CMMC 2.0 UPDATES:

Our Frequently Asked Questions have been updated to reflect the most recent information provided by the CMMC-AB and the Department of Defense.

Cybersecurity Maturity Model Certification

On March 18, 2020, the Department of Defense (DoD) released Version 1.02 of the Cybersecurity Maturity Model Certification (CMMC) document, as a replacement for Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012.Since that time federal contracting companies have been inquiring about CMMC, and asking questions about this topic. To help contractors, clients, and potential prospects, Edwards Performance Solutions has provided a list of the most frequently asked questions (FAQ) and DoD related questions below.

CMMC 2.0

The short answer is no. According to the CMMC-AB, CMMC 1.0 has been “OBE” (overcome by events). With that said, the majority of requirements of CMMC 1.0 will be implemented in CMMC 2.0.

The interim DFARS rule established a five-year phase-in period, during which CMMC compliance is only required in select pilot contracts, as approved by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD(A&S)). The Department does not intend to approve inclusion of a CMMC requirement in any contract prior to completion of the CMMC 2.0 rulemaking process.

Once CMMC 2.0 is codified through rulemaking, the Department will require companies to adhere to the revised CMMC framework according to requirements set forth in regulation.

The publication of materials relating to CMMC 2.0 reflect the Department’s strategic intent with respect to the CMMC program; however, CMMC 2.0 will not be a contractual requirement until the Department completes rulemaking to implement the program. The rulemaking process and timelines can take 9-24 months. CMMC 2.0 will become a contract requirement once rulemaking is completed.

The Department values feedback from industry, Congress, and other stakeholders and received over 850 public comments in response to the interim rule establishing CMMC 1.0. These comments focused on the need to enhance CMMC by (1) reducing costs, particularly for small businesses; (2) increasing trust in the CMMC assessment ecosystem; and (3) clarifying and aligning cybersecurity requirements to other federal requirements and commonly accepted standards. CMMC 2.0 was designed to meet these goals, which also contribute toward enhancing the cybersecurity of the defense industrial base.

The Department will publish a comprehensive cost analysis associated with each level of CMMC 2.0 as part of rulemaking. Costs are projected to be significantly lower relative to CMMC 1.0 because the Department intends to (a) streamline requirements at all levels, eliminating CMMC-unique practices and maturity processes, (b) allow companies associated with the new Level 1 (Foundational) and some Level 2 (Advanced) acquisition programs to perform self-assessments rather than third-party assessments, and (c) increase oversight of the third-party assessment ecosystem.

Once CMMC 2.0 is implemented, DoD will specify the required CMMC level in the solicitation and in any Requests for Information (RFIs), if utilized.

Under CMMC 2.0, the “Advanced” level (Level 2) will be equivalent to the NIST SP 800-171r2 which is carried into the CMMC-AB Level 1 and Level 2 Assessor Guides with a CMMC-specific numbering system. The “Expert” level (Level 3), which is currently under development, will be based on a subset of NIST SP 800-172 requirements.

Once CMMC 2.0 is implemented, self-assessments, associated with Level 1 and a subset of Level 2 programs, will be required on an annual basis. Third-party and government-led assessments, associated with some Level 2 and all Level 3 programs, will be required on a triennial basis.

Once CMMC 2.0 is fully implemented, DoD will only accept CMMC assessments provided by an authorized and accredited C3PAO and C3PAOs shall use only Certified CMMC Assessors (CCAs) for the conduct of CMMC assessments.

DoD’s intent under CMMC 2.0 is that if a DIB company does not process, store, or transmit Controlled Unclassified Information (CUI) on its unclassified network, but does process, store or handle Federal Contract Information (FCI), then it must perform a CMMC Level 1 self-assessment and submit the results with an annual affirmation by a senior company official into SPRS.

CMMC only applies to DIB contractor’s unclassified networks that process, store or transmit FCI or CUI.

No, the results will not be made public. Once CMMC 2.0 is fully implemented, the DoD will have access to information and data relating to a company’s assessment, to include the assessment results and final report. The DoD will store all self-assessment results on SPRS. CMMC certificates and the associated third-party assessment data will be stored in the CMMC Enterprise Mission Assurance Support Services (eMASS) database. CMMC eMASS will automatically post a copy of a company’s CMMC certificate to the Supplier Performance Risk System (SPRS). The detailed results of a CMMC assessment will not be made public.

If a company voluntarily chooses to obtain a CMMC assessment and certification from a third-party assessment organization in the absence of a contractual requirement, the company must provide written consent to allow DoD access to or use of those assessment results. If a company consents to DoD access and use of data relating to the assessment, then DoD intends to store that information on eMASS.

