Cybersecurity Maturity Model Certification: Is It Really That Scary?

If you’re involved in IT budgeting, scoping, or planning—whether for a small business or as part of a large corporation—you’ve likely heard of the Cybersecurity Maturity Model Certification (CMMC). But what exactly is CMMC, and is it really as intimidating as it sounds?

CMMC is a cybersecurity framework designed to strengthen the security posture of companies working with the Department of Defense (DoD). It provides a structured approach to ensuring organizations meet specific security standards, many of which are aligned with NIST (National Institute of Standards and Technology) controls, such as those in NIST SP 800-53 and NIST SP 800-171. These standards ensure robust cybersecurity measures across critical systems and data.

Even complying with the most basic level of this framework has become a practical and common-sense strategy for most IT professionals. For instance, implementing Multi-Factor Authentication (MFA) and other basic security controls should now be standard practice. If your organization is still lacking these fundamental measures, it may need more attention than you realize. In today’s environment, where security threats are rampant, it’s no longer a matter of if a breach will occur, but when.

Adopting the CMMC framework not only helps you comply with DoD regulations but also puts your organization in a much more secure and resilient position overall. Too often, security measures and controls are sacrificed for the sake of convenience, but that approach is becoming outdated. If you’re using cloud services to manage identities, you’re likely already using some form of security solution. The goal now is to maximize your investment in current systems while eliminating any gaps in your security architecture.

To help you get started, here’s a quick checklist to ensure your environment is on track for CMMC v1 and v2 compliance, with considerations for NIST controls:

• Multi-Factor Authentication (MFA): Ensure MFA is enabled for all critical systems to meet NIST control requirements for access control (AC-17, IA-5).
• Access Controls: Implement strict access controls to limit who can access sensitive information, following NIST guidelines (AC-1, AC-3, AC-6).
• Regular Audits: Conduct regular security audits to identify and address vulnerabilities, as required by NIST (CA-7, AU-2).
• Incident Response Plan: Have a comprehensive plan in place to respond quickly to any security breaches, as per NIST recommendations (IR-1, IR-4).

Understanding CMMC Levels

The DoD recently issued updated guidance outlining how it will determine CMMC levels for its solicitations and contracts. Here’s a breakdown of the different levels:

• CMMC Level 1: Requires a self-assessment for contractors who process, store, or transmit only Federal Contract Information (FCI). This level is suitable for contractors who do not handle Controlled Unclassified Information (CUI).
• CMMC Level 2: This level is unique because it involves both a self-assessment and certification. Contracts that require a CMMC Level 2 certification involve receiving CUI under the National Archive’s “Defense Organizational Index Grouping.” Non-Defense CUI contracts may only require a self-assessment.
• CMMC Level 3: Reserved for contracts involving advanced technologies, significant aggregation of CUI, or those where an attack could cause widespread vulnerabilities across the DoD. Very few contracts will require this level.

For organizations using Microsoft 365 to manage their environments, there’s additional complexity to manage. Here at Covenant Technology Partners, we have developed a 300+ point checklist to ensure that your Microsoft 365 tenant aligns with both CMMC requirements and best practices for cybersecurity. This checklist provides a comprehensive, granular approach to securing your Microsoft 365 environment, identifying gaps and ensuring compliance with critical NIST controls.

Ultimately, contractors should pursue the CMMC level appropriate for the types of DoD information they handle and their future business goals. To avoid missing out on contracting opportunities, it’s crucial not to delay identifying and obtaining the CMMC level that aligns with your needs.

By understanding and implementing the CMMC framework, your organization can significantly enhance its cybersecurity posture and be well-prepared to meet DoD requirements, backed by the security controls outlined in NIST’s extensive guidelines.