As a small or medium-sized business owner, navigating the seeming maze of compliance and assessment requirements for CMMC 2.0 can feel overwhelming, especially when your main focus is on running your business.
With the Cybersecurity Maturity Model Certification (CMMC) 2.0 Final Rule now in effect, all Defense Industrial Base (DIB) contractors and subcontractors must get assessed at one of three levels to show how they’re safeguarding the federal contract information (FCI) and controlled unclassified information (CUI) they process, store, or transmit.
If you’re unsure how to unpack the requirements and get started on your compliance journey, or pick up where your compliance efforts stalled, you’re not alone.
Many other Department of Defense (DoD) businesses, large and small, are grappling with how best to meet the regulatory mandates.
What is clear, however, is that getting assessed and meeting CMMC 2.0 compliance are not optional. They’re required for all DIB businesses in order to keep your existing DoD contracts or be eligible for others.
Since most businesses within the DIB are SMBs, the potential financial blow of losing such a critical revenue source could prove debilitating, if not fatal, to many of them.
In this article, we’ll detail the six crucial factors you should take into consideration when choosing a CMMC compliance readiness partner.
With this information, you’ll have a clear picture of what to look out for so you can become compliant, pass your assessment, and most importantly, get certified so you can continue your relationship with the DoD and capitalize on new opportunities.
If you’re a CMMC Level 2 business, have you figured out the type of CUI your business stores, processes, or transmits? Do you know how that data flows through your organization to accurately scope your CUI boundary?
Related Article: 5 Questions To Pinpoint Your Required CMMC Level
What security gaps do you have within your identified boundary? Which cybersecurity solutions are allowable as remediations to fix those security vulnerabilities?
By partnering with an external compliance readiness partner, you’ll get answers to these and other questions you may have about the regulatory requirements.
Your readiness partner can evaluate your environment, taking into consideration the unique aspects of your organization, to offer a customized compliance plan tailored to your business.
CMMC 2.0 compliance requirements are intended to be both robust and measurable to ensure that businesses are doing everything they can to safeguard the sensitive federal information they handle.
It also gives the government a way to enforce ongoing compliance.
Using a compliance readiness partner will allow you to get a handle on where you are in the process, what steps you still need to take to satisfy the requirements, and help ensure that nothing is missed to increase your chances for a successful outcome.
Generally, a compliance readiness partner will be a managed IT service provider (MSP).
It’s important to note, however, that your compliance partner cannot also be the certified third-party assessor organization (C3PAO) that you choose to conduct your Level 2 assessment.
Related Article: How To Find An Approved C3PAO For Your CMMC Level 2 Assessment
Here are 6 factors to consider:
If you’re unsure where to start, find out if your potential compliance readiness company helps with pre-assessment tasks, and if so, to what extent.
Look for a compliance partner that can help you find and evaluate the kind of data you handle, whether it’s FCI or CUI, and where that data lives within your environment.
This will allow you to discover the devices, processes, applications, systems, and personnel your FCI or CUI touches as it flows through your organization.
With this information, your compliance partner will then help you establish a CMMC assessment boundary. This means you’ll be able to narrow the focus of your compliance remediations and resources to that targeted area.
What’s more, your managed IT partner can submit your supplier performance risk system (SPRS) score to get a baseline to determine your current security posture.
Ultimately, this will save you valuable time and money by not wasting resources upgrading or adopting unnecessary security controls for out-of-scope areas.
A gap analysis is not only a requirement of CMMC, but it’s also critical to actually becoming compliant. That’s because it brings into focus the hidden security defects within your organization.
Related Article: CMMC Step 2: How A Gap Analysis Can Help You Find Your Security Risks
So, it’s vital that you choose a company with the knowledge and expertise to conduct a comprehensive gap analysis to weigh your current security measures against those required by CMMC for your level.
Keep in mind that CMMC Level 1 organizations need to meet 17 foundational security controls that align with 15 practices in Federal Acquisition Regulation (FAR) 52.204-21. Level 1 businesses must perform an annual self-assessment and re-attest to continuing compliance every year.
At Level 2, the Advanced level, contractors and subcontractors must satisfy 110 security requirements from the National Institute of Standards and Technology Special Publication 800-171 (NIST SP 800-171). Most Level 2 businesses will need to get assessed every three years by a C3PAO and self-attest annually.
