CMMC 2.0 Is Here: What You Need to Do Now to Stay Compliant

Since 2019, the Cybersecurity Maturity Model Certification (CMMC) has served as an important guideline for Department of Defense (DoD) contractors and subcontractors, helping them maintain proper security controls and protect sensitive government information.

With the introduction of CMMC 2.0 last year and its implementation in the coming months, anyone working with DoD contracts must stay on top of the changes and be ready to up their cybersecurity. Today's post will cover the basics of what you need to do to stay compliant and face CMMC 2.0 with confidence.

What Is CMMC 2.0?

The Cybersecurity Maturity Model Certification (CMMC) is a framework that outlines the cybersecurity measures businesses need to implement to qualify for DoD contracts. The certification creates a clear standard and helps indicate that a business is prepared to protect sensitive government information.

CMMC 2.0 is a revised version of the original CMMC, and it aims to make certification more streamlined, scalable, and flexible with the following main changes:

• Reduction from 5 levels to just 3.

• Self-assessments for all level 1 contracts and some level 2 contracts.

• Greater alignment with standards outlined in NIST 800-171 and NIST 800-172.

Who Needs to Comply?

CMMC 2.0 applies to any contractors or subcontractors involved with the DoD. Businesses working with federal contract information (FCI) are generally required to achieve a level 1 certification, while organizations handling controlled unclassified information (CUI) need to meet either level 2 or level 3 requirements, depending on the type of data they work with.

If you already have a DoD contract or are hoping to secure one soon, it's important to understand what kind of information you handle (or will be handling). This way, you can start working towards implementing the right security controls. If you're unsure which level applies to you, talk with a compliance specialist to ensure you're on the right track.

How Can I Prepare for CMMC 2.0?

The best way to prepare for the full implementation of CMMC 2.0 is to take action early. Here are five key steps you should take as soon as possible to start moving towards compliance.

1. Identify Your Certification Level

Determine which CMMC 2.0 certification level your organization needs based on the type and sensitivity of the data you work with. This will help you focus your compliance efforts and know what specific changes you need to make in your organization.

2. Conduct a Gap Analysis for NIST 800-171

Assess your current cybersecurity controls against the NIST 800-171 and NIST 800-172 requirements to identify any gaps. With a clearer understanding of where you stand with these regulations, you'll know what actions to prioritize to close those gaps effectively.

3. Document SSPs and POA&Ms

A System Security Plan (SSP), which is required for levels 2 and 3 of CMMC 2.0, outlines your current cybersecurity practices and is consistently updated to show your progress. A Plan of Action and Milestones (POA&M) details steps for meeting any requirements that aren't currently being fulfilled. Both documents will help track your compliance efforts and be ready for audits.

4. Strengthen Your Cybersecurity Posture

Review and improve your internal cybersecurity policies and procedures, ensuring they align with CMMC 2.0 standards. Work on building a strong culture of security awareness among your team, and implement software and procedures that will keep your systems secure.

5. Work with a RPO or Certified CMMC Assessor

A Registered Provider Organization (RPO) can help you understand CMMC 2.0 requirements and how they'll look in your business, providing you with specific, guided preparations. Once you're ready to receive your certification, an official, certified assessor can run an audit and confirm whether or not you're compliant.

What Are Some Common Mistakes Businesses Make?

As you navigate the complexities of CMMC 2.0, be careful to avoid these common traps:

• Don't wait too long to start implementing new procedures and preparing for your CMMC 2.0 certification. Deadlines will come more quickly than you think!

• Don't underestimate how much time, effort, and resources are necessary for remediation and documentation of your compliance efforts. Give yourself plenty of time to get everything done.

• Don't assume you qualify for a self-assessment, especially if you are working towards level 2 compliance. Double-check with your compliance consultant and make sure you don't need an official third-party assessment to get your certification.

• Don’t overlook supply chain risk management requirements. Make sure your vendors and contractors are also maintaining high cybersecurity standards so that the sensitive DoD data you handle isn't indirectly exposed or put at risk.

How Can a Compliance Partner Help?

Compliance is a big job with a lot of moving parts. Between updates to complex regulations and changes within your own business, it's helpful to have consistent, continual support for the implementation of new policies and procedures, remediation to meet standards, and certification assessments.

Your compliance partner can provide expertise about compliance regulations, your industry, and your business; help you make detailed plans and roadmaps; and streamline your compliance efforts. They can also provide continuous monitoring and updates to ensure your security posture stays consistent with CMMC 2.0.

Conquer CMMC 2.0 with ICS

CMMC 2.0 compliance might seem a bit overwhelming, but ICS is here to make things simple and stress-free. With the help of our compliance experts, you can work through complex regulations, maintain proper documentation, and prepare for your certification with confidence. Give us a call to talk about CMMC 2.0 and what it means for your business.