Wrapping up Your Compliance Journey
The Department of Defense's CMMC 2.0 certification represents a pivotal step in strengthening cybersecurity across the defense industrial base. By mapping the requirements to maturity levels, organizations can clearly see what is expected of them as they work towards achieving compliance and beyond. The integration of CMMC with NIST 800-171 controls ensures a well-defined path to improving cybersecurity practices.
In an era where cyber threats continue to evolve and pose significant risks to national security, CMMC 2.0 plays a vital role in fortifying the cybersecurity and cyber resilience of organizations that engage with the DoD. By diligently following the roadmap to CMMC compliance, organizations can contribute to a safer and more secure national defense.
How slashBlue Can Help
Who We Serve
slashBlue is a managed services provider (MSP) specializing in cybersecurity for architecture firms, engineering firms, and defense contractors.
Our Process
Our 6 step cybersecurity advisory and oversight program is designed to address the most critical steps required to gain cmmc compliance.
How Long it Takes
Using our 6 step cybersecurity advisory and oversight program we help most businesses reach their target maturity in 3-4 months. For firms seeking to achieve Level 2 cmmc compliance we are able to achieve maturity for most organizations in less than half a year.
How We Work
Our program works with your current IT team or MSP. We will work along side your team to guide them in the implementation of security protocols and in remediation of vulnerabilities that could pose a threat to your information integrity. Or if you don't have an IT team or MSP, as a managed services provider ourselves we can also take full responsibility for your cybersecurity and technology environment, delivering you a more mature technology environment designed for cmmc compliance.
What You Get
As part of our Cybersecurity Advisory and Oversight Program we provide you with a cyberSecurity slashBlueprint which contains your cmmc assessment report and roadmap for achieving cmmc compliance. Once your target maturity has been reached we will perform a cmmc self assessment and connect you with one of our trusted certified cmmc assessors.