COMMENTARY

5 steps to prepare for CMMC

Tablestakes are raised but that's a good thing

It’s full steam ahead for the Department of Defense Cybersecurity Maturity Model. This new requirement will start showing up in DoD Requests for Information as of June, although actual certification is not required until contract award.

In preparing for it, hundreds of thousands of defense contractors must take a formalized and structured approach to their cybersecurity policies and procedures – and prove their efficacy to government-sanctioned auditors.

CMMC Raises Contractor Tablestakes. That’s a Good Thing

For many, especially smaller to mid-sized companies, it requires an effort beyond anything they’ve had to do before. Because compliance verification will be ongoing, it won’t be just a one-and-done activity.

While that may seem onerous to some, CMMC actually presents a unique moment of opportunity to do a full assessment of a contractor’s security posture. That’s something that many may not do often, if at all. With 17 CMMC security domains, the five levels of CMMC certification involve multiple areas of risk that should be regularly reviewed by any company, and especially those supplying goods and services in the interest of national defense.

Consider even just the basic Level 1 certification. It requires limiting access to systems that contain Federal Contract Info (FCI) or Controlled Unclassified Information (CUI) information systems. Access needs to be role-based and restricted to authorized users and devices. Also, external information systems ranging from mobile phones and personal computers to websites or social media are prohibited from accessing FCI and CUI.

Given the number of active systems in any organization that could touch all of those requirements, from purchasing and accounting to service and customer support, that’s a lot to unpack. Yet these controls are fundamental to good cybersecurity, whether an organization is serving the DoD or any other set of customers. For DoD at least, they are no longer optional.

Preparing for CMMC - the Right Opportunity to Embrace Best Practices

While formalizing security process may be new for many smaller firms, there are five foundational actions that will help structure the effort:

  1. Map controls to your organization. The key is to start with the right comprehensive set of questions. While CMMC doesn’t prescribe to that highly detailed level, there are existing industry standards like the Shared Assessment Group Standardized Information Gathering (SIG) Questionnaire that, when correctly applied, will help a contracting organization know specifically what to assess in their policies and procedures.
  2. Consult a domain expert. Considering there are hundreds of SIG questions to choose from, the administrative burden of selecting and managing the correct ones for each contractor’s requirement can feel a bit overwhelming. When the questions are selected, a risk score will be needed for each response to indicate where challenges exist. Identified problem areas will need remediation, so a system will be needed to keep track of that as well.
  3. Gather evidence. Once the CMMC audit process is finalized in the next two or three months, it will likely mandate evidence that the required practices and processes are being met. As that can get pretty complex, a contractor’s internal assessment process should accommodate a repository for necessary documentation.
  4. Take it to the next level. Going beyond the absolute basics will demonstrate a contractor’s commitment to security and strengthen their position for DoD opportunities. As just one example, penetration testing is a high value practice to consider. CMMC Level 1 certification doesn’t specifically require a contractor to conduct penetration testing, but it is considered a best security practice for protecting sensitive data. A penetration test will readily identify known and unknown vulnerabilities, allowing them to be prioritized for remediation. The practice helps clarify strengths in the security infrastructure and also new controls that need to be implemented.
  5. Follow the data trail. Beyond the contractor’s home defenses, the security of their supply chain partners matter as well. It’s no secret that the defense supply chain is highly complex. It’s not unusual to have multiple layers of subcontractors on a large contract. Supply chain risks start at the top and trickle down, so it’s important for the prime contractor to act like a leader. If subs don’t use best practices like pen testing or vulnerability scans, that puts the prime at risk. But you can’t ask a subcontractor to do this if you haven’t done it for your own organization.

There’s a lot to get done, but it’s a critically important exercise. While CMMC is serving as a time-sensitive catalyst, all organizations, but especially defense contractors, should be regularly observing these practices anyway.

The greater opportunity in CMMC preparation is for defense contractors to use this moment for a robust assessment that will strengthen the security of their organization, and in turn strengthen the infrastructure that is essential to America’s defense.

 

About the Author

Ishan Girdhar is the CEO of Privva, Inc., a software company focused on identifying and managing supply chain risk for clients across a diverse customer base spanning legal, financial services, technology, healthcare, education, and media sectors.

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