Whether you work directly with the Department of Defense or are a subcontractor, you need to ensure that you comply with the most recent version of the Cybersecurity Maturity Model Certification. Failing to meet these CMMC compliance requirements will leave you ineligible for work on future defense projects. In addition, continuing to work on Department of Defense contracts without the proper certification could even result in litigation under the False Claims Act.
You don't want to find yourself in a bad position, however, you are also probably pretty confused about what you need to do to comply with CMMC requirements. Unfortunately, this confusion has caused a lot of contractors not to start working on their compliance. Fortunately, there are a few simple things you can do to ensure you are on your way to meeting these cybersecurity requirements. These will help any company that needs to meet CMMC compliance requirements do so quickly. Here are the top 4 things to do.
Like anything else, you need to start your efforts in the planning stage. A readiness assessment is the first thing you should do as it will save you time and money. While you can find a complete list of everything you need to think about in your readiness assessment on the CMMC website, one of the biggest things to consider is whether you can make the changes yourself or need help.
Aside from this, you will need to think about the cost of any changes that you will make. Be sure to set aside time in the planning stage to establish a budget that allows you to make all the necessary changes.
There are five different maturity levels for CMMC compliance that you should choose from based on the type of work you do for the Department of Defense. The requirements for each level get more intense and build upon the previous ones. For instance, the first level, basic cybersecurity hygiene, only incorporates 17 practices. The advanced level includes 171 cybersecurity practices for contractors who handle the most sensitive Department of Defense work.
For the most part, contractors can expect to need to meet the third level. This consists of 130 cybersecurity practices along with documentation of the physical and IT security policies and practices. Your job is to understand what level you’ll need for the data you handle. If you don't meet the required maturity level on your first audit, it can take a long time to perform remediations and get an appointment for a second audit.
After determining your necessary maturity level within CMMC compliance, you should start implementing changes to help you adopt these cybersecurity practices. This can include anything, such as training employees, documenting procedures and policies, installing hardware and software, and configuring servers and workstations.
This is also the time to look at Cybersecurity-as-a-Service solutions if you need them. Companies that offer these services have the tools and experience to help remediate any gaps you may have missed with your self-assessment.
Once you pass your audit, you'll want to ensure that you stay compliant. That means you need to monitor your procedures, policies, and tools constantly. In other words, the last step you should take to ensure compliance is to establish a plan for continuous cybersecurity monitoring, regular auditing, and evidence collection. One of the best ways to ensure you are regularly monitoring your compliance is to repeat a self-assessment annually.
While the maturity level and changes you need may vary based on your industry and current cybersecurity level, a few basic steps in the process will always stay the same. By completing these tasks, you can ensure that you meet CMMC compliance requirements.