As cyber threats continue to rise, businesses working with the Department of Defense must strengthen their security measures to protect critical information. That is where the Cybersecurity Maturity Model Certification, or CMMC, comes in. The CMMC provides a framework for companies to secure sensitive government information. This becomes crucial for businesses handling Federal Contract Information or Controlled Unclassified Information.
Moreover, the DoD has recently made some significant changes to CMMC. There was an older structure of five levels, which was reduced to three. This was to simplify the process while keeping the security strong. At the same time as these changes were being developed, newer questions began to grow.
Therefore, if you are part of the defense supply chain, you might wonder how to prepare. The article below answers five most frequently asked questions about recent updates.
1. What Are The Recent Updates To The CMMC Framework?
Much work has been done to revise the CMMC framework to make it more practical and easier to adhere to. Below are some of the key changes that led to the reduction of the CMMC levels from five to three under CMMC 2.0:
- Level 1 (Foundational): Basic set of cyber security practices. For use by companies that handle FCI.
- Level 2 (Advanced): This replaces the previous Level 3. It applies to companies handling Controlled Unclassified Information (CUI) and requires adherence to NIST SP 800-171 security controls.
- Level 3 (Expert): This level is for organizations that deal with highly sensitive information. It employs advanced security requirements from NIST SP 800-172.
Other key changes include the introduction of self-assessments, which means companies can self-assess at Level 1 instead of requiring a third-party audit. Moreover, at Level 2, some businesses may also self-assess, depending on their contract type. For organizations looking to stay informed, the CMMC news provides valuable updates.
2. How Do These Updates Impact Compliance Timelines?
Compliance timelines also shift under the updated framework. Whereas under CMMC 1.0, it was unclear precisely when companies would need to become compliant, under CMMC 2.0, the DoD has provided some clarity on the timeline for compliance. Moreover, the DoD is expected to complete the rulemaking by the end of 2025.
Furthermore, companies already working towards compliance now have more time to work out the fine details. This will allow them to fine-tune security, place all vital policy documentation, and shut any outstanding gaps.
3. Will There Be Changes To The Assessment Process?
Yes, the assessment process has changed under CMMC 2.0, and these changes ease things for business. Among the primary goals of the new version, one can mention the reduction of costs, especially for those small companies with minimal resources.
Additionally, in CMMC 1.0, all the companies required third-party audits, which were very costly and complex. However, CMMC 2.0 introduces the following differentiated approach:
- Level 1 assessments are now self-assessments. Companies that handle only Federal Contract Information, or FCI, can check their cybersecurity practices without hiring an outside auditor. This dramatically lowers costs and makes compliance easier for smaller businesses.
- Level 2 can be a self-assessment or third-party assessment. If an organization deals with less sensitive, unclassified information, it might be allowed to self-assess.
- Level 3 assessments will still require third-party audits. These are very likely to be carried out by government officials since highly sensitive data is a concern.
Another major shift involves the frequency at which audits need to be carried out by organizations. Levels 2 and 3 businesses would require a third-party audit once every three years, besides performing annual self-assessments whose reports will be submitted to the DoD.
4. What are the key differences between the previous and current CMMC versions?
The key differences between CMMC 1.0 and CMMC 2.0 can be summarized in three major areas: structure, process requirements, and assessment models.
First, it has a simplified structure. CMMC 1.0 over-complicated things because it had five levels, each with higher security requirements moving up the chain. Many times, this wasn’t very clear and did not make compliance any more straightforward. In the case of CMMC 2.0, only three levels exist now.
Second, CMMC 2.0 is also more aligned with the NIST standard. For example, Level 2 now aligns directly with the 110 controls in the NIST SP 800-171, while Level 3 consists of more advanced controls from NIST SP 800-172.
Third, the assessment burden was reduced in CMMC 2.0. While in CMMC 1.0, all levels had to be audited by a third party, the burden on businesses was too high, especially for smaller companies.
5. How can organizations prepare for the updated CMMC requirements?
Organizations can do several things in preparation for the new CMMC version. Since this latest version emphasizes practical cybersecurity, it is vital to be adequately prepared. Here is how:
First, carry out the gap analysis and compare your current cybersecurity setup against the requirements of the CMMC. For Level 2, compare practices with the controls under the NIST SP 800-171, whereas on Level 1, one should go through the basic security measures that are kept in the organization.
Next, pay attention to documentation, as good documentation is necessary when making your case that you meet the requirements. Besides, ensure your policies and procedures, including security controls, are in writing, up to date, and available.
Wrapping Up
These changes to the CMMC framework are crucial updates for those organizations that work with sensitive government information. This means that CMMC 2.0 removes some of the unnecessary complexity of its predecessor, further aligns with existing standards set forth by NIST today and therefore makes compliance more straightforward to manage. But with all these changes come new responsibilities. Thus, companies must understand what is different, keep track of timelines, and prepare for assessments in advance.
