As a Department of Defense (DoD) contractor or subcontractor within the Defense Industrial Base (DIB), you're likely wondering when you'll get to the finish line in your race to become compliant with the Cybersecurity Maturity Model Certification (CMMC) 2.0 requirements.
To be sure, getting certified will be a major milestone in the lengthy, challenging, and costly CMMC compliance process. Certification is your ticket to keeping your current contracts and staying eligible to win new ones.
But once you've reached that point, what comes next?
Your compliance journey doesn’t end when you become compliant. Nor does it end once you successfully pass your CMMC assessment and achieve final certification.
In this article we’ll discuss why ongoing compliance support is necessary even after you become certified. We’ll also outline the steps we take at Kelser to ensure that you remain compliant and are positioned to streamline the process for future assessments.
With this information, you’ll understand how staying compliant can help strengthen your relationship with the DoD and give you a competitive advantage within the marketplace.
As you know, the DoD developed the CMMC 2.0 Final Rule to establish a uniform way to ensure that DIB primes and subcontractors were doing everything possible to protect the federal contract information (FCI) and uncontrolled classified information (CUI) they store, process, or transmit.
To do this, the government developed a CMMC certification process that splits these businesses into three levels, requiring tougher security controls and assessment requirements for each ascending level.
Related Article: Understanding Your CMMC Audit: Here's What You Can Expect
Level 1 businesses, considered the Foundational level, must meet 17 basic cyber hygiene practices taken from the Federal Acquisition Regulation (FAR) 52.204-21 and perform a self-assessment as evidence that they’ve met compliance.
Level 2 businesses, the Advanced level, must satisfy 110 security controls organized in 14 control families from the National Institute of Standards & Technology (NIST) SP 800-171 to safeguard the FCI and CUI they handle.
These businesses are required to get audited every three years. While a few Level 2 businesses will be allowed to perform a self-assessment, most will need to get audited by an approved certified third-party assessor organization (C3PAO) to become certified.
Related Article: How To Find An Approved C3PAO For Your CMMC Level 2 Assessment
At the Expert level, Level 3 businesses are responsible for combating advanced persistent threats (APTs). Because of the highly sensitive, but not secret, federal information they handle, Level 3 organizations must meet the most stringent cybersecurity requirements of the three levels.
Level 3 businesses are required to get assessed by federal auditors every three years.
Regardless of the level, all DIB contractors need to self-attest their ongoing compliance every year following a formal assessment.
To add weight to the self-attestation process, the regulation states that businesses will need to designate a senior executive within their organization to sign off confirming that the organizations remains compliant.
The official must then submit the self-assessment and signed attestation to the DoD through its Supplier Performance Risk System (SPRS) portal.
Self-attestation is essentially when contractors and subcontractors affirm to the federal government that their businesses are continuing to follow the security mandates of the CMMC security framework.
Annual self-attestation is mandatory to maintain your certification.
This requirement allows the government to further strengthen its supply chain against evolving cybersecurity threats and ensure the ongoing security and integrity of its sensitive data.
This part of the CMMC compliance requirements is designed to:
As we've stated, while achieving CMMC certification is the key end goal, it does not represent the end of your compliance journey. In fact, compliance is a continual process.
As part of our CMMC readiness roadmap, Kelser delivers customized guidance to help you maintain both your security posture and your CMMC certification.
Here’s what we offer:
First, we thoroughly review your security policies, procedures, tools, protocols and other resources to verify that they’re up-to-date and accurately reflect your assessment boundary.
This will include a thorough examination of your system security plan (SSP). Your SSP is a crucial document that details your organization’s comprehensive cybersecurity strategy.
Related Article: CMMC Step 4: SSP Documentation–What’s Your CMMC Compliance Evidence?
It encapsulates all of your documentation and the specific security controls you’ve adopted to protect the sensitive federal information you handle.
Regularly reviewing your records and documentation and keeping them up-to-date is critical to staying compliant since your SSP serves as the blueprint for the robust compliance guardrails you’ve put in place.
We will evaluate any changes to your environment, such as any new hires, devices, software, or systems you’ve added since your CMMC assessment.
This review will verify that any newly added elements that fall within your defined assessment boundary satisfy compliance standards for your level. Then, we’ll ensure that your compliance documentation is updated to reflect these changes.
We may also offer expert advice and make recommendations for strategic investments in additional hardware, software, or other tools that meet CMMC compliance and streamline future CMMC compliance for subsequent assessments.
This allows you to take advantage of new technologies that could help boost your network performance, maximize uptime, offer more robust safeguards against threat actors, or reduce costs.
As part of our recommendation of such tools, services, or equipment, we would of course confirm that they meet CMMC compliance requirements. With such strategic investments, you can leverage your technology to maintain the safety and integrity of the federal data you handle.
Just as technology is rapidly evolving, cybersecurity regulations are also frequently adapted to try to keep pace with the constantly changing threat landscape.
Our IT experts will use their broad industry and regulatory knowledge to keep you informed about any changes to the CMMC framework that could impact your security measures or assessment requirements.
This will not only help you stay compliant, but it could also potentially prevent you from failing a subsequent audit because you didn’t meet the changed requirements.
As part of doing business with the DoD, you’re required to submit your supplier performance risk system (SPRS) score regularly.
The frequency depends on your CMMC level. For Level 2 businesses, you must update your SPRS score every year to ensure accuracy. It must then be submitted into the SPRS database.
Since your SPRS score essentially serves as your report card, this mandate is a key part of maintaining good standing with the DoD. The database lets the government track your performance, compliance, quality of service, prices, and other metrics.
With this information, the DoD is able to evaluate your company compared to other businesses within its supply chain and assess its risk in doing business with you.
As a managed IT service provider (MSP, we can help you submit your SPRS, and make targeted recommendations to help you boost your score.
We’ll ensure that you’re providing regular employee cybersecurity awareness training to your entire team. Since human error is the leading cause of data breaches, including phishing attacks, educating your staff about cybersecurity is a major part of both reducing risk and maintaining compliance.
Providing training that includes real-world modules helps ensure that your employees are informed about the latest cyber threats, how to spot them, and best practices to avoid falling prey.
This also gives you an opportunity to inform new hires about your security policies and procedures and serve as a reminder to other staff.
Such training is essential to developing a culture of cybersecurity in the workplace to promote awareness, foster employee ownership and accountability, mitigate risks, and ensure ongoing adherence to your compliance security measures.
After reading this article, you now understand that achieving final CMMC certification isn’t the end of your compliance journey. Rather, staying compliant is an ongoing process.
You’ve done the hard work—spending considerable time and money to become CMMC compliant. Now is not the time to let your guard down.
Related Article: How to Cut CMMC Compliance & C3PAO Audit Costs: Grants, MSPs & More
Ensuring rigorous adherence to your cybersecurity controls allows you to boost your security posture, stay compliant, maintain your certification, and continue doing business with the Department of Defense.
With managed IT services, you gain a deep bench of IT professionals with specialized skills, without the high cost of hiring and maintaining an internal team.
Regardless of the MSP you choose, we recommend that you research several providers to help ensure you pick one with the qualifications and know-how to get you to the CMMC finish line and be there to support you after you've crossed it.
While we know you have options, as a managed IT services provider (MSP), Kelser has decades of experience helping other small and medium-sized businesses like yours meet various regulatory cybersecurity requirements.
We’ll be there to guide you every step of the way through your compliance journey, from start to finish—and even after that.
Do you know where you are in the CMMC compliance process? If not, click the button to schedule a no-obligation readiness consultation.