CMMC Compliance Support: 5 Tips for Maintaining Your CMMC Compliance Status

EXECUTIVE BRIEF

Achieving Cybersecurity Maturity Model Certification (CMMC) compliance is at the top of mind for defense contractors,  but investing in tools and resources to sustain compliance is equally important. This article provides five tips to maintain your compliance posture, including:

• Continuous Monitoring: Regularly assess vulnerabilities and implement automated monitoring tools like SIEM, EDR, and vulnerability scanners. 
• Stay Ahead: Regularly conduct training programs for your workforce to ensure everyone understands cybersecurity best practices.
• Perform Regular Gap Analysis: Regularly evaluate your cybersecurity posture by identifying control effectiveness, documenting policies, and conducting inventory & assessment of controls. 

Dig deeper and continue learning below! 

Once you’ve managed to achieve compliance with the U.S. Department of Defense (DoD)’s (also known as the Department of War) CMMC requirements, how do you maintain it?

The CMMC framework protects sensitive information, ensuring the DoD maintains secure and resilient supply chains. Achieving compliance with CMMC requirements is no small feat, but the real challenge lies in consistently maintaining that status. If you’re looking for some CMMC help, here are five practical tips to help you stay CMMC-compliant and confidently win contracts for your business.

The Purpose and Scope of CMMC  

CMMC was created to safeguard Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) handled by defense contractors. As cyber threats become increasingly sophisticated, protecting sensitive data is paramount for national security. Compliance with CMMC standards ensures contractors have adequate cybersecurity measures to prevent unauthorized access and data breaches. However, attaining compliance isn't merely a one-time event; it's an ongoing commitment to maintaining and enhancing cybersecurity practices. Contractors are regularly re-assessed, especially at CMMC Level 2 and CMMC Level 3. 

Who Needs CMMC Certification?

All organizations involved in DoD contracts will need to comply with CMMC requirements at some point, including subcontractors. The certification demonstrates your ability to protect sensitive information and aligns you with the DoD's expectations for handling CUI and FCI. For DoD contractors, maintaining CMMC compliance is not just about meeting regulatory requirements—it's required to remain eligible for future contracts.

5 Tips to Maintain CMMC Compliance

Tip 1: Implement Continuous Monitoring

By regularly assessing your cybersecurity requirements and identifying potential vulnerabilities, you can proactively address issues before they escalate. Implementing automated monitoring tools and processes helps ensure your organization complies with CMMC standards and can quickly respond to emerging advanced persistent threats and cyberattacks. Some examples of monitoring tools include:

• Security Information and Event Management (SIEM) Systems: SIEM tools collect and analyze security data in real-time. These tools aggregate logs from across the network, identifying anomalies that could signal a breach. Configuring alerts based on CMMC’s specific security controls can help your team act quickly on compliance-related incidents.
• Endpoint Detection and Response (EDR) Solutions: EDR solutions monitor devices across your network continuously. These tools actively scan endpoints for unusual activity, helping ensure that CMMC requirements around device security and activity monitoring are met. They can also automate responses to contain threats before they spread.
• Automated Vulnerability Scanners: These tools scan your  system for vulnerabilities and misconfigurations - catching weaknesses that violate CMMC standards, such as outdated software or open ports. Integrating these scanners with your SIEM helps prioritize remediation efforts by alerting you to high-risk vulnerabilities.

Tip 2: Keep Up with CMMC Updates

The CMMC framework is subject to updates and revisions, which may impact your organization's compliance status. To stay informed and adapt your practices accordingly, subscribe to relevant industry newsletters, participate in webinars, and engage with professional organizations. For instance, you can find regular updates on ISI’s Insights page.

Tip 3: Conduct Regular Training

Foster a culture of security awareness by educating your workforce on cybersecurity best practices and the importance of adhering to the latest cybersecurity standards. Implementing training programs and providing resources for employees helps ensure everyone in your organization understands their role in your system security plan. Some recommended training programs include:

• Cybersecurity Awareness Training: KnowBe4 or Proofpoint Security Awareness platforms offer comprehensive training and simulated phishing exercises. These tools test employee responses and reinforce awareness of common threats.
• Role-Based Security Training: SANS Institute or CyberVista offers role-specific modules that align with CMMC, providing detailed, practical instruction based on employees' access levels and responsibilities.
• Incident Response and Reporting Training: Cybrary for Incident Response or customized tabletop exercises can emphasize prompt reporting and provide hands-on exercises for managing incidents, a critical component of CMMC compliance.

