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CMMC Certification: Your Guide to Success

Ola Sage, a leading figure in the CMMC (Cybersecurity Maturity Model Certification) ecosystem, provides valuable insights on the path to meeting this industry-wide cybersecurity standard. According to Sage, if you’re pursuing CMMC for your organization, it’s crucial to stay ahead of the curve. (Washington Technology October 4, 2023)

DOD’s Commitment to CMMC Implementation

Over the past two years, the Department of Defense (DOD) has been diligently addressed concerns surrounding the complexity, cost, and necessity of CMMC. certification. This dedicated effort is driving a projected rulemaking for CMMC implementation in early 2025. Despite potential obstacles such as government shutdowns and inspector general accreditation audits, DOD remains unwavering in its pursuit of this goal. (ibid)

It’s essential for contractors to understand that waiting for updates or guidance isn’t an option. Navigating the 110 security controls integral to CMMC certification typically requires 12 to 18 months. When the rulemaking process concludes, uncertified contractors risk losing their ability to contract with the DOD as primes or subcontractors. This puts existing contracts and future proposal opportunities at risk. (ibid)

CMMC Certification’s Impact on Your Business

CMMC certification holds immense potential for an organization. Certified companies not only retain existing business but also build a reputation within the industry. Moreover, they gain access to a broader spectrum of DOD contracts, especially as civilian agencies adopt CMMC. (ibid)

Conversely, non-certified companies face serious challenges. They can’t bid on proposals that require CMMC compliance, and critical flaws may necessitate restarting the certification process. More significantly, they risk losing current contracts, leading to revenue loss, cybersecurity talent attrition, and strained relationships with partners like banks and insurers. (ibid)

Prepare for CMMC: Sooner is Better

While fiscal year 2025 might seem distant, it’s prudent for DOD contractors to act as if CMMC compliance is just around the corner.

Communication Within Your Supply Chain

Although much attention focuses on prime contractors, it’s crucial to remember that CMMC compliance extends to every level of the supply chain, including the smallest subcontractors. A minor mistake or an employee’s lapse can lead to disastrous consequences, risking contracts worth millions. (ibid)

DOD is set to mandate the inclusion of CMMC in contractual flow clauses. Many prime contractors send letters to inform their supply chain partners about impending CMMC requirements and the need to comply. However, smaller contractors less familiar with regulatory intricacies may perceive this as additional bureaucratic paperwork. (ibid)

Therefore, high-tier contractors must stress the importance of compliance and cultivate trust. This involves using authorized assessors and certified CMMC professionals, ensuring that companies claiming ecosystem participation are officially registered. (ibid)

Another critical step is understanding your subcontractors’ status in the approval process. Larger prime contractors may find it worthwhile to invest in mock assessments for their subcontractors to assess potential risks. Supporting smaller subcontractors with limited resources may entail sharing best practices, offering expert assistance, or providing secure storage facilities. (ibid)

Three Paths to CMMC Certification

Preparing for CMMC certification necessitates a strategic approach based on your expertise, time constraints, and finances. Here are three viable paths:

  1. Internal Implementation: Begin by downloading a version of NIST 800-172a to guide your internal team in implementing the 110 controls of NIST 800-171. This approach requires a certain level of technical knowledge within your team.
  2. Hiring a Registered Practitioner Organization (RPO): Organizations seeking specialized expertise can hire an RPO, despite the potentially higher cost.
  3. Hybrid Approach: Combine internal and external support, allowing your internal team to handle some aspects while engaging external consultants for others. (ibid)

Whichever approach you choose, initiating your preparations now is essential, as addressing all 110 controls typically requires 12-18 months. When ready, engage an authorized CMMC Third Party Assessment Organization (C3PAO). Most C3PAOs offer mock assessments to identify areas that may need further attention, followed by an official assessment that provides a formal result. (ibid)

An Accelerated Option for DOD Contractors

DOD contractors can accelerate their CMMC certification journey by leveraging the Pentagon’s interim Joint Surveillance Voluntary Program. This program offers a voluntary NIST 800-171 assessment conducted by a C3PAO in collaboration with the Defense Industrial Base’s Cybersecurity Assessment Center. DOD’s intent is to grant Level 2 certification for three years to contractors who successfully pass this rigorous assessment. However, this voluntary program will only remain available until rulemaking is finalized. (ibid)

CMMC 2.0: Are You Ready?

With over 300,000 contractors under the Department of Defense’s umbrella, cybersecurity is paramount. National security doesn’t wait for government operations, election results, or inspector general audits. That’s why DOD leadership is pushing for CMMC rulemaking finalization. Becoming CMMC-compliant is not just a defense against security threats but also an effective offensive strategy to secure your business’s future. (ibid)

Are you prepared for CMMC 2.0? Give us a call.