The CMMC assessment costs will depend upon several factors including the CMMC level, complexity of the DIB company’s unclassified network for the certification boundary, and market forces. DoD will develop a new cost estimate associated with CMMC 2.0 to account for the changes made to the program which will be published on the Federal Register as part of the rulemaking process.

A CMMC self-assessment will apply to those companies that are only required to protect the information systems on which FCI is processed, stored or transmitted; and a subset of companies that are required to protect CUI. The CMMC self-assessment should be completed using the CMMC Assessment Guide codified in 32 CFR for the appropriate CMMC level. A CMMC self-attestation is a representation that the offeror meets the requirements of the CMMC level required by the solicitation. The CMMC program will require an annual self-assessment and an annual affirmation by a senior company official.

A “Basic Assessment”, as defined in DFARS clause 252.204-7020, NIST SP 800-171 DoD Assessment Requirements, means a contractor’s self-assessment of the contractor’s implementation of NIST SP 800-171 that:

  1. Is based on the Contractor’s review of their system security plan(s) associated with covered contractor information system(s);
  2. Is conducted in accordance with the NIST SP 800-171 DoD Assessment Methodology; and
  3. Results in a confidence level of “Low” in the resulting score, because it is a self-generated score.

The DoD intends to engage with our international partners to establish agreements related to cybersecurity and ensure that foreign companies that support U.S. warfighters will be equipped to safeguard sensitive national security information. These agreements will establish a framework to address application of CMMC to non-US companies. Implementation of such agreements will be accomplished through the rulemaking process.

The Department is pursuing development of acceptance standards between CMMC and other cybersecurity standards and assessments, to include between CMMC Level 2 (Advanced) and the NIST SP 800-171 DoD Assessment Methodology for the high assessment confidence level, as well as CMMC Level 2 and the GSA Federal Risk and Authorization Management Program (FedRAMP) requirements for commercial cloud service offerings.

Furthermore, DoD is working with international partners to coordinate on potential agreements between CMMC and their respective cybersecurity programs.

Any such equivalencies or acceptance standards, if established, will be implemented as part of the rulemaking process.

CMMC 101

The CMMC-AB website and newsletter provide the latest information. Edwards website also adds regular updates to our dedicated CMMC webpage explaining how updates can potentially affect your organization, and how we can help.

There are three components to undertstanding the CMMC Model - the CMMC Model itself, the CMMC Assessment Guide, and the NIST 800-171r2 Framework. Visit the Office of the Under Secretary of Defense for Aquisition & Sustainment.

Originally, the DoD stated it plans to introduce CMMC requirements into the first 15 solicitations starting in March 2021 and will build more CMMC requirements into solicitations over the next four years. CMMC requirements are already present in some pre-RFP documentation.2.0 is planned to introduce CMMC requirements into solicitations as soon as final rulemaking is complete, in 9-24 months.

A Licensed Partner Publisher provide the materials for Licensed Training Partners (LTPs), used by their Certified Instructors for training Certified CMMC Professionals, Certified CMMC Assessor Level 1, and Certified CMMC Assessor Level 3 candidates.

Licensed Training Providers (LTPs) are private companies who specialize in cybersecurity assessments and professional instruction (like Edwards), as well as the universities, community colleges, and other learning institutions that train Certified Professionals and Certified Assessors.

Certified Third-Party Assessment Organizations (C3PAOs) are organizations employing Certified CMMC Assessors (CCAs) and Certified CMMC Professionals (CCPs), ensuring they adhere to the CMMC-AB Code of Professional Conduct. C3PAOs provide quality assurance of the assessment process and results, and presents them for final certification to the CMMC-AB. C3PAO's themselves must meet stringent standards, internal CMMC certification, and can be verified on the CMMC marketplace if they are currently an approved CMMC provider.

In September 2020, the CMMC-AB approved the first LPPs to deliver certification curriculum and published a list on their  website. Edwards is proud to have been selected as an LPP and we are currently delivering our first CMMC-AB Approved Training Materials (CATM), including the Certified CMMC-AB Professional (CCP) Field Guide, CCP Student Workbook and Instructors PowerPoint Slides. Visit our Edwards training platform for upcoming courses.

Many OSCs need a trusted consultant to support their CMMC journey from preparation through certification. RPOs employ credentialed Registered Practitioners, who are qualified to provide CMMC consulting and support to OSCs in the Defense Industrial Base (DIB). The CMMC-AB created the RPO certification to provide approved organizations known for their quality and dedication to CMMC standards. Edwards is a RPO, certified through the CMMC-AB, and each member of our Cybersecurity Team are RPs.

Edwards is a Candidate C3PAO. A comprehensive list of C3PAOs at all stages of approval is available on the CMMC-AB Marketplace.

