Cyber Compliance

Premier Federal understands the security demands faced by both the contractors and US federal agencies. In particular, contractors currently doing business or planning to do business with the U.S. Department of Defense (DoD) are required to meet certain parameters of the Defense Federal Acquisition Regulation Supplement (DFARS). This is a government regulation that is currently applied via various NIST regulations such as 800-171, 171B, 53, etc. However, in 2020 and beyond any business / contractor planning to do business with DoD will be mandated to achieve a certain level of third party certification called Cyber Security Maturity Model Certification (CMMC).

What is CMMC?

Protecting the U.S. Department of Defense (DOD) organizations critical information is a unique responsibility. This enormous security challenge must be implemented in an environment of very large and complex networks.

The Cybersecurity Maturity Model Certification (CMMC) is the Department of Defense’s (DoD) newest verification mechanism designed to ensure that cybersecurity controls and processes adequately protect Controlled Unclassified Information (CUI) that resides on Defense Industrial Base (DIB) systems and networks.

In 2016, the DoD implemented requirements for safeguarding Covered Defense Information (CDI) and cyber incident reporting through the release of Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7012. The DFARS directed DoD Contractors to self-attest that adequate security controls were implemented within contractor systems to ensure that CDI confidentiality was maintained. In 2019, the Office of the Undersecretary of Defense for Acquisition and Sustainment (OUSD (A&S)) started the process of creating the CMMC with the finalization of the CMMC v1.0 expected in Q1 2020.

CMMC Timeline

When fully operational, the CMMC will be mandatory for all entities doing business with the DoD at any level. Prime contractors, and their subcontractors, will be required to meet one of the five CMMC trust levels, and demonstrate that cybersecurity has been sufficiently implemented through the completion of independent validation activities.

In Q1 2020 the CMMC will release a checklist for contractors which will allow them to identify how well they currently comply with the framework, and to assist with planning and implementing security maturity tasks. The CMMC will be included as a component of Requests for Information (RFIs) in mid-2020 and is expected to be included in Requests for Proposal (RFPs) by late 2020. The required CMMC compliance level will be contained in sections L & M of RFPs, making cybersecurity an “allowable cost” in DoD contracts.

CMMC Framework

The CMMC model framework categorizes Cyber Security best practices at the highest level by domains. Each domain is further segmented by a set of capabilities. Capabilities are achievements to ensure Cyber Security objectives are met within each domain. DoD contractors will demonstrate compliance with the required capabilities by adhering to practices and processes which have been mapped across the five maturity levels of CMMC. Practices will measure the technical activities required to achieve compliance with a given capability, and processes will measure the maturity of a company’s policies. Within each domain, DIB contractors will be accredited under the CMMC if they can demonstrate compliance with the required practices and mature processes as required for the given CMMC level.

CMMC Levels

There will be five cumulative Certification levels to the CMMC:

Level 1 – Basic Cyber Hygiene: Includes basic cybersecurity appropriate for small companies utilizing a subset of universally accepted common practices. The processes at this level would include some performed practices, at least in an ad hoc manner. This level has 35 security controls that must be successfully implemented.
Level 2 – Intermediate Cyber Hygiene: Includes universally accepted cybersecurity best practices. Practices at this level would be documented, and access to CUI data will require multi-factor authentication. This level includes an additional 115 security controls beyond that of Level 1.
Level 3 – Good Cyber Hygiene: Includes coverage of all NIST SP 800-171 Rev. 1 controls and additional practices beyond the scope of current CUI protection. Processes at this level are maintained and followed, and there is a comprehensive knowledge of cyber assets. This level requires an additional 91 security controls beyond those covered in Levels 1 and 2.
Level 4 – Proactive: Includes advanced and sophisticated cybersecurity practices. The processes at this level are periodically reviewed, properly resourced, and are improved regularly across the enterprise. In addition, the defensive responses operate at machine speed and there is a comprehensive knowledge of all cyber assets. This level has an additional 95 controls beyond the first three Levels.
Level 5 – Advanced / Progressive: Includes highly advanced cybersecurity practices. The processes involved at this level include continuous improvement across the enterprise and defensive responses performed at machine speed. This level requires an additional 34 controls.

CMMC Vs NIST 800-171

It is important that organizations understand that the CMMC will require a CMMC 3^rd Party Assessment Organization (C3PAO) to perform an annual independent assessment of their CMMC implementation for the security controls protecting CUI data. This would be in place of NIST 800-171 compliance through self-attestation.

In a recent audit of 10 DoD contractors servicing contracts with a value in excess of $1 million, who self-attested to compliance with NIST SP 800-171, eight were deemed deficient in implementing basic cybersecurity controls. Upon further analysis, it was determined that deficiencies were due to NIST SP 800-171 requiring compliance without regard to strength or maturity of the controls as implemented, and deficiencies in the process of ensuring ongoing, consistent control execution.

Process institutionalization (policies, plans, processes and procedures to manage the environment where the CUI resides) will be a big differentiator in CMMC because it provides assurances that the practices are being implemented effectively and in a sustainable manner.

CMMC Domains will also include four additional controls that are not currently covered under NIST 800-171: