If you’re a supplier or subcontractor within the Department of Defense (DoD)’s Defense Industrial Base (DIB), how secure is your environment to safeguard the sensitive federal information you handle or will handle?
How does your current security posture measure up against the National Institute of Standards and Technology (NIST) controls that many defense suppliers are now required to meet in order to obtain CMMC certification?
In Step 1 of the CMMC certification readiness process, you defined your boundaries for scoping the federal contract information (FCI) and controlled unclassified information (CUI) within your environment.
A gap analysis is the next critical step in the process that will reveal how prepared you are to meet CMMC compliance and achieve certification.
In this article, we’ll explore how a gap analysis can help you identify various security weaknesses within your infrastructure that could prevent you from getting CMMC certified.
With this information, you’ll understand how to perform a gap analysis to pinpoint the security vulnerabilities within your IT environment.
You can then implement the proper cybersecurity controls to satisfy compliance and help ensure that you can keep your existing DoD contracts or obtain new ones.
What Are The Key Components Of A Gap Analysis?
A gap analysis is an essential tool that can help you evaluate your current security measures against the cybersecurity requirements for your CMMC level.
CMMC 2.0 sets specific cybersecurity requirements for suppliers to achieve and maintain compliance. The regulation draws on existing cybersecurity frameworks, including NIST and Defense Federal Acquisition Regulation Supplement (DFARS).
CMMC 2.0 differs from those other regulations in that it adds new assessment standards to verify CMMC compliance for federal defense contractors and subcontractors.
Related Article: Step 1 For CMMC Certification: Understanding Your CUI & CMMC Level
So, how do you prepare for a CMMC gap analysis?
Below, we’ll explain exactly what DoD suppliers need to know about a CMMC gap analysis.
Step 1: Review Security Controls For CMMC Compliance
Now that you’ve completed a scope, you should conduct a review of your policies, procedures, and access controls to see how they measure up against the cybersecurity stipulations for your CMMC level.
The three CMMC levels have different cybersecurity requirements, with each level building upon the previous one.
Level 1 organizations at the foundational level need to put in place basic cyber hygiene practices and tools to protect Federal Contract Information (FCI).
Organizations at Level 2 (Advanced), however, must meet both Level 1 controls as well as 110 NIST 800-171 requirements to protect any FCI and CUI they store, process, or transfer.
Level 3 businesses will be expected to satisfy all of the requirements from the two lower levels, plus additional NIST 800-172 safeguards specially for this Expert level.
When reviewing your existing cybersecurity policies and procedures, check to make sure that they’re up-to-date with current best practices, privacy, and cybersecurity regulations.
For instance, do you have established protocols for authorized access to your on-premises data center?
Have you designated an incident response security team with a communication tree to let staff know who should be contacted in the event of a suspected cyber incident?
Does your cybersecurity policy address specific employee responsibilities and prohibitions around equipment usage, internet access, and social media postings—both on premises and while working remotely? Do you require ongoing cybersecurity employee awareness training for all staff?
Your policies and procedures should provide governance and accountability for safeguarding both your physical and virtual assets.
Developing a comprehensive cybersecurity policy will allow you to set expectations around cyber hygiene to help preserve the integrity of your data and reduce the chances of cybercriminals being able to infiltrate your network to steal or compromise your sensitive information.
Related Article: Do I Need A Managed IT Service Provider To Meet CMMC Requirements?
Step 2: Perform A Technical Assessment Of IT Systems
With an established scope, a certified CMMC specialist is able to perform a gap analysis of your IT systems. The gap analysis will use the required CMMC compliance standards for your business to look for any weaknesses within your set boundary.
This technical assessment will examine the specifically identified parts of your environment that store, process, or transmit FCI or CUI, including your employees, data, computers, networking equipment, software, applications, and systems.
By performing a gap analysis, you'll get a comprehensive security audit of your defined perimeter to allow you to identify any security vulnerabilities that fall short of CMMC compliance.
