EXECUTIVE BRIEF
With the Final CMMC Rule effective on December 16, 2024, defense contractors are ramping up their searches for additional, external support. But with so many options on the market, here are a few differentiators to keep your eye out for:
- Cyber AB Registered Provider Organization (RPO) certification
- On-staff Registered Practitioners (RPs)
- Specific focus on Department of Defense (DoD) cybersecurity regulations such as NIST SP 800-171
Dig deeper and continue reading below!
As defense contractors prepare for CMMC self-assessments and CMMC third-party assessments, many are looking for external guidance to help them achieve compliance. And with good reason. When it comes to enhancing your cybersecurity posture and advancing your progress toward CMMC certification, a Managed Service Provider (MSP) can be a huge value-add for your company.
However, you’re likely being bombarded with ads from companies of all sorts offering CMMC compliance services. But what should you be looking for? This article details what certifications, experience, and offerings defense contractors should keep in mind when comparing MSPs.
An Introduction to CMMC and Its Importance for Defense Contractors
The Cybersecurity Maturity Model Certification (CMMC) program standardizes cybersecurity practices to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) across the defense supply chain.
This program was revised and streamlined with CMMC 2.0, which will be effective beginning on December 16, 2024. One of the biggest revisions in CMMC 2.0 requires defense contractors to achieve CMMC certification both to win new contracts and to sustain current contracts.
Compliance can no longer be put on the back burner; now it's a part of any defense contractors’ overarching business goals.
What Is a CMMC Consultant?
A CMMC consultant is an individual or group—typically a Managed Service Provider (MSP)— that can guide your organization through the CMMC certification process, often by implementing new policies and procedures and recommending new technologies and best practices to protect your IT and data systems. An MSP can
- Act as your external IT department or supplements your current IT department
- Provide your organization with cybersecurity solutions and corresponding documentation that meets CMMC practices (NIST SP 800-171a Rev2 controls and objectives)
- Guide your organization through the CMMC audit and preparation process
The Significance of the MSP
Compliance can overburden a small IT department, especially if they don't have DoD regulatory experience. An MSP can work alongside your current IT department to ensure your organization can confidently bid on new, lucrative contracts. A few of the significant benefits of working with an MSP are:
- Cost Predictability: You can avoid the risk of last-minute adjustments, upgrades, and additional services to pass assessments and maintain compliance.
- Sustained Compliance: An MSP can proactively monitor compliance changes and tool enhancements, ensuring your security needs stay aligned with evolving federal regulations.
- Demonstrated Expertise: CMMC certified MSPs have demonstrated the ability to uphold requirements, offering more predictable assessment success.
Understanding the Role of a CMMC Consultant in CMMC Compliance
A good MSP will ensure your organization is prepared for your CMMC audit. From assessing your current CMMC readiness, to remediating any gaps that exist in your systems, to preparing your team for the formal assessment, your MSP is your right-hand partner throughout your compliance journey.
Common Challenges
It's estimated that small-to-medium sized businesses (SMBs) account for 73% of contractors within the Defense Industrial Base (DIB). While SMBs drive innovation within the DIB, they often lack the resources larger organizations have access to. Some common challenges are:
- Lack of technical experience in cybersecurity compliance regulations
- Not enough resources to fund fully functional IT department
- Team members serving in dual-hatted roles to meet contract demands
Different Types of CMMC Consultants
CMMC's a big buzzword in the Cybersecurity and Compliance space, so you've probably seen a lot of companies marketing CMMC compliance services already. However, it's important to be mindful of the fact CUI safeguards only apply to the DoD and the defense supply chain (prime and subcontractors). When evaluating potential Managed Service Providers (MSPs), they’re likely going to fall into one of these two categories:
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Generalist MSP |
Specialized MSP |
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If working with defense contractors:
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If working with defense contractors:
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The benefit of a specialized MSP like ISI is that the entire organization has experience with—and is solely focused on—the complex regulations specific to the DIB. The services we offer are all tailored to CMMC practices and can be modified to meet your organization’s needs while still achieving compliance.
Key Factors to Consider When Choosing a CMMC Consultant
Not all MSPs are the same. There are varying degrees of expertise, comprehensiveness, and commitment that defense contractors have to weed through when searching for the right external support.
Let's dig deeper into what your organization should be looking for in an MSP. Beginning with...
Expertise in CMMC
As of now, only defense contractors are mandated to protect Controlled Unclassified Information (CUI). The regulations surrounding CUI are completely niche to this industry. That's why it's vitally important your organization hires an MSP that has the DIB-specific expertise needed to support your progress toward compliance.
Three things to look for in your potential MSPs are:
- Percentage of clients in the DIB
- Registered Provider Organization (RPO) certification, showcasing organization-wide expertise with CMMC regulations
- Staff with Registered Practitioner (RP) certification, signaling individual expertise with CMMC
Comprehensive Service Offerings
In the defense contracting world, there is no “quick fix” to achieve CMMC certification. Implementing all 110 of the security controls required to achieve CMMC Level 2 certification takes time and effort: often six months or more depending on your initial readiness. Your CMMC service provider should be able to:
- Conduct a gap analysis
- Implement the security stack needed to achieve compliance
- Lead your team through the audit preparation process
- Continue monitoring your systems to sustain compliance after certification
Excellent Customer Support
With CMMC compliance, there's a lot to be done. But, when working with an MSP, the work shouldn’t feel siloed, and your consultants shouldn’t be strangers. Your MSP should prioritize quick response times, regular check-ins and updates, and transparent communication about any changes or issues that arise. While they’re not on your payroll, you should feel like your MSP advisor is part of your team.
