CMMC Compliance for DoD Contractors
Amidst the headlines, regular updates, and industry buzz, many across the Defense Industrial Base (DIB) have been left with more questions than answers on CMMC. At IsI, our expertise lies at the intersection of compliance, cybersecurity, and managed IT solutions, making us the go-to partner to guide Department of Defense (DoD) contractors through the complexities of CMMC and compliance requirements as a whole. With a seasoned team boasting hundreds of years of collective experience and four Registered Practitioners (RPs) on staff, we’re dedicated to ensuring adherence to the latest compliance standards.
What is CMMC?
Let’s get back to the basics. CMMC stands for Cybersecurity Maturity Model Certification. It is a program designed by the DoD to protect the Pentagon’s supply chain and standardize compliance across the DIB. CMMC expands upon an existing compliance framework called NIST 800-171 which has been in place since 2017. CMMC was initially announced in July 2019 with the primary goal of replacing the existing self-assessment model used by contractors with a standardized process. In November 2021, CMMC 2.0 was announced to streamline the original program and revise overall requirements. CMMC 2.0 is expected to become law in 2025.
Understanding CMMC Certification Levels
CMMC has three defined certification levels; Foundational (level 1), Advanced (Level 2), and Expert (level 3). Contractors can determine the CMMC level that they fit into based on the sensitivity of the data that they handle. Questions here? An IsI team member would be happy to help when you schedule your consultation!
The Three Levels of CMMC
Advanced (Level 2): Contractors handling Controlled Unclassified Information (CUI) will fall into level 2. This level requires compliance with the 110 security controls outlined in NIST SP 800-171. These controls are broken into 14 control families and must be met to reach compliance. Friendly hint– Contractors should not proceed with a CMMC assessment until they comply with these controls achieving a Supplier Performance Risk System (SPRS) score of 110.
Expert (Level 3): The Expert level is designated for contractors handling CUI in the DoD’s highest priority programs. The assessment requirements for Level 3 are still under development at this time.
As a leading Registered Provider Organization (RPO), IsI excels in guiding companies to achieve compliance with CMMC Levels 1 and 2. Further, our MSP division was created around compliance. From tool selection to policy creation, nothing was put in place without first evaluating its importance and impact on a potential client’s CMMC status. Our CMMC solution includes a curated security stack that enables clients to achieve 70% compliance during the onboarding and initial compliance phases alone. Our proven track record and highly experienced team are here to help make your compliance journey a smooth one, so you can focus more of your time on growing your business. Partnering with IsI as your RPO offers numerous advantages including:
Streamlined Assessment Preparation
We’ll help you navigate the compliance process so you can save both time and money in the long run.
Vendor Management
We handle comprehensive vendor management, leveraging a meticulously vetted tool stack to meet compliance and cybersecurity requirements.
Cost-Effective Guidance
Our support will help ensure that you won’t need to pay for costly corrective actions following your CMMC assessment.
The Path to CMMC Compliance
DoD contractors will need to meet the compliance requirements of NIST 800-171 to prepare for their assessment. Preparation can be handled in-house if the necessary resources are available, however, contractors may consider partnering with a CMMC provider (commonly referred to as an RPO) to help guide them through this tedious process. At IsI, we break the preparation for CMMC assessment into five steps:
Identify your CMMC level.
Specify your CMMC assets
Select a technical design.
Ensure cloud compliance.
Plan, record, and adopt.
Upon completion of these critical steps, contractors unlock the gateway to their CMMC assessment, however, the path ahead is not forecasted to be a quick one.
With approximately 50 Certified Third-Party Assessor Organizations (C3PAOs) available in the market, and an overwhelming 100,000 DoD contractors awaiting assessment, the demand far exceeds the available resources. The linked infographic depicts what the compliance timeline looks like through 2025. With the impending enforcement of CMMC regulations in 2025, the urgency for DoD contractors to act has never been more pressing. Our team estimates that the preparation period leading up to the CMMC assessment could span a daunting 3-4 quarters. This timeline underscores the critical need for swift and decisive action.
What does the foreseeable future look like?
The public comment period for CMMC 2.0 came to a close on February 26, 2024. Here are the important upcoming dates:
- Approximately November 2024: Comment Adjudication Ends (300 comments submitted)
- December 2024 – CMMC is Published as a Final Rule, making CMMC 2.0 active. Assessments can begin in earnest by C3PAOs at this point.
- Late Q1/Early Q2 2025 – The CMMC requirement will begin to appear in new DoD contracts and potentially in modifications to existing contracts.
- 2028 – CMMC requirement appears in ALL applicable DoD contracts
As we continually refine this page with the latest updates on this DoD program, please feel encouraged to get in touch with us to learn more about our CMMC consulting services. We’re proud to emphasize that IsI stands as an accredited RPO, certified by Cyber AB, ensuring the highest standards of expertise and service. Are you ready to navigate the evolving landscape of compliance requirements for your organization? Submit the form below to get started.