Level 3 businesses must meet the most rigorous standards because they’re responsible for fighting against advanced persistent threats (APTs). Federal auditors must perform their triennial CMMC assessments. They must also self-attest each year.
Having a customized gap analysis performed will allow you to pinpoint the trouble spots within your environment and correct those security flaws.
Once you’ve identified your security weaknesses, you’ll need to ensure that the security devices, software, systems, training, and other resources you adopt follow best practices for your industry and meet the CMMC requirements.
When selecting a CMMC readiness provider, be sure that they have a team with the specialized skills and knowledge to offer strategic recommendations about the right security solutions you’ll need to become compliant, such as access controls, employee security awareness training, and an incident response plan.
A system security plan (SSP) is another important factor to consider when choosing a compliance partner.
As with a CMMC gap analysis, an SSP is required to satisfy security compliance. It is essentially your documented evidence detailing your compliance strategy. Be prepared to show your finalized SSP to your C3PAO assessor as proof that you’ve met all of the compliance requirements.
Related Article: CMMC Step 4: SSP Documentation–What’s Your CMMC Compliance Evidence?
It’s one thing to put the security controls in place, it’s another to put them in writing. Find out if the MSP you’re considering partnering with will help you develop a comprehensive SSP to document all of the security measures you’ve implemented and how each of them work to safeguard the CUI and FCI you store, process, or share.
Without an SSP, you won’t pass your CMMC audit, which means you won’t get certified.
When deciding between compliance readiness partners, you should also ask whether or not they provide any pre-assessment preparation ahead of your official CMMC audit. This is a crucial step that shouldn’t be skipped.
You’ve already done the hard work of becoming compliant. Finding a last-minute security gap on the day of your assessment is not the time to discover issues.
A pre-audit review provides you with a CMMC compliance checklist to ensure that nothing gets overlooked.
Likewise, you should also determine if the potential compliance partner you’re researching performs a mock audit as part of this pre-audit preparation. If so, ask them what their mock audit covers and who on your team would need to be involved in it.
A CMMC mock assessment benefits your entire team because it makes sure that your staff is fully prepared when your actual assessment day arrives.
It ensures that they’re well-versed on your security measures and can deftly answer potential auditors’ questions about your compliance efforts and the security controls you’ve implemented, and demonstrate how they work to protect FCI and CUI.
In addition, you’ll be able to demonstrate to auditors how specific security measures work in real-time to prevent unauthorized access, such as physical security locks, role-based access controls, and multi-factor authentication.
This way, you can approach your upcoming CMMC assessment with confidence, knowing you’ve crossed every ‘t’ and dotted every ‘i’ to help ensure a smooth and successful audit.
Finally, your search criteria for a viable CMMC readiness provider should also be narrowed down to those businesses that offer ongoing support, even after your assessment and you’ve achieved final certification.
Ongoing compliance support is essential to keeping your security policies, records, and SSP up to date so that they accurately reflect your current environment. It will also help ensure that your team is continuing to adhere to the security controls you put in place.
This will allow you to confidently re-attest ongoing compliance each year following your assessment.
As a DoD contractor or subcontractor, there’s no shortcut for becoming compliant and achieving CMMC certification. After reading this article, you’ve learned what’s involved to becoming CMMC 2.0 compliant and what’s at stake if you fail to do so.
You also now understand how the right compliance partner can help streamline your compliance journey, providing expert guidance on the IT and cybersecurity tools, policies, procedures, and other security measures you need to become compliant, get certified, and maintain your relationship with the DoD.
This can save you considerable time, energy, and money by ensuring you have the right security tools, policies, and procedures in place to satisfy the CMMC requirements and pass your audit to achieve CMMC certification.
As a managed IT services provider (MSP), Kelser Corporation has years of experience providing compliance support for defense contractors, suppliers, and other organizations to meet various regulations, including DFARS and NIST.
While we recognize that you have options when it comes to the company you choose to help spearhead your compliance process, we encourage you to do your research before entrusting your business to any external IT services company.
We write articles like this because we’re committed to helping businesses succeed, and we want to provide information that can help you make the best IT decisions for your business.
If you need help navigating the compliance maze and you’re unsure where your compliance efforts stand, click the button below to book a no-obligation readiness consultation with a certified CMMC expert.