CMMC Certification Readiness: A Quick Guide to the New DoD Requirements

The Department of Defense (DoD) finalized the regulations for the Cybersecurity Maturity Model Certification (CMMC) program in October 2024. The CMMC Program mandates that defense contractors safeguard sensitive data. This data includes Federal Contract Information (FCI) and Controlled Unclassified Information (CUI), while under contract. CMMC certification readiness is becoming increasingly important for businesses with DoD contracts. It’s vital to take the necessary steps toward compliance. Relying on your IT team or a managed service provider can make this process seamless.  

What Is CMMC?

The CMMC is a set of standards from the DoD that requires defense contractors to implement cybersecurity measures (which vary based on the level needed) to protect government information. As a defense contractor, you must meet specific criteria based on what information you handle, and undergo certification. 

What Is the Final CMMC Program Rule?

The Final CMMC Program Rule introduces a requirement for defense contractors to meet security standards if they handle FCI or CUI. The rule is a part of the Defense Federal Acquisition Regulation Supplement (DFARS). It is set to be rolled out in stages, with the final DFARS rule expected no later than mid-2025. These rules will become a part of the DoD’s procurement procedures. 

How to Get Ready for CMMC Certification

Identify the Required CMMC Level

Your first step in CMMC certification readiness is to determine what level of certification your organization needs. There are three distinct levels:

• Level 1: Basic cybersecurity practices designed to protect FCI, with 15 security requirements needed.
• Level 2: More advanced security measures are needed for securing CUI, with 110 security requirements outlined in NIST SP 800-171.
• Level 3: The highest-level security measures for CUI. This level incorporates an additional 24 protections from NIST SP 800-172.

Conduct a Risk Assessment or Gap Analysis

Performing a thorough risk assessment and/or gap analysis will help you identify the areas where your existing cybersecurity systems fall short of the required standards. In Level 2 and Level 3, you have 180 days to complete the necessary requirements before “standard contractual remedies will apply.” Which typically means termination of the contractor. 

By completing one or both, you’ll understand what improvements need to be made to achieve compliance at your correct level. You may also benefit from a third-party resource completing these assessments. This will give an unbiased view of your current infrastructure and systems that are in place. 

Leverage an IT Provider to Close Gaps

Whether you choose to have your assessments done by your IT provider or not, closing any gaps with your IT provider is vital, especially if that provider has experience with DoD contracts or CMMC certification readiness. It is important to correctly implement necessary security requirements. 

The Risk of Noncompliance

As with most noncompliance with regulatory requirements, there are strict consequences. Failure to meet CMMC Program standards can result in the loss of your DoD contract and potential civil lawsuits. You must continually meet all requirements for your designated level and complete all self- and third-party assessments as often as required for your level. 

If you have a conditional status, any unmet requirements will need to be met within 180 days to avoid contract termination, withholding of payment or other penalties.  

Need Support in Determining Your CMMC Certification Readiness?

Determining your CMMC certification readiness is essential for any contractor that will be working with the DoD. When you determine the appropriate level, conduct a risk assessment or gap analysis, and work with an experienced IT support company, meeting the necessary requirements will be a breeze.  
If you need assistance with CMMC certification, SOC compliance or any other compliance support, contact the pros at OrlanTech.