Tip 4: Perform Routine Gap Analysis

Conducting routine gap analyses is essential for identifying vulnerabilities and addressing areas of non-compliance. By regularly evaluating your organization's cybersecurity posture, you can pinpoint weaknesses and implement targeted remediation strategies. Some key components of these gap analyses include:

• Inventory and Assessment of Current Controls: Using a tool like FutureFeed or Microsoft Compliance Manager, automate the inventory process, capturing configurations, policies, and user access rights to verify alignment with specific CMMC domains.
• Control Effectiveness Testing: Run tests for multi-factor authentication (MFA), data encryption, and access controls to identify weaknesses that may hinder compliance. Then, rank findings by risk level for prioritized remediation.
• Documentation and Policy Review: Compare your incident response plan, user access policies, and training records against CMMC Level 2 standards, identifying missing or outdated documentation.

Tip 5: Leverage Managed Services

Managed services providers offer specialized knowledge and resources to support your organization's continued information security efforts. By partnering with a managed services provider, you can alleviate the burden of managing compliance internally and focus on your core business operations.

Best Practices for Integrating CMMC Compliance into Business Operations

Integrating CMMC compliance into your daily operations involves embedding cybersecurity practices into your organization's culture and workflows.

Preparing for a CMMC Audit  

Preparing for a CMMC audit involves understanding the assessment process and gathering the necessary documentation to demonstrate compliance. By familiarizing yourself with the audit requirements and establishing clear procedures for documenting your cybersecurity practices, you can streamline the audit process and reduce the risk of non-compliance.

Partnering with Cyber AB Approved Assessors for Certification

Partnering with CMMC Third-Party Assessment Organizations (C3PAOs) is essential for successful CMMC certification at Level 2 or 3. These compliance experts are trained to evaluate your maturity level and your organization's compliance with CMMC standards. They provide guidance on achieving and maintaining your certification level. Selecting a reputable and experienced C3PAO is crucial for a smooth certification process and ongoing support.

Establishing a long-term partnership with your C3PAO is also extremely beneficial. These professionals can provide ongoing support and updates on any changes to security requirements, helping you stay ahead of potential challenges. By fostering a strong relationship with your assessor, you ensure that your organization remains compliant and capable of meeting the evolving demands of the DoD.

Challenges in Maintaining CMMC Compliance and How to Overcome Them

Costs of CMMC Certification

CMMC certification, of course, has specific financial implications. You can allocate resources effectively and minimize financial strain by estimating the costs of achieving and maintaining certification. Consider assessment fees, personnel training, and technology upgrades when budgeting.

Resource and Technological Challenges

Investing in the necessary tools and technologies, such as automated monitoring systems and cybersecurity training programs, can help you overcome obstacles and ensure compliance. Consider reallocating resources or engaging a Registered Provider Organization (RPO), such as ISI, to support your efforts.

Timelines for CMMC Implementation

By familiarizing yourself with the expected timelines for achieving and maintaining certification, you can develop a strategic plan to ensure that your organization remains compliant and avoids disruptions to business operations.

• The CMMC Marketplace, which allows assessments to start, was activated on December 16, 2024.
• CMMC contract requirements are set to begin appearing in contracts on November 10, 2025, and will be rolled out in phases over a three-year period. 

• The first phase of CMMC contract requirements will apply to Level 1 (Self-Assessment) and Level 2 (Self-Assessment).
• Level 2 (C3PAO) contract requirements will largely be rolled out in Q4 2026. However, the DoD and prime contractors can introduce these requirements as early as Q4 2025 for specific contracts.

Ensuring Continuous Compliance and Updating Your Practices

Maintaining CMMC compliance over time requires a proactive approach to monitoring and updating your practices. Regularly reviewing your organization's cybersecurity posture and implementing necessary changes can ensure that your practices remain aligned with CMMC standards and prepared for future assessments.

