CMMC: As Relevant Today as it was in 2021

The wait is finally over! After two long years of anticipation, the proposed rule for the Cybersecurity Maturity Model Certification (CMMC) is officially out. While it's important to remember that nothing is set in stone until the public comment period concludes and the final rule is published, there's no better time than now for those in the defense industrial base or aspiring to be part of the Department of Defense (DoD) supply chain to start gearing up for CMMC compliance.

In this blog, we will discuss why CMMC matters, what it means for defense contractors, and essential steps to begin your journey toward CMMC readiness.

Why Does CMMC Matter?

CMMC is the DoD's response to the growing threat of cyberattacks in the defense sector. It aims to enhance the cybersecurity posture of the defense industrial base by requiring contractors to meet specific cybersecurity standards and practices. In simple terms, CMMC ensures that sensitive government data remains secure throughout the supply chain.

What Does CMMC Mean for Defense Contractors?

If you are part of the Defense Industrial Base (DIB) or aspire to work with the DoD, CMMC is not something you can afford to ignore. Once fully implemented, CMMC will become a mandatory requirement for all DoD contracts, affecting thousands of defense contractors. To continue participating in DoD contracts, you will need to provide affirmations at different steps and achieve and maintain a certain level of CMMC certification per the new rule.

DIB contractors should pay close attention to these new affirmations and certification requirements as they can position the contractor for liability under the False Claims Act (FCA) during a time of significant escalation in cybersecurity whistleblower cases and fraud enforcement actions initiated by the DoD and the Department of Justice (DoJ).  The FCA is one of the strongest whistleblower federal laws in the United States that imposes liability on persons and companies who defraud government programs.

Steps to Start Working on CMMC:

• Self-Assessments and Gap Analysis: Begin by assessing your current cybersecurity practices and identifying the gaps between your existing measures and the NIST SP 800-171 Rev 2. Understanding where you stand is the first step toward improvement.
• Educate Your Team: Cybersecurity is a team effort. Ensure your employees know the importance of CMMC compliance and provide training to enhance their cybersecurity knowledge and skills.
• Select the Right Level: CMMC is divided into three levels, each representing a different degree of cybersecurity maturity. Determine which level is appropriate for your organization based on the contracts you wish to pursue.
• Implement Necessary Controls: Depending on your chosen CMMC level, start implementing the required controls and practices. This may involve upgrading your IT infrastructure, enhancing data protection measures, and implementing robust access controls.
• Documentation and Record-keeping: Maintain thorough records of your cybersecurity efforts, including policies, procedures, and evidence of compliance. Proper documentation is essential for the certification process.
• Hire Experts if Necessary: Depending on your organization's size and complexity, you may need to enlist the help of cybersecurity experts or consultants to guide you through the CMMC compliance journey.
• Stay Informed: Keep a close eye on updates and developments regarding CMMC. Subscribe to official DoD channels and industry news to ensure you are up to date with any changes in the requirements.

Conclusion:

The release of the CMMC proposed rule marks a significant milestone in the efforts to strengthen cybersecurity in the defense industry. While the final rule is yet to be published, it's never too early to start working on CMMC compliance. By taking proactive steps now, defense contractors can position themselves for success in the evolving landscape of DoD contracts. Remember, cybersecurity is not just a requirement; it's a vital component of ensuring national security and safeguarding sensitive information. Don't wait; start your journey toward CMMC readiness today.

Ingalls Information Security offers CMMC expert consulting services. Contact our DoD Services team for information.