How to Implement CMMC 2.0: A Guide for Defense Contractors

In the landscape of the 2020s, the rise of digital warfare, the emergence of targeted hacking, and the increasing importance of digital infrastructure have elevated cybersecurity to a top priority for companies of all sizes. This is especially true for organizations operating within the Defense Industrial Base (DIB), where the protection of sensitive defense-related information and technologies is paramount to national security. Although security standards such as NIST 800-171 have been around since 2015, self-assessments have proven inadequate in protecting the Pentagon’s supply chain from increased cybersecurity attacks and sub-contractor vulnerability. In response, the Department of Defense (DoD) created the Cybersecurity Maturity Model Certification (CMMC) program to enhance the cybersecurity posture of government contractors handling sensitive information. 

Understanding CMMC 2.0

CMMC is a government program aimed at assessing and enhancing the cybersecurity practices of organizations contracting with the DoD. The requirements of CMMC 2.0 are divided into three maturity levels, each with increasing cybersecurity requirements, ensuring contractors are equipped to safeguard controlled unclassified information (CUI) and federal contract information (FCI).

Organizations falling into level 2 will need to be assessed by a CMMC Third Party Assessment Organization (C3PAO) to receive their CMMC certification. Level 3 requires a government-led assessment by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). While level 1 allows self-assessment, these contractors should not neglect their own cybersecurity efforts.

CMMC is designed to serve as a verification mechanism, ensuring not only the implementation of appropriate cybersecurity practices and processes across the defense supply chain but also their consistent maintenance. As a result, contractors will be mandated to undergo assessments every three years.

Key Steps to Prepare for CMMC 2.0 Compliance

Preparing for compliance with CMMC 2.0 involves meticulous planning and implementation of cybersecurity measures. With CMMC expected to become law in 2025, we’ve outlined some key steps organizations should take to ensure they are adhering to mandatory requirements. 

• Assessment of Current State: Evaluate your organization’s existing cybersecurity practices, and determine which CMMC level you fall into. Be sure to consider flow-down requirements that could be applicable depending on the CMMC level required by your prime contracts and the type of CUI you handle. It is important to consider if you have the necessary resources in-house of if you would benefit from CMMC compliance services.
• Gap Analysis: Conduct a thorough gap analysis to identify disparities between your current cybersecurity posture and the requirements of your CMMC level.
• Develop a Remediation Plan: Develop a remediation plan that outlines the steps needed to achieve compliance, including timelines, resource allocation, and responsible personnel.
• Implementation of Controls: Implement cybersecurity controls and processes needed to meet your identified CMMC level. This will likely involve implementing any unmet security controls outlined in NIST 800-171.
• Documentation: Maintain comprehensive documentation of all cybersecurity policies, procedures, and evidence of implementation, which will be crucial during the certification process.
• Training and Awareness: Provide cybersecurity training and awareness programs to employees to ensure they understand their roles and responsibilities in maintaining a secure environment.
• Engage with a C3PAO: Engage with a C3PAO to schedule and undergo your assessment. You can find a list of authorized assessors listed on the Cyber AB marketplace.
• Continuous Monitoring: Cybersecurity requirements are always evolving. Continuously monitor, assess, and improve your organization’s cybersecurity posture to adapt to emerging threats and regulatory changes.

IsI is here to support defense contractors with CMMC services throughout every step of the compliance journey. We are a certified Registered Provider Organization (RPO) with four Registered Practitioners (RPs) on staff. Are you interested in setting up a consultation to discuss your CMMC compliance initiatives? Be sure to reach out today to ensure your organization is prepared for the future of cybersecurity and compliance in the defense sector.