How to Perform a CMMC Gap Assessment
How to Perform a CMMC Gap Assessment
The Cybersecurity Maturity Model Certification (CMMC) is critical for defense contractors who want to earn and maintain eligibility for Department of Defense (DoD) contracts. The CMMC certification ensures that organizations meet stringent cybersecurity requirements.
These requirements are mandatory for businesses that handle controlled unclassified information (CUI) and federal contract information (FCI). A strong cybersecurity posture is not just a regulatory requirement; it's a competitive differentiator demonstrating a business's commitment to safeguarding sensitive information.
Navigating the complexities of CMMC compliance can be overwhelming, and that's precisely where ISI can help. With expertise in CMMC standards, ISI can guide businesses through the entire compliance process, starting with a thorough gap assessment. The gap assessment is a three-pronged attack that identifies areas of non-compliance, reveals vulnerabilities, and establishes a clear path to certification. Follow along to learn more about this crucial part of the session.
What Is a CMMC Gap Assessment?
A CMMC gap assessment is an evaluation designed to identify gaps between an organization's cybersecurity practices and the requirements discussed in the CMMC's framework.
The gap assessment assists in achieving compliance with NIST 800-171 and CMMC standards. The structured evaluation identifies areas where an organization's security posture might fall short of meeting the required standards. Here are five reasons why your business should perform a gap assessment:
- Identifies non-compliance
- Prevents certification delays
- Prioritizes remediation efforts
- Builds a roadmap to compliance
- Ensures alignment with both frameworks
When you uncover and address gaps through a thorough assessment, contractors can safeguard sensitive data, mitigate vulnerabilities, and ensure readiness for official CMMC assessments. Compliance with CMMC requirements is non-negotiable for contractors handling CUI and FCI. This is why your business needs to undergo a gap assessment so its security posture is ready to meet DoD contract obligations.
What Does a CMMC Gap Analysis Cost?
The cost of a CMMC gap analysis will depend on multiple factors, such as:
- Company size
- Maturity of existing cybersecurity practices
- Scope of the assessment
- Compliance efforts
Company Size
Smaller businesses require a more focused assessment. In contrast, larger organizations with complex systems require in-depth evaluations that could span multiple departments and locations.
Maturity of Cybersecurity Practices
Organizations with mature cybersecurity frameworks may require only minor adjustments, whereas those starting from scratch must establish foundational policies, processes, and technologies.
Scope of the Assessment
Defining the scope ensures all critical systems, processes, and data handling of CUI or FCI are evaluated for compliance.
Existing Compliance Efforts
Companies with existing NIST 800-171 controls might have fewer gaps, while those new to compliance face greater resource and time commitments to meet CMMC standards.
While costs can fluctuate, the value of a gap analysis is truly within its ability to provide a clear path to compliance. Investing in a gap analysis helps avoid any potential penalties or loss of contracts. By addressing deficiencies early, your organization can achieve efficient, cost-effective compliance.
How to Perform a CMMC Gap Assessment
A well-structured approach ensures your gap assessment is effective and actionable. Below are the key steps to prepare your business for a gap assessment.
1. Identify the Required CMMC Level for Your Business (Levels 1, 2, or 3)
The appropriate CMMC level for your business depends on the type of data you handle and the specific requirements outlined in your contracts. The three levels are:
- Level 1 (Foundational): For businesses handling less sensitive information called Federal Contract Information (FCI).
- Level 2 (Advanced): Designed for companies managing Controlled Unclassified Information (CUI) with moderate protection needs.
- Level 3 (Expert): Reserved for organizations dealing with highly sensitive CUI data requiring robust cybersecurity controls.
As the level increases, the requirements and controls become more rigorous to protect sensitive information.
2. Scope Your Compliance Boundary
Identify your business' systems, processes, and data that fall under CMMC requirements. Some areas of your operations may be required to meet CMMC requirements, while others may not. You can establish clear boundaries by pinpointing where sensitive data flows and who has access—whether in cloud environments or physical locations. This process helps you determine the impacted areas within your business and focus your compliance efforts effectively.
3. Review Your Organization’s Current Cybersecurity Posture Using the CMMC 2.0 Framework
Where does your business currently reside with its security posture? To begin, review your existing cybersecurity policies, procedures, and technical controls to understand where you stand. If you're starting from scratch, identify the CMMC compliance level (1, 2, or 3) you want to achieve and develop a plan to meet the required level.
4. Map Existing Security Controls to CMMC Requirements
Map your current security controls to the 320 objectives outlined in the MMC framework. Prioritize addressing the more recent security objectives to advance your compliance efforts effectively. Going beyond the foundational controls can ensure a more thorough and forward-looking assessment of your organization's security posture.
