Image by Jason Goodman

CMMC 2.0 Cybersecurity for DOD Contractors

Government rules and regulations are designed to protect you, your customers and our homeland, but their complexities can make CMMC cybersecurity compliance a daunting process. While you may already have firewall protections to keep you and your information somewhat safe, standard firewall protections won’t be enough to pass Federal regulation requirements.

 

Ignite-AI can provide a comprehensive cybersecurity plan that’s right for you. Our experienced team is well-versed in government compliance and can support your business’s software security needs.

Everything You Need to Comply with Federal Regulations

Our solutions include everything you need to comply with Federal regulations, such as:

  • A complete Business Continuity Plan with overarching goals and policies

  • A Disaster Recovery Plan and the Security Controls

  • A complete identification of risks, vulnerabilities and threats

  • Step-by-step procedures

  • Continuous monitoring and improvement

Our compliance group is composed of project managers and specialists with decades of experience in meeting government regulations. We also work with experts in the field, including the authors of Cybersecurity regulations, such as CMMC, NIST 800-171, and DFARS.
 

Image by Sigmund

Don't let CMMC Cybersecurity 2.0
compliance hold you back...

The CMMC 360 Group

Due to the complexity of the CMMC 2.0 initiative, the CMMC 360 Group was created to streamline this process. This consortium of subject matter experts was created to help keep cost down and expertise at a level for all types of DOD Contractors to quickly assess their readiness and best practices for implementation.

What is the goal of CMMC 2.0?

As with CMMC V1, protection of sensitive information and evaluating an organization's security measures is the primary focus of CMMC 2.0. 


CMMC 2.0 differs from CMMC V1 as it seeks to: 

  1. Simplify CMMC and enhance clarity on cybersecurity regulatory, policy, and contracting requirements.

  2. Focus on third-party audit mandates and the most advanced cybersecurity measures of organizations that support essential programs in the aerospace and defense industries.

  3. Increase DoD oversight of professional and ethical criteria regarding third-party assessment.

A Closer Look at the Three Levels of CMMC 2.0

The first version of CMMC focused on both practices and processes, with five levels for each to obtain certification. But CMMC 2.0 eliminates processes and focuses only on practices, leaving only three levels. Let's take a closer look.

Level 1: Basic Cyber Hygiene (Foundational) 

This is the most basic level of certification and consists of several practices that correspond directly to essential safety conditions outlined in the Federal Acquisition Regulation (FAR). 


Level One consists of 17 basic cybersecurity practices such as implementing Access Control as well as Identity and Authentication. 


Other practices include:

 

  • Asset Management (AM)

  • Audit and Accountability (AA)

  • Awareness and Training (AT)

  • Configuration Management (CM)

  • Incident Response (IR)

  • Maintenance (MA)

  • Media Protection (MP)

  • Personnel Security (PS)

  • Physical Protection (PP)

  • Recovery (RE)

  • Risk Management (RM)

  • Security Assessment (SAS)

  • Situational Awareness (SA)

  • System and Communications Protections (SCP)

  • System and Information Integrity (SII)


The primary aim is to protect federal contract information, and it is mandatory for anyone looking to obtain a DoD contract. 


The only people who will not have to obtain Level 1 are commercial-off-the-shelf (COTS) providers who do not receive federal contract information. 

Level 2: Intermediate Cyber Hygiene (Advanced)

Level 2 requires recorded policies for each of the 17 practices covered by the certification and documentation for completing each practice's policies. 


It is a more extensive set of security practices - 55 in addition to the 17 in Level 1 - that are a subset of the NIST SP 800-171 requirements, which protect controlled unclassified information in the IT of government contractors and subtractors (NIST stands for National Institute of Standards and Technology).


The goal is to create a basic sense of cybersecurity for any organization that has CUI, which requires a higher level of security than an organization with only FCI.
 

Level 3: Good Cyber Hygiene (Advanced)

The final level mandates an organizations establish and maintain a plan to implement the requirements of CMMC. 


