Does your organization need CMMC certification?Adarsh Rai
What is CMMC compliance?
The Cybersecurity Maturity Model Certification (CMMC) program was created by the US Department of Defense (DoD) to examine defense contractors’ cybersecurity skills, readiness, and competence. At a high level, the framework is made up of procedures, recommendations, and inputs from current cybersecurity standards, including NIST, FAR, and DFARS. The program‘s primary goal is to improve the trustworthiness and security of Federal contractors’ Controlled Unclassified Information (CUI) and Federal Contract Information (FCI).
Who needs CMMC certification?
The Cybersecurity Maturity Model Certification (CMMC) is being implemented by the Department of Defense to regulate cybersecurity procedures across the federal government’s defense and security industrial infrastructure. These activities are part of a larger effort to safeguard national security in today’s competitive world and improve cyberthreat preparedness. If your organization works as a contractor or subcontractor for the US Department of Defense (DoD), you must plan to meet CMMC requirements in order to bid on and win contracts.
If your organization falls into one of the categories below, it is a good idea to start preparing for your CMMC certification.
Managed service providers (MSPs) and managed security service providers (MSSPs) will be held responsible for upholding CMMC requirements if they portray themselves or their solutions as CMMC as a service offering and are thus liable under the False Claims Act (FCA). If you have access to your client’s data, systems, or network infrastructure and they are part of the DoD supply chain, you will be subject to CMMC and will most likely be expected to demonstrate due diligence and care.
- Prime contractors
Prime contractors are typically larger firms that have a direct correlation with DoD entities. Since primes have access to all of the contract’s sensitive information, they often require a higher CMMC level than subcontractors.
Smaller companies frequently subcontract to prime contractors for completing certain tasks as part of a bigger project. As these products are still covered by the contract, they must conform with CMMC at the appropriate maturity level for the data they manage. Some areas of the project, on the other hand, may demand higher CMMC levels.
Different organizations may supply specific products in support of prime contractors’ DoD contracts, but these suppliers are still part of the DIB. As a result, these sub-tier providers must still meet the requirements for the relevant CMMC maturity level for those items. This maturity level is distinct from the one required of the prime contractor.
- Third party contractors
Companies farther down the supply chain may not even be required to meet the same CMMC compliance standards as the prime contract. The level of compliance with which they must adhere will most likely be governed by how information flows from the primary contract to the third party in question. By October 1st, 2025, all DoD contracts exceeding the $10,000 micro-purchase threshold are mandated to be CMMC certified. By 2025, the Department of Defense is expected to have collaborated with at least 48,000 CMMC qualified contractors.
- Exceptions – (COTS)
Only contacts for COTS (commercial off the shelf) items are currently exempt from meeting CMMC criteria. COTS suppliers should ensure they have level 1 CMMC controls in place, according to experts in the sector, as it would be a reasonable move if the DoD included COTS contracts in future advice, as resellers and distributors come into touch with contract data that could be categorized as sensitive.
How does CMMC apply to non US companies?
The Department of Defense plans to work with overseas partners to establish cybersecurity agreements and ensure that foreign enterprises that serve US warfighters are able to protect critical national security information. These agreements will lay the groundwork for the deployment of CMMC to non-US businesses. The regulatory process will be used to put such agreements into effect.
How much does CMMC certification cost?
As part of the rulemaking process, the Department will publish a complete cost study for each level of CMMC 2.0. Because the Department intends to:
- Streamline requirements at all levels, eliminating CMMC-specific practices and maturity processes.
- Allow companies associated with the new Level 1 (Foundational) and some Level 2 (Advanced) acquisition programs to perform self-assessments rather than third-party assessments.
- Increase oversight of the third-party assessment ecosystem, costs are expected to be significantly lower than in CMMC 1.0.
It is critical for DoD contractors to understand that these are estimates. The final parameters for the CMMC certification expenses are currently being determined. The good news for contractors is that the fee for CMMC certification is reimbursable, not prohibitive. It is an “allowable cost,” or an expense that can be claimed to the Department of Defense.
What if my organization has a breach in CMMC?
Beyond the immediate loss of government funding, the implications of a breach of CUI or other sensitive data have plenty of additional ramifications for companies proven to be negligent. These include everything from being barred from bidding on future government contracts to bad brand awareness resulting from the public disclosure of a breach, to strict government inquiries and fines.
Best practices must be followed outside of your cybersecurity department to avert breaches. All personnel who come into touch with CUI must be instructed on how to properly manage this information in accordance with CMMC. Companies may find it useful to develop a standard template that includes sensitive media examples, CUI element types, categories, and designate indication characteristics for convenient reference and training.
Click here to read more about CMMC from the official documentation by the Department of Acquisition & Sustainment.
CMMC certifies a company’s compliance with best practices in cybersecurity processes and operations. Government agencies and prime contractors can be certain that a prospective contractor will securely store and manage sensitive data.
As it is implemented over the next few years, CMMC accreditation will become increasingly important. It will quickly become a requirement for securing Federal contracts. Preparing for CMMC now will guarantee that your firm has mature cybersecurity policies and processes in place before CMMC assessments begin, putting you in a better position to compete on future Federal contracts and subcontracts.
If your organization functions as a defense contractor with the DOD, and deals with CUI and FCI, you must ensure that the CMMC level data protection requirements are met. Caplock Security offers a broad range of services and solutions to help organizations facilitate change, achieve their vision, and optimize performance and productivity.