Caleb Barlow

COMMENTARY

Four CMMC actions to take right now

Waiting will only increase risk and difficulty

As the recent SolarWinds data breach amply demonstrated, government networks are at serious risk due to third-party vendors, including many widely trusted and pervasive vendors.

Mere months before the SolarWinds breach was disclosed, the Department of Defense released the first version of a new requirement called Cybersecurity Maturity Model Certification (CMMC), mandating contractors rapidly reimagine their security protocols or risk losing DoD business.

In a CMMC model, vendors cannot negotiate on security – it becomes a mandatory requirement to win or renew a DoD contract.

CMMC’s lofty goal is to ensure that third-party organizations implement protections against cybersecurity threats to U.S. national security. It’s likely only the first step in a broader federal agency push to require more accountability from private sector vendors, whereby compliance with cybersecurity postures will be required to land future non-DoD government contracts. 

Much about the CMMC process is still unknown, including the dates when organizations will be tested, mainly because the government’s gears grind slowly. The period of transition to CMMC began in November 2020 and is expected to conclude on September 30, 2025, with rules continuing to evolve over the next four years.

Yet there are specific actions contractors can take right now to get ahead of the mandates, including preparing compliant System Security Plans (SSP) for when the proverbial flood gates open.

Preparing for CMMC is critically important because it simultaneously evaluates the security posture of an organization and assesses its maturity. In other words, CMMC isn’t just about confirming that "our organization has this control in place now," but rather that the organization can demonstrate that the control was in place for some time before, is in use today, and is currently understood by employees thanks to training.

These constitute proof points of a legitimately robust security system designed to prevent breaches, transcending mere posturing. Since the key here is time, getting a head start is invaluable.

Here are the top four actions your organization can take to improve CMMC readiness once the DoD comes knocking:

  1. Prioritize the use of tracking documents to trace necessary evidence back to the specific control. As mentioned, demonstrating the maturity of an SSP is crucial. Tracking documents will be able to provide certifiers with concrete evidence that specific controls in your plan have been in use – and successful – for some time. In short, be sure that you are updating your policies and procedures and keep track of every update – it helps to demonstrate maturity
  1. Educate employees on exactly what has changed. Even with firm cybersecurity plans in place, employees can be an organization’s Achilles heel. A recent study from Kenna Security revealed that 69% of respondents had received cybersecurity training from their employers, but 61% failed a basic quiz. Education is crucial to ensure teams understand security related policies and procedures across business units, and everyone from the most junior employee to a system administrator should be included. When an assessor starts asking your employees questions – it is imperative that they understand the organizations defined policies and procedures for security and know where to find them.
  1. Avoid getting stuck in the “we’ve always done it this way” mentality. Outdated practices and mindsets around validating security controls need to be thrown out; they won’t enable your organization to be DoD-compliant, or adequately protect sensitive data during an era when cyberattacks are growing in both numbers and severity. CMMC will balance people, processes, and technology to establish a good foundational security posture, but teams must be nimble and open to change if they hope to meet the new CMMC standards. Consider using agile techniques like daily standups as you start to prepare your CMMC documentation.
  1. Take time to prepare for CMMC certification. Institutionalizing any organization’s new policies and processes will take time. Some organizations may require cultural change – somersaults in thinking from the top down, including reversing old habits that made IT teams solely responsible for security. An organization’s stakeholders must actively participate in the cybersecurity program, which needs to be integrated into the organization’s DNA. If this doesn’t happen, CMMC will be extremely difficult to achieve. And like any organizational change – start early as one of the things you will need to demonstrate is that your policies and procedures are mature.

At this point, preparing for CMMC may feel like painting the outside of an aircraft while it’s in flight: the goalposts are moving, the process is still evolving, and certification is being handled by third-party assessors. Companies that are being told to use version one of a CMMC assessment guide that will certainly change in the months to come.

Even so, actively working towards certification now is a far better choice than standing still in the face of important and potentially overwhelming change. Being agile and adaptable will prove beneficial as the government and its contractors navigate murky waters to create a security-first environment. There is no reason to delay working on your CMMC documentation, SSP, and the associated policies and procedures now.

About the Author

Caleb Barlow is the president and CEO of CynergisTek, a healthcare-focused cybersecurity company that works with more than 1,000 healthcare organizations on data security, privacy, and compliance. Previously, he led the IBM X-Force Threat Intelligence organization. He has appeared on TED stage, TODAY, and regularly appears on national news broadcasts. Caleb’s views have appeared in the Wall Street Journal, Washington Post, USA Today, New York Times, and dozens of other publications. He testified before U.S. Congress and the United Nations by invitation of the President of the U.N. General Assembly.

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