Level 3 includes all the practices included in Levels 1 and 2, the requirements stated in NISA SP 800-171 as well as NISA SP 800-172--which supplements NISA SP 800-171--and an additional 58 practices. 


The primary objective is to enhance the security practices established in the previous two levels and expand an organization's overall security. 

How CMMC 2.0 Differs from CMMC V1

CMMC 2.0 represents three fundamental changes that refine the original program requirements:


A Streamlined Model: CMMC 2.0 focuses on the most critical requirements, condensing the model to 3 compliance levels instead of five. Additionally, it aligns with widely accepted standards, adhering to the National Institute of Standards and Technology's cybersecurity standards. 


Reliability Assessments: Companies at Level 1 and a subset of Level 2 can demonstrate compliance through self-assessments, reducing assessment costs for third-party organizations. There is also increased accountability with increased oversight of the professional and ethical standards of third-party assessors. 


Flexible Implementation: Under limited circumstances, companies can make Plans of Action and Milestones (POA&Ms) to achieve certification, fostering a spirit of collaboration among team members. CMMC 2.0 also allows waivers to CMMC requirements under certain limited circumstances, adding flexibility and speed to the certification process. 

Next Steps for CMMC 2.0

The Department of Defense intends to pursue rulemaking for CMMC 2.0 in Part 32 of the Code of Federal Regulations (CFR) and in the Defense Federal Acquisition Regulation Supplement (DFARS) in Part 48 of the CFR.

 
Both rules will have a public comment period, as stakeholder input is essential in meeting the goals of the CMMC program. The DoD will actively seek out the opinions of others as it strives towards full implementation of the new standard.


The Department is looking to suspend current CMMC Piloting during the rulemaking process and will not include any CMMC requirement in any contract before rulemaking is completed. 


While rulemaking is underway, contractors are encouraged to enhance their cybersecurity efforts. The DoD is also looking to provide incentives to any company that obtains a CMMC certification during this time. 

When Will Compliance Become Mandatory? 

Compliance with CMMC 2.0 will not become mandatory until the rulemaking process is completed. The process is currently expected to take 9 to 24 months. 


Until that time, the DoD is following the DFARS Interim Rule, meaning only a select few pilot contractors must comply with CMMC requirements. 


But all organizations, irrespective of whether or not they must comply with CMMC at this time, should work toward implementing NISA SP 800-171 regulations. 


As soon as the rulemaking process and coding are complete, CMMC 2.0 will become a contractual requirement for all organizations looking to conduct business with the DoD. 

How To Prepare for CMMC 2.0

Companies that have already formulated their security systems plans (SSP), created POA&Ms, and computed as well as submitted their Supplier Performance Risk System (SPRS) score are in pretty good shape to make the shift toward CMMC 2.0.


For companies that haven't done so, here are some ways they can prepare and improve their cybersecurity posture: 

 

  1. Establish a technical boundary where controlled unclassified information is received, processed, and stored

  2. Define how CUI information will be shared with partners and government sponsors 

  3. Document your organization's security posture as compliant with current DFARS rules

  4. Document control implementations 

  5. Identify gaps and remediation plans in your Plans of Action and Milestones

  6. Produce and upload a DoD assessment score into the SPRS

  7. Ensure the Cybersecurity Incident Response Plan (CIRP) is updated and tested annually

  8. Continually improve in all of the aforementioned areas until CMMC 2.0 is implemented

The Importance of CMMC Compliance

Security of information is an ever-present concern, especially when working in the aerospace and defense sector. 


Companies that comply with cybersecurity standards ensure the safety of sensitive information, and they put forth an image of responsibility to the public and government officials. The CMMC 360 Group is aiming to surpass Level 2 of CMMC 2.0, reflecting our commitment to safe and secure high-performance computing. 


Interested in learning more? Get in touch to discover how The CMMC 360 Group can arm you with the right tools to take on any mission with speed, agility, and maximum protection. 

 

Find your solution.
Contact Us:

PMB# 123

13395 Voyager Parkway #130, Colorado Springs, CO 80921

info@ignite-ai.com  |  Tel: 720-436-2152

  • LinkedIn