The Future of CMMC and Its Impact on the Defense Industrial Base

As the CMMC framework evolves to address emerging cybersecurity threats and challenges, there will be ongoing updates and advancements. The most significant foreseeable change will be switching standards from NIST SP 800-171a Rev2 to Rev3. By staying informed about potential changes and preparing for future developments, your organization can remain compliant and competitive in the defense industry.

CMMC is critical in enhancing defense supply chain security and resilience by ensuring organizations maintain robust cybersecurity practices. Certification demonstrates your commitment to cybersecurity and aligns you with the DoD's expectations. Achieving and maintaining compliance enhances your organization's reputation, differentiates your organization from competitors, and contributes to your overall business success.

Partnering with a CMMC compliance service organization, such as ISI, can provide valuable insights and support. By leveraging our expertise and resources, your organization can attest to compliance, remain compliant, prepare for future challenges, and position itself for growth and success in the DIB.

FAQs about CMMC Compliance Support

What Are the Differences Between CMMC and Other Cybersecurity Frameworks?

The key difference between CMMC and other cybersecurity frameworks is their purpose. CMMC was developed to certify whether a contractor has implemented previously mandated cybersecurity requirements, specifically the National Institute of Standards and Technology Special Publication 800-171 (NIST SP 800-171). In that sense, it is closely connected to other cybersecurity requirements such as the Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012. But its role in verifying and certifying contractors before awarding defense contracts is unique. Other standards, such as International Organization for Standardization (ISO) 27001, focus on general information security management, whereas CMMC is tailored specifically for the defense sector.

How Often Will My Organization Need to Be Reassessed for CMMC Compliance?

Organizations must undergo periodic reassessment to maintain CMMC compliance, though the type and frequency depend on your CMMC level. Level 1 organizations are expected to complete annual self-assessments. Level 2 (C3PAO) organizations must undergo a triennial third-party assessment by a certified C3PAO and provide annual compliance affirmations. CMMC Level 3 organizations are expected to undergo triennial assessments by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) rather than third-party assessors.

What Is a C3PAO, and How Do I Find One?

A C3PAO is a certified assessor responsible for evaluating your organization's compliance with CMMC program standards. To find a reputable C3PAO, consult the official CMMC Accreditation Body's marketplace (CyberAB.org) or seek recommendations from industry peers or registered practitioners.

What Happens If My Organization Fails a CMMC Assessment?

If your organization fails a CMMC assessment, promptly addressing any identified gaps and vulnerabilities is essential. Developing a Plan of Action and Milestones (POA&M) can guide your remediation efforts and ensure timely compliance.

Is It Possible to Appeal the Results of a CMMC Assessment?

You can appeal the decision if you believe a CMMC assessment's results are inaccurate or unfair. The appeals process is through the Accreditation Body (Cyber AB), not the DoD. Consult the Cyber AB’s guidelines for the specific process and requirements for appealing an assessment outcome.

Can Small Businesses Realistically Achieve CMMC Compliance?

While achieving CMMC compliance may pose challenges for small businesses, it is attainable with the right resources and support. Engaging professional services and leveraging available tools and technologies can help smaller organizations meet compliance requirements and maintain competitiveness in the defense industry.

Does CMMC Compliance Affect Businesses that Don’t Directly Contract with the DoD?

As of now, CMMC only applies to prime and subcontractors within the DoD supply chain. However, CMMC was always a testing ground for implementing CUI safeguarding requirements. The goal has always been to expand these requirements to all federal contractors handling CUI. With the CMMC 2.0 final rule, the momentum to expand these requirements across federal agencies (potentially affecting FedRAMP-authorized providers) will only grow.

How to Do a CMMC Self-assessment?

To conduct a CMMC self-assessment, you must evaluate your organization’s implementation of the required security controls (17 for Level 1, 110 for Level 2) against the National Institute of Standards and Technology standards. You then must submit your score to the Supplier Performance Risk System (SPRS). An annual affirmation by a senior official is also required.