In this way, you can ensure that your FCI and CUI is protected according to the requirements for your CMMC level, without unnecessarily implementing company-wide security measures that could end up being overly restrictive and costly to implement and maintain.
Step 3: Evaluate Your Gap Analysis For CMMC Certification Readiness
Once your gap analysis has been performed, you will receive a detailed report of your gap analysis.
The report will highlight any CMMC cybersecurity deficiencies found within your scope.
With this report, you’ll get a clear picture of your existing security and compliance risks so you know what to prioritize before your official audit by a certified third-party assessment organization (C3PAO).
Level 1 businesses must conduct an annual self-assessment.
Level 2 suppliers and their subcontractors must undergo an assessment every three years. While a select number of Level 2 companies will be allowed to conduct a self-assessment, most will need to undergo a C3PAO audit to get certified.
A federal assessor will perform Level 3 audits every three years.
Step 4: Create A Remediation Plan To Close CMMC Compliance Gaps
Finally, you’ll get a detailed improvement plan to fix compliance gaps efficiently and cost-effectively that's tailored to your business.
An IT professional with cybersecurity and CMMC expertise can provide expert guidance and make informed recommendations on the right tools and resources you should implement.
Related Article: How Zero Trust Can Streamline NIST & CMMC Compliance For Your Business
Some advanced security solutions include:
- Multi-factor authentication
- Network microsegmentation
- Antivirus and anti-malware software
- Domain name system (DNS) and spam filtering software
- Next-generation firewalls
- Endpoint detection
- Network monitoring
- Incident response and reporting
- Software updates and security patches
- Secure data backups
Having a customized remediation plan will help ensure that nothing gets missed, increasing the likelihood of a successful audit and certification.
What Do You Get From A Gap Analysis?
Once the gap analysis audit is complete, a CMMC professional will thoroughly analyze the data to provide you with two critical CMMC compliance tools:
Comprehensive Security Gap Analysis Report:
Following your gap analysis, a CMMC professional will create a comprehensive report giving you a detailed, side-by-side evaluation sheet that shows where you meet CMMC requirements and where you fall short.
Prioritized Remediation Plan:
With your security gap report in hand, you’ll then get a step-by-step roadmap to fix security weaknesses and ensure you’re fully prepared before your cybersecurity compliance audit.
Based on your gap analysis, this plan will spell out the specific recommended remediation security tools and systems needed for your business to become CMMC compliant.
Why Does A Gap Analysis Matter For CMMC Compliance?
A gap analysis is an essential part of the CMMC compliance journey that cannot be overlooked because it takes the guesswork out of identifying security vulnerabilities within your IT environment.
Used as a CMMC 2.0 security posture guidebook, a gap analysis allows you to measure your current security defenses against the CMMC requirements for your level. You can then implement necessary safeguards to fix those security issues.
In this way, a gap analysis helps you plan, budget, and allocate your resources efficiently to remediate high-risk cybersecurity flaws so you can move through your CMMC certification process with confidence.
Without this step, you could be making faulty assumptions about your cybersecurity compliance readiness, which could lead to:
- missed security vulnerabilities that could compromise your CMMC certification
- unnecessary spending on security tools or resources you don’t actually need
- flagged security measures that don’t meet the security requirements for your level, leading to delays and potential C3PAO audit failures
The Bottom Line On How A CMMC Gap Analysis Helps Your Compliance Readiness
After reading this article, you now understand how completing a CMMC gap analysis will help you recognize the cybersecurity weaknesses within your organization and the steps you should take to remediate them.
With a gap analysis, you’ll have a clear understanding of how your security defenses stack up against the required CMMC cybersecurity standards to improve your compliance readiness.
If you still have questions, or you need help with your gap analysis, don’t hesitate to reach out —we’re here to guide you every step of the way.
Let’s work together to make sure that your business is prepared, secure, and compliant so you can keep your DoD contracts or win new ones.
