The Cybersecurity Maturity Model Certification (CMMC) is a new cybersecurity framework by the US Department of Defense (DoD) for the DoD supply chain and its contractors. The goal of the new CMMC compliance requirement is to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
This new umbrella standard includes requirements from NIST SP 800-171, the Federal Acquisition Requirements (FAR) document 52.204-21, and beyond. In the latest iteration CMMC 2.0 which was announced on November 4th, 2021 there are three levels of CMMC compliance. Each level requires more practices and controls than the previous. Most organizations will have to comply with either Level 1 or Level 2.
Who Needs CMMC Certification?
Only contracts for Commercial off-the-shelf (COTS) products will be exempt from CMMC compliance requirements.
Any company and its subcontractors that bid on a DoD contract that contains Federal Contract Information (FCI) and/or Controlled Unclassified Information (CUI) will be required to be CMMC compliant.
Which Level of CMMC Will We Need?
The CMMC level mandated will be stated in the contract information. The majority of contracts will require a Level 1 or Level 2 compliance.
As a general rule:
- If your company will receive exclusively FCI under the contract, then your will need CMMC Level 1 implementation and certification.
- However, if your organization will receive CUI in addition, then CMMC Level 2 will be required as a minimum.
For more details about the different CMMC Levels and the assessment requirements see: CMMC Compliance Levels in CMMC 2.0.
Depending on the CMMC Compliance Requirements you will need to comply with, the implementation and compliance status will be verified via a self-assessment that needs to be submitted to the SPRS, a Certified 3rd Party Assessor Organization (C3PAO), or DOD officials. While the outside assessments will be valid for three years, any self-assessments will have to be conducted annually and need to be accompanied by an annual affirmation from a senior company official that the company is meeting requirements.
When Will This Be Required?
The DoD had started rolling out CMMC 1.02 compliance requirements for a few pilot contracts beginning of 2021. However, due to the significant changes in the latest CMMC 2.0 iteration, the DoD suspended any CMMC requirements for new contracts until the rulemaking process for CMMC 2.0 is completed. In May 2022 CMMC director Stacy Bostjanick announced that the Pentagon plans to publish the CMMC ‘interim rule’ in early 2023, with initial requirements showing up in DoD contracts starting in May 2023.
In the meantime, DFARS 252.204-7012 and -7019 are still in effect and require each organization to have a
- NIST SP 800-171 Assessment performed, the
- resulting score submitted to the SPRS, and a
- System Security Plan (SSP) as well as a
- Plan of Actions & Milestones (PoA&M) document in place.
New DoD contracts might have minimum requirements for the organization’s NIST SP 800-171 assessment score.
Although the CMMC compliance requirements are still several months away, we highly recommend that companies who plan to bid on DoD contracts start preparations for their CMMC assessment now. The early adopters of CMMC will have a clear competitive advantage – especially considering that implementation will take several months and compliance is required at the time of contract award.
Currently, the DoD is discussing different incentives for those companies that become compliant before CMMC is mandatory. After years of delays, the CMMC rulemaking process seems to be on track and the latest update by CMMC director Stacy Bostjanick indicated that it is progressing faster than initially announced. Considering the upcoming May 2023 date (revised from July 2023) for CMMC contract requirements we expect a rush with the availability of the C3PAOs becoming a bottleneck. In other words – it’s time to get ready sooner than later.
How Long Does It Take to Implement CMMC?
The implementation time frame depends on these main factors:
- The level of certification you are required to comply with
- The current state of your NIST SP 800-171 implementation
- The size and scope of your system.
For example, after an initial Gap Analysis, it will take most organizations 6-12 months to achieve CMMC Level 2 compliance and to be ready for the certification assessment. CMMC Level 1 compliance can be accomplished in a much shorter time frame.
What Is the CMMC Cost?
The cost of achieving CMMC compliance depends on the same factors listed above. You have to consider expenses for these steps:
- Support by companies that help with the preparation and implementation
- CMMC implementation cost
- CMMC Assessment by a CMMC Third-Party Assessor Organization (C3PAO) if you are required to do so (CMMC Level 2 and Level 3)
There will be ongoing expenses in addition to the initial cost of becoming compliant.