CMMC Requirements for Small Businesses: Navigating the Road to Compliance on a Budget
The Cybersecurity Maturity Model Certification (CMMC) process can feel daunting. Achieving certification can be lengthy, complex, and costly, and it applies to all Department of Defense (DoD) contractors and subcontractors handling Controlled Unclassified Information (CUI) or Federal Contract Information (FCI). Whether you’re Northrup Grumman or a 40-person startup that just launched last year, CMMC should be top of mind.
It makes sense for small businesses to look for ways to save on specific parts of the certification process, while adhering to the requirements that remain non-negotiable. This article will guide you through some essential aspects of CMMC certification, from understanding what certifications your small business needs to some best practices for navigating the process on a budget.
Does My Company Need To Be CMMC Certified?
If your business is part of the Defense Industrial Base (DIB) and handles FCI or CUI, you will need to be CMMC certified. The level of security your small business needs depends on the sensitivity of the information you're working with and the specific requirements of your contract(s).
Can You Self-Certify CMMC?
The possibility of self-certification depends on the level of CMMC you are pursuing. Under CMMC 2.0 (which replaced the original 2020 CMMC model), self-certification is allowed for Level 1 and potentially for certain requirements of Level 2. Higher levels require third-party assessments to ensure compliance with more stringent security controls.
If your small business only handles contracts that require level 1 security, this certification is less expensive than the rigors of levels 2 and 3. However, self-certification should be taken seriously as it requires a thorough understanding of the necessary security controls, documentation, and an honest evaluation of your company's cybersecurity practices. Check out our more detailed overview of the distinctions between Levels 1, 2, and 3.
What’s the Difference Between NIST 800-171 and CMMC Compliance?
Often confused as the same thing, NIST 800-171 and CMMC are closely related but serve different purposes. NIST 800-171a sets the rules that must be followed for cybersecurity practices to protect CUI in non-federal systems; CMMC, on the other hand, is the particular set of audit requirements that companies must follow in order to become certified against those rules. They work together to ensure companies meet the cybersecurity guidelines to handle sensitive material.
How Does CMMC 2.0 Affect Small Businesses?
CMMC 2.0 consolidated the certification process from a five-tiered model into a three-tiered system that allows Level 1 and select Level 2 organizations to conduct a self-assessment and annual affirmation rather than seek a third-party assessment. This should be a significant cost saver. However, CMMC 2.0’s stronger focus on security controls outlined in NIST 800-171 means most SMBs seeking Level 2 – and all SMBs seeking Level 3 – will likely need to make substantial investments to ensure they’re in compliance.
Issues for Small and Medium-Sized Businesses Implementing CMMC Compliance
Small businesses looking to achieve CMMC compliance will have to overcome hurdles related to compliance costs, training, and limited resources. Navigating these obstacles to achieve CMMC compliance is crucial for maintaining eligibility for government contracts.
Compliance Costs
While there is no application cost associated with becoming CMMC compliant, the cost is accrued in the substantial investments made to make their business compliant.
For example, the DoD estimates the cost of self-assessment and initial affirmation for a small business seeking Level 1 certification at about $6,000. Levels 2 and 3 require a business to invest significantly in cybersecurity infrastructure, training, and third-party assessments. For many small businesses, these costs can be prohibitive, making competing for Level 2 and 3 DoD contracts difficult.
Training and Education Needs
To successfully implement CMMC practices, a workforce must be well-trained in cybersecurity principles and protocols. However, small businesses often lack the resources to provide extensive internal training, which may result in gaps in compliance and increase the risk of security vulnerabilities.
Resource Constraints
Investing in cybersecurity training is essential, but it also represents a significant challenge for resource-constrained businesses. Small businesses typically have limited IT staff and resources, making implementing and maintaining the required cybersecurity practices difficult. The complexity of the CMMC framework can overwhelm small teams, leading to delays in compliance and increased vulnerability to cyber threats. Partnering with a compliance focused MSP or hiring additional team members can help alleviate some of these challenges.
5 Best Practices for Small Businesses Working Toward CMMC Compliance
Achieving CMMC compliance can take up to 12 months or more. Given this extended timeline, businesses should follow some of these best practices, to ensure they’re staying informed and consistently working towards meeting the required compliance standards.
1. Educate Your Workforce on Good Cybersecurity Hygiene
Remember: good cybersecurity starts with your employees. It’s critical to ensure that your workforce understands the basics of cybersecurity hygiene. One way you can achieve this is to offer updates about the latest threats and regular training sessions that go over the following topics:
- Identifying and reporting suspicious activity
- Following access control protocols.
- Ensuring proper data encryption practices
- Using strong passwords
Offering these training sessions can help create a culture of cybersecurity awareness, reduce the risk of breaches, and help businesses maintain compliance.
2. Hire an MSP with CMMC Expertise
MSPs with experience in CMMC compliance can be invaluable partners for small businesses. They can help implement the necessary controls, monitor systems, prepare you for the assessment process, and help you secure more competitive pricing on necessary security software.
While hiring an MSP represents an additional cost, it will save time in the long run and reduce the potential for non-compliance. Ultimately, choosing the right MSP will help ensure your business's ability to secure DoD contracts.
3. Get Cybersecurity Insurance
Cybersecurity insurance can help financially protect your business by covering potential losses resulting from a cyberattack. It provides coverage for some of the following:
- Data breaches
- Ransomware attacks
- Compliance violations
For small businesses, cybersecurity insurance can be an added safety measure to ensure financial stability in the event of a security incident. While the upfront and ongoing costs of insurance may seem high, they’re minimal compared to the potential financial devastation and reputation loss your business could face if compromised by a cyberattack.
4. Implement New Cybersecurity Solutions
Often one of the most expensive parts of achieving CMMC compliance is investing in and integrating a new cybersecurity infrastructure. What new cybersecurity solutions your business needs will depend on what you currently have and the security maturity level your business needs to attain.
New cybersecurity solutions could involve implementing new monitoring software, encryption programs, access control, and hardware enhancements to secure your on-premises or cloud network. These investments can be highly costly for small businesses, but they might be mandatory to protect sensitive information. If you’ve already begun to make these investments before the certification process begins, the cost of achieving compliance will be more spread out.
5. Prepare for CMMC Assessment
Preparing for a CMMC assessment involves:
- Thorough documentation of your cybersecurity practices
- Regular audits of your systems
- Employee training
- Conducting a pre-assessment
- Identifying gaps and establishing a plan of action and milestones for remediation
Working with a Registered Provider Organization (RPO) like IsI will help you prepare for the assessment process. Following these steps will help your business and give you the confidence to pass the official assessment when the time comes.
How Much Does CMMC Certification Cost?
Costs vary based on your organization’s size and complexity. We estimate preparing for third-party assessment costs for organizations aiming to achieve Level 2 compliance will start from a base of around $30,000. To assist with budgeting for these costs, small businesses can explore options like grants and loans. Subcontractors affected by flowdown requirements should consider having conversations with prime contractors to determine whether they can help support some of these implementation costs.
Are There Any Resources or Programs Available to Help Small Businesses with CMMC Compliance?
Several resources and programs are available to help small businesses navigate CMMC compliance. The DoD's Office of Small Business Programs offers assistance, and organizations like the Cybersecurity Maturity Model Certification Accreditation Body (Cyber-AB) provide guidance and training materials. Additionally, state and local government agencies often offer grants or funding opportunities to support cybersecurity improvements.
Are There Any Exemptions or Waivers for Small Businesses Regarding CMMC Requirements?
Regardless of size, companies that want to pursue government contracts must meet the required CMMC level. There are no current exemptions or waivers for small businesses regarding CMMC requirements. However, the DoD has been mindful of small businesses' challenges and has introduced phased implementation and resources to help them achieve compliance. While the requirements are firm, small businesses can access various forms of assistance to meet CMMC standards.
ISI Helps Small and Mid-Sized Defense Contractors Achieve CMMC Compliance
Navigating the CMMC certification process on a budget can be challenging for small businesses, but there are ways to manage costs effectively. Small businesses can save money by leveraging available resources, exploring cost-effective solutions for cybersecurity upgrades, and hiring experts like ISI to help with compliance. To learn more about how to achieve CMMC compliance, contact our team today.