5. Identify and Document Compliance Gaps
Focus on key areas like access controls, incident response plans, and your System Security Plan (SSP). Document any gaps you can find and prioritize remediation.
6. Develop a Remediation Roadmap
From the previous step, create a Plan of Action & Milestones (POA&M) document to address identified gaps. This roadmap should include timelines, responsibilities, and any resource allocations needed. Use this roadmap as your guide to achieving compliance.
What to Expect During a Gap Assessment
During a gap assessment, expect interviews with key stakeholders, system reviews, and current policy evaluations. The gap assessment process provides a realistic picture of your organization's compliance readiness.
It's not necessarily an "audit" to find out what is wrong with your business, but a fact-finding mission to uncover what is working and what needs to be put into place to fortify your business's cybersecurity strength. Defense contractors undergoing the assessment should anticipate varied timelines based on their organizational complexity and size.
Tools and Frameworks for Performing an Effective Gap Assessment
Successful and effective assessments leverage resources like compliance checklists, NIST SP 800-171 scoring tools, and specialized assessment software. While gap analyses identify deficiencies, readiness (mock) assessments simulate the certification process.
To maximize the effectiveness of your compliance efforts, use both gap analyses and readiness assessments strategically. Start with a gap analysis to identify security weaknesses and prioritize remediation efforts. Once gaps are addressed, conduct a mock assessment to validate your implementation and prepare for certification. This two-step approach ensures a thorough and efficient path to achieving and maintaining CMMC compliance.
Best Practices for Conducting an Effective Gap Assessment
An effective gap assessment requires a strategic and collaborative approach to deliver meaningful results. Start by engaging key stakeholders from IT, operations, leadership, and end users, all who interact with the systems and data. This collaboration ensures a thorough understanding of your organization's processes, risks, and priorities, fostering alignment and buy-in for remediation efforts.
Avoid common pitfalls in gap assessments, including inadequate documentation, which can lead to unclear responsibilities, missed deadlines, and a lack of accountability. Additionally, underestimating the scope of the assessment often results in overlooked risks and incomplete remediation efforts, undermining the effectiveness of the assessment.
Steps to Remediate Gaps Identified in the Assessment
So, you have completed your assessment and found some gaps. Now what? Don't wait. Start immediately and prioritize high-impact gaps, focusing on the greatest risks to your security posture and compliance objectives. Addressing critical issues first reduces immediate risks and builds momentum for tackling more complex challenges. Begin by following these steps:
- Develop and implement a Plan of Action and Milestones (POA&M) to address deficiencies.
- For identified gaps, strengthen policies and procedures, such as updating access controls or refining incident response plans.
- Consider bringing on a Managed IT Provider, like ISI, to provide expert guidance in enhancing your cybersecurity posture and meet regulatory requirements.
Documentation and Reporting Best Practices Post-Assessment
A comprehensive gap assessment report should include findings, gap analysis metrics, and recommended remediation actions. This additional paperwork is vital documentation that helps your business prepare for future audits and compliance reviews. The more you identify, document, and address, the more it will help your business, serving as a foundation for continuous improvement.
ISI Insight: Try to stay as organized as possible. Comprehensive and well-maintained records address immediate needs and lay the groundwork for constant improvement. Staying organized with tidy, easily accessible documents will streamline processes and enhance efficiency in future assessments.
Compliance Timeline and Future Expectations for CMMC
With the rollout of CMMC 2.0, contractors must stay ahead by understanding deadlines and requirements. Early action is critical to maintaining compliance and competitiveness in the DIB. Delays in preparation could lead to missed opportunities and potential loss of contracts.
Unfortunately, compliance is now a non-negotiable requirement for working with the DoD. Proactively implementing necessary changes ensures compliance readiness and will turn your business into a trusted and reliable partner in the defense sector.
CMMC Gap Assessment FAQ
Is NIST Compliance Just for the IT Department?
No, cybersecurity compliance must be integrated into every level of the organization. NIST compliance is an organization-wide effort involving multiple departments. This can include facilities, HR, operations, and the leadership team.
How Will My Organization Know What CMMC Level Is Required for a Contract?
The required CMMC level depends on the type and sensitivity of the data that is associated with the contract. If you need clarification on the security level required, consult a compliance expert and review the contract for clarity.
How Long Does a Typical Gap Assessment Take?
The time to complete a gap assessment varies by organization size and complexity, typically ranging from several weeks to a few months, including preparation, evaluation, and reporting.
