To enhance the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the supply chain, the U.S. Department of Defense (DoD) is working with DoD stakeholders, university-affiliated research centers, federally funded centers and industry at large to develop the Cybersecurity Maturity Model Certification (CMMC), a process that measures the ability of company within the defense industrial base (DIB) sector to protect FCI and CUI. CMMC also adds a certification element to verify implementation of cybersecurity requirements. Certifications will need to be performed by accredited third parties such as Schneider Downs, who will independently validate the proper implementation and satisfaction of the security requirements.
CMMC is designed to provide the DoD assurance that a DIB contractor can adequately protect CUI at a level commensurate with the risk and account for flow down to subcontractors in a multitier supply chain. The CMMC will be included in RFIs and RFPs in 2020 and will eventually be mandatory for all prime contractors and subcontractors.
The CMMC model framework categorizes cybersecurity best practices at the highest level by domains. Each domain is further segmented by a set of capabilities – achievements to ensure that cybersecurity objectives are met within each domain. Companies will further validate compliance with the required capabilities by demonstrating adherence to practices and processes that have been mapped across five maturity levels (explained below). Within this context, practices will measure the technical activities required to achieve compliance with a given capability requirement, while processes will measure the maturity of a company’s processes.
The CMMC model has five defined levels, each with a set of supporting practices and processes, from Level 1 that addresses basic cyber hygiene to proactive and advanced Levels 4 and 5. In parallel, processes range from being performed at Level 1, documented at Level 2 and optimized across the organization at Level 5. To meet a specific CMMC level, an organization must meet the practices and processes within that level and below. Levels are described as follows:
The CMMC model consists of 17 domains, the majority which originated from the FIPS 200 security-related areas and the NIST SP 800-171 control families. The domains are as follows:
While draft versions of the CMMC are currently available for review, the final version of CMMC is not expected to be released until January 2020. CMMC is set to start appearing in RFIs in June 2020, and the expectation is that it will start appearing in RFPs in September 2020.
As it relates to price, the FAQ section of the CMMC webpage notes that, “The cost of certification will be considered an allowable, reimbursable cost and will not be prohibitive. For contracts that require CMMC, you may be disqualified from participating if your organization is not certified.” Given that, we expect future RFIs and RFPs will allow prime contractors subcontractors to work the cost of compliance into their bids.
CMMC assessments will need to be performed by CMMC third-party assessment organizations (C3PAO), training for which is expected to take place between January and June of 2020.
Schneider Downs intends to become a C3PAO. In the meantime, until such requirements are made public, we can help your organization prepare for CMMC by performing an assessment against the NIST 800-171 framework. For more information, please Daniel J. Desko or Troy Fine.
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