Collaborative Partnerships
As with any consultant, you want to make sure you're choosing a true partner for your compliance journey. You should sense your MSP cares about the success of your business and has your overall cybersecurity posture at the top of their mind. Remember: while achieving compliance is a critical part of the work they do for you, the overall goal is to build and strengthen your overall cybersecurity. A dedicated MSP should always be working toward that end.
Efficiency with Advanced Technology
The computer you buy from Dell or Best Buy isn't going to have the security tools needed to pass your CMMC audit. Your MSP will have to implement additional security tools for your network systems and individual devices that meet NIST SP 800-171a Rev2 requirements. Look for an MSP that can help you achieve compliance simply through the use of their tech stack. (For instance, at ISI, our curated security stack enables clients to achieve 65% compliance simply during the onboarding process alone).
Tips for Evaluating and Selecting the Right CMMC Consultant for Your Organization
There are a few things you should do when selecting an external service provider for your compliance journey:
- Interview multiple organizations before choosing one
- Make sure you choose an external service provider that you can build a rapport with
- Double-check to ensure they have experience with CMMC practices (i.e. that they're a certified Cyber AB RPO)
What Questions Should I Ask a Potential CMMC Consultant?
When interviewing potential MSP partners, consider asking these questions to ensure your organization is receiving the best quality service:
- Is your organization currently, or working towards, a Cyber AB Registered Provider Organization (RPO) certification?
- The RPO certification shows the MSP’s expertise and commitment to upholding CMMC requirements and best practices. It's a clear indication of a committed consultant.
- >> ISI is a certified RPO.
- Are any of your team members certified CMMC Registered Practitioners (RPs)?
- Having RPs on staff shows not only expertise in CMMC requirements, but also in implementing CMMC compliant solutions.
- >> ISI has four RPs on staff.
- Does your organization plan on becoming CMMC certified?
- The Final CMMC Program rule states that External Service Providers (including MSPs) are not required to achieve CMMC certification since the services provided will be part of the Organization’s Seeking Assessment (OSA's) scope. However, going through a voluntary assessment showcases the MSPs commitment to cybersecurity standards and demonstrates their ability to pass a CMMC audit.
- >> ISI is voluntarily undergoing the CMMC certification process.
- Does your organization utilize varying vendors for your security stack?
- Over-reliance on a single vendor may achieve CMMC certification, but may cause your organization headaches in the future. If the Crowdstrike outage showed us anything, it’s that your cybersecurity solutions need to include a variety of vendors to ensure continuity in services.
- >> ISI is not reliant on one vendor to provide cybersecurity tools, which ensures continuity in services during an outage or vendor breach.
- What is your average response time to support tickets?
- This seems basic, but it’s incredibly important. You've invested a lot into your business: you should choose an MSP that takes your business and tech issues seriously.
- >> ISI aims to respond to all tickets/requests within one-hour during business hours.
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CMMC 2.0 Updates and Their Impact on Defense Contractors
The CMMC 32 CFR final rule becomes effective on December 16, 2024, finalizing the revised maturity levels and assessment criteria in place, as well as opening the marketplace for CMMC third-party assessments. In short, CMMC is here to stay.
More than 80,000 defense contractors are expected to fall into Level 2, which will require companies to implement all 110 controls and 320 objectives. However, many of these defense contractors may not have the internal IT infrastructure, expertise, or resources to confidently achieve CMMC certification in-house.
ISI has the defense industry-specific expertise to help you reach your compliance goals. We've already helped over 180 customers achieve their NIST assessment, and we work with over 900 companies in the DIB. Our staff are uniquely focused on the compliance challenges that face you, as a DoD contractor. Contact us today to find out how partnering with ISI will speed the process toward CMMC certification for your organization.
>> Partner with ISI for your compliance journey!
FAQs about CMMC Consultants
Can you self-certify CMMC?
Level 1 certification is solely through self-assessment. There is also a Self-Assessment certification for some Level 2 companies. The contracts you bid on will determine whether a Level 2 Self-Assessment is sufficient or whether you need full Level 2 C3PAO certification. If you want to play it safe, going through the Level 2 C3PAO certification process satisfies Level 1 and Level 2 (Self-Assessment) requirements, opening your business up to more business opportunities.
How long does a CMMC assessment take?
The length of a CMMC assessment varies for a variety of reasons. Everything from internal preparation and organization to staff availability come into play. That said, you should plan for at least one, full work week (five, 8-hour days) for the assessment period.
Who can audit CMMC?
Audits are completed by a CMMC 3rd-Party Assessment Organization (C3PAO). Once you select a C3PAO, an assessment team consisting of a lead CMMC Certified Assessor (CCA), a secondary CCA, and an individual conducting quality assurance reviews for the assessment team will begin your audit. C3PAOs and CCAs accredited by the Cyber AB are the only entities capable of completing a CMMC assessment.
Does CMMC require a SIEM?
CMMC does not explicitly require a Security Information and Event Management (SIEM) software. However, many of the NIST 800-171A controls can be supported through a SIEM due to its ability to support centralized logging, threat detection, and incident responses.
What is the difference between a CMMC consultant and a C3PAO?
A CMMC consultant is a service provider to support the technical aspects of your compliance journey. With a Managed Service Provider (MSP), you can complement or outsource components of your IT department with individuals with CMMC expertise.
A C3PAO, on the other hand, reviews your IT infrastructure as well as any policies or procedures associated with CMMC practices.
