How To Navigate The CMMC Compliance Process: A Step-by-Step Guide

The big question on every DoD contractor's mind at this point in time is compliance. You must fulfill the latest standards of Cybersecurity Maturity Model Certification (CMMC) because CMMC is now final. It's set to take effect on December 16, 2024, and will be reflected in contracts by the middle of 2025.

So again, compliance is of the utmost importance.

To help you fastrack your compliance, cut costs, and maintain a competitive edge, this blog provides a CMMC Compliance Checklist.

Quick Overview of CMMC Compliance

The CMMC was created to improve the Defense Industrial Base's (DIB) ability to secure controlled unclassified information (CUI). It came as a significant step toward a more cohesive and uniform approach to cybersecurity.

But there's more to it than meets the eye.

Fundamentally, cybersecurity readiness is divided into three progressive levels under the CMMC 2.0 structure, with Level 1 representing fundamental cyber hygiene measures and Level 3 representing advanced and progressive capabilities.

The stages listed below give a high-level summary of the eight necessary steps in the CMMC compliance process.

Step-by-step Breakdown of the Compliance Process

Step 1: Know Your CMMC Level

In contrast to CMMC 1.0, which had five maturity levels, CMMC 2.0 includes three tiers. The maturity procedures and special security procedures of CMMC 1.0 are removed in these levels, which closely correspond to the NIST 800 requirements.

These are the three CMMC 2.0 levels:

CMMC 2.0 Level 1: Fundamental

Organizations must perform an annual self-evaluation at this level, and a corporate officer must certify it. The emphasis is on fulfilling the fundamental protection standards for Federal Contract Information (FCI) outlined in Clause 52.204-21 of the Federal Acquisitions Regulations (FAR).

CMMC 2.0 Level 2: Advanced

The Advanced level, which is in line with NIST SP 800-171, requires contractors that send, share, receive, and store sensitive national security data to undergo triennial third-party assessments. 

CMMC 2.0 Level 3: Expert

The 134 controls needed for Level 3 are 110 from NIST SP 800-171 and another 24 from NIST SP 800-172. These controls, which might be organizational structures, policies, procedures, guidelines, or practices, are a way to manage risk.

Step 2: Perform a Gap Assessment

A gap analysis compares your company's present cybersecurity posture to the requirements of the appropriate CMMC level. Determine the gaps in your organization's performance and the precise steps required to close them.

Step 3: Create a System Security Plan (SSP)

An SSP is a crucial document for firms seeking compliance with CMMC. The SSP offers a thorough summary of the security measures and controls put in place inside a company's systems.

Step 4: Put Security Controls in Place

Start implementing the required security measures based on the findings of the gap analysis and the specifications in the CMMC framework. These controls cover access control, identity and authentication, media protection, incident response, system and communication protection, and more. 

Step 5: Create a Plan of Action and Milestones (POA&M)

A POA&M is a document that lists the precise steps, accountable parties, deadlines, and checkpoints for resolving the lingering risks and shortcomings throughout the implementation phase. Your POA&M for CMMC must cover the following:

• Determine and rank your weaknesses: Examine the findings of your security assessments or gap analyses to find any gaps or vulnerabilities in your cybersecurity procedures and controls.
• Describe remedial measures: Determine the precise steps needed to address and fix each weakness or vulnerability that has been found. Clearly state the actions, duties, and tasks required to carry out the needed enhancements.
• Establish timelines: Give each remediation action a reasonable completion date. Take into account elements including the amount of effort needed, the action's complexity, and the availability of resources.
• Split the tasks: Assign teams or people-specific tasks to carry out each corrective action. Make sure that all those in charge are aware of their responsibilities and expectations.
• Define milestones: To monitor progress, divide the remediation actions into smaller checkpoints or milestones. Establish clear benchmarks that signify important phases or critical actions in finishing the remediation process as a whole.
• Add mitigation techniques: Create mitigation plans for any vulnerabilities or weaknesses that can't be fixed right away because of dependencies, resource constraints, or other issues.
• Document supporting details: For every remediation measure, include pertinent information and supporting documentation in the POA&M.
• Start tracking and reporting: Establish a procedure for tracking the POA&M's development, including frequent updates and reporting on the state of corrective measures.
• Examine and revise: Review and update the POA&M frequently to take into account new threats, modifications to the cybersecurity environment, and changing compliance needs.

Step 6: Perform Internal Evaluations

Conduct internal evaluations on a regular basis to see how well your company is adhering to CMMC regulations. These evaluations, which can be carried out by internal teams or outside experts, ought to involve examining policies, carrying out technical audits, and confirming that security controls are being applied correctly.

Internal evaluations guarantee continued compliance and assist in pinpointing areas that need improvement.

Step 7: Consult a Third-Party Evaluator

Your company needs to work with a CMMC Third Party Assessor Organization (C3PAO) in order to become CMMC compliant. Your company's cybersecurity procedures will be formally evaluated by the C3PAO, which will also grant the certification required to submit bids for DoD contracts.

Step 8: Continue to be Compliant

Compliance with CMMC is a continuous process. Organizations must maintain compliance after certification by regularly assessing and upgrading their security protocols to meet the ever-growing CMMC requirements and evolving threats.

Perform routine internal evaluations, examine and revise policies and processes, and give staff members continual training per the DoD's upgrades.

Final Words

Each step is valuable, but finding the right C3PAOs can make or break your compliance efforts. They assist organizations in creating a Plan of Action and Milestones (POA&M), which serves as a roadmap to improve cybersecurity procedures and comply with CMMC regulations.

So, make sure you make the right choice.

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