Yes, Edwards is a CMMC-AB approved Licensed Partner Publisher (LPP). We currently offer the Certified CMMC Professional (CCP) based on the CMMC-AB Approved Training Materials (CATM), as well as CMMC informational courses such as CMMC Executive Overview and CMMC Fundamentals. Contact us at Training@EdwPS.com or visit our training platform for more information.

Controlled Unclassified Information. Organizations proccessing CUI must achieve Maturity Level 3.

Federal Contract Information. Organizations handling FCI must achieve a minimum Maturity Level 1.

The Maturity Levels (Level 1 - Level 3) are dependent upon what type of data you and your subcontractors hold, process, or create in support of DoD contracts. All DoD contractors and subcontractors are required to attain at least Maturity Level 1 compliance if they handle Federal Contract Information (FCI). Those processing Controlled Unclassified Information (CUI) must achieve Maturity Level 3. More information about the levels and corresponding requirements, as well as impact to your business, is one of the focuses of our informational courses: CMMC Executive Overview and CMMC Fundamentals, available for groups of 10 or more upon request. Contact us at training@edwps.com for more information.

The CMMC-AB suggests that you plan for the certification process to take 6+ months. Currently, no LTP's (Licensed Training Providers) can offer the CMMC-AB approved courses that are required to sit for the certification exams: CCP, CCA-1 and CCA-3. The LTPs expect for the DoD final documentation and learning objectives to be issued in time to deliver courses starting in Q3/Q4 of 2021.

To become CMMC certified, an organization must schedule an assessment with a C3PAO. The certification is valid for 3 years. More information can be found on the CMMC-AB website.

Many OSCs need a trusted consultant to support their CMMC journey from preparation through certification. RPOs employ credentialed Registered PR actioners, who are qualified to provide CMMC consulting and support to OSCs in the Defense Industrial Base (DIB). The CMMC-AB created the RPO certification to provide approved organizations known for their quality and dedication to CMMC standards. Edwards is a Registered Provider Organization, certified through the CMMC-AB, and several members of our Cybersecurity Team are Registered Practitioners.

Consulting & Audits

Once the standard is complete, the training is developed, and Certified CMMC Assessors are certified to conduct assessments, the CMMC-AB will release a publicly available list of CCAs on their website.

Organizations Seeking Certification (OSC) should contract with a RPO or a C3PAO to help prepare for either Level 1 or Level 2 certification from CMMC. Only approved C3PAOs can conduct the official assessment, and you cannot contract with the same provider for both the pre-assessment consulting services (i.e., RPOs) and the actual CMMC assessment (i.e., C3PAO). You can find verified RPOs and approved C3PAOs on the CMMC Marketplace.

As of January 2021, the CMMC-AB established a small group of Provisional Assessors and will be working with a small group of Provisional Instructors, to start rolling out CMMC-AB approved training. The final learning objectives for the CMMC 2.0 CCP training are expected in February 2022, with most LPPs and LTPs currently delivering the original CCP training now. The Certified CMMC Assessor (CCA) approved training should follow within six months. Prerequisites can be found on the CMMC-AB website.

A Certified CMMC Assessor will be qualified to lead a CMMC Assessment Team under a C3PAO, for an assessment up to level 2. Certified CMMC Professionals may participate as part of the C3PAO assessment team at Level 1 or 2, but cannot lead the assessment.

Organizations Seeking Certification (OSC) should contract with a RPO or a C3PAO to help prepare for either Level 1 or Level 3 certification from CMMC. Only C3PAOs can conduct the official assessment, and you cannot contract with the same provider for both the pre-assessment consulting services (i.e., RPOs) and the actual CMMC assessment/audit (i.e., C3PAO). You can find verified RPOs and C3PAOs on the CMMC Marketplace.

As of January 2022, a small group of C3PAOs have been approved to conduct formal CMMC assessments; OSCs should expect to contract with an approved C3PAO within Q1 of 2022.

The CMMC Marketplace lists many C3PAOs with some background information on each organization, including Edwards Performance Solutions. It is important to understand the agreed upon level of assessment your organization needs (Level 1 or Level 2),the scope of the assessment and pricing prior to entering into a contract with a C3PAO.

Many RPOs and C3PAOs are available to assist your organization in preparing for the assessment. You can select from many already available on the CMMC marketplace or contact us at Info@EdwPS.comto discuss how Edwards Performance Solutions can help you prepare..

Organizations Seeking Certification (OSC's) can contract with a RPO or a C3PAO to help prepare for a Level 1 or Level 2 self-attestation, but it is not required. OSCs who need the Level2 assessment certification will need to contract with an approved a C3PAO. Only C3PAOs can conduct the official assessment, and you cannot contract with the same C3PAO for both the pre-assessment consulting services and the actual CMMC assessment. You can find verified RPOs and approved C3PAOs on the CