CMMC Coming to Solicitations

Cybersecurity Maturity Model Certification (CMMC) requirements may show up in solicitations within six months. (GOVCONWire, May 12, 2020)

A Department of Defense spokesperson expects about 10 DoD RFIs in June to include the new requirements. She said, “As we release the RFIs, we’ll have the certified and trained auditors who will be able to go out to industry and certify companies at the level of maturity required for the work that they’re bidding on.” (ibid)

Additionally, changes to the Defense Federal Acquisition Regulation Supplement 252.204-7012 should be finalized by October. “You will not see the CMMC in any Department of Defense contracts or RFPs until the rule change is completed.” (ibid)

Questions on the Cybersecurity Maturity Model Certification and whether you can bid on upcoming solicitations? Give us a call.

CMMC not for COTS

A recent modification to DoD’s website spells out a small but very specific change about the Cybersecurity Maturity Model Certification (CMMC): it’s not applicable to DoD suppliers that only provide commercial-off-the-shelf products. (FedScoop, May 5, 2020)

Originally, DoD and CMMC administrators explained that all contractors and subcontractors must be certified under  CMMC by a third-party assessor. However, a few weeks ago, the Office of the Under Secretary of Defense for Acquisition and Sustainment changed the official website. The revised FAQ section states: “Companies that solely produce Commercial-Off-The-Shelf (COTS) products do not require a CMMC certification.” (ibid)

CMMC is in place to certify contractors have the cybersecurity practices in place to work with controlled unclassified information, the actual products themselves. (ibid)

Wondering if CMMC applies to the products and or services you provide? Give us a call.

New Cybersecurity Certification Requirements

The Office for the Under Secretary of Defense and Sustainment (OUSD (A&S)) recently released its Cyber Security Maturity model Certification (CMMC). DoD stakeholders, University Affiliated Research Centers (UARCs), Federally Funded Research and Development Centers (FFRDCs) and the Defense Industrial Base (DIB) all had a hand in developing the CMMC model. This model measures cybersecurity maturity using five levels (from basic to advanced) and aligns a set of processes and practices with the type and sensitivity of the information to be protected and any associated threats to that information. (CMMC Model v1.0, January 30, 2020)

DoD’s CMMC enhances the protection of:

  • Federal Contract Information (FCI) provided or generated by the government, but not intended for public release
  • Controlled Unclassified Information (CUI), which requires safeguarding or dissemination consistent with laws, regulations and government-wide policies. (ibid)

The CMMC model includes the safeguarding requirements for FCI spelled out in FAR clause 52.204-21 and the security requirements for CUI stated in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 per DFARS clause 252.204-7012 [3,4,5].

Included in the CMMC model is a certification piece verifying the implementation of cybersecurity maturity measure processes and practices. This is intended to deliver assurance to the DoD that contractors and subcontractors can sufficiently protect CUI at a level equal to the risk. (ibid)

To obtain a full overview of the CMMC Model, domains, practices, and processes, please review the Cybersecurity Maturity Model Certification.

Have questions about the effect on your current contract or one in works? Give us a call.

CMMC a Plus for Small Businesses?

Katie Arrington, on staff  with the Undersecretary of Defense for Acquisition and Sustainment believes nation-states are actively targeting small businesses digitally. And, she says, we are losing the battle of cyberattacks. (Fifth Domain, October 8, 2019)

According to Arrington, rivals cost the US an estimated $600 billion per year and 5G will multiply that number exponentially by 2025. As a result, Arrington believes the cybersecurity maturity model certification (CMMC) is actually intended for small businesses. (ibid)

CMMC grades company cybersecurity on a scale of one (least secure) to five (most stringent). Small businesses must comply with a tiered rating structure. So a company offering cleaning services may need only comply with CMMC level one while an engineering firm is held to level four

Arrington says that CMMC levels the playing field. Old compliance standards allowed companies to perform their contracts while working on their plan of action to become technically acceptable. This left sensitive systems that require additional security controls vulnerable and with weak spots. Many small businesses do not have the resources to obtain a high CMMC level, ultimately limiting competition in the marketplace; others fear the costs will be so high, that small companies will be priced out of the marketplace and limit their ability to compete on government contracts. 

The most recent Navy breaches targeted contractors without classified information per se, but taken in total the data disclosed sensitive capabilities. This is exactly what the CMMC framework addresses. (ibid)

Requests for proposals are expected to include CMMC requirements, as early as fall 2020.

Questions about CMMC requirements? Give us a call.

CMMC RFI

The Department of Defense (DoD) has issued a request for information for the “long-term implementation, functioning, sustainment, and growth” of the Cybersecurity Maturity Model Certification (CMMC). (FedBizOps.gov, October 3, 2019)

Last month, DoD issued version 0.4 of the CMMC. Contractors may now see the cybersecurity standards required when working on projects with controlled but unclassified information. CMMC will assist DoD to secure more than 300,000 organizations. (Fed Scoop, October 4, 2019)

The accreditation body does not directly perform the assessments but manages third-party organizations that do. It is  a nonprofit that utilizes “revenues generated through dues, fees, partner relationships, conferences, etc.” to fund the work.  The deadline to submit feedback is October 21, 2019. (FedBizOps.gov ibid)

We’d be glad to discuss this RFI with you. Just give us a call.