As the Department of Defense (DoD) continues to implement the Cybersecurity Maturity Model Certification (CMMC) program, defense contractors must be ready for assessments that are now appearing in select contracts. Whether you’re a small business or a prime contractor, preparing for a CMMC assessment is essential to maintaining eligibility for DoD contracts.
Step 1: Know Your CMMC Level
Start by identifying which CMMC level applies to your organization:
Level 1 (Foundational): For companies handling only Federal Contract Information (FCI). Requires 17 basic cybersecurity practices and allows for annual self-assessments.
Level 2 (Advanced): For those managing Controlled Unclassified Information (CUI). Requires compliance with 110 NIST SP 800-171 controls and typically a third-party assessment every three years.
Level 3 (Expert): For organizations working with highly sensitive data. Involves additional controls from NIST SP 800-172 and government-led assessments.
Step 2: Conduct a Gap Analysis
Evaluate your current cybersecurity posture against the required level. A gap analysis helps identify missing or weak controls and sets the stage for remediation. This can be done internally or with the help of a consultant.
Step 3: Implement Security Controls
Once gaps are identified, implement the necessary security measures. Focus on:
Access control and encryption
Incident response planning
Endpoint protection and monitoring
Security awareness training
Regular vulnerability scanning
These controls not only support compliance but also strengthen your overall cybersecurity resilience.
Step 4: Prepare Documentation
Documentation is a critical part of the assessment. You’ll need:
A System Security Plan (SSP) detailing how each control is implemented.
A Plan of Action and Milestones (POA&M) for any incomplete controls.
Supporting policies and procedures for all relevant security domains.
Step 5: Perform a Mock Assessment
Before the official assessment, conduct a mock review to validate your readiness. This includes reviewing documentation, testing control effectiveness, and preparing staff for interviews.
Step 6: Engage a C3PAO or MSP
For Level 2 and above, you’ll need a Certified Third-Party Assessment Organization (C3PAO) to conduct the official assessment. Managed Service Providers (MSPs) can also assist with implementation and ongoing compliance.
Step 7: Explore Funding Support
Small and mid-sized businesses may qualify for funding through programs like the Defense Cybersecurity Assistance Program (DCAP) or Small Business Innovation Research (SBIR) to offset compliance costs.
Bottom line: Preparing for a CMMC assessment is a strategic investment in your organization’s future with the Department of Defense (DoD). Start early, stay organized, and seek expert help when needed to ensure a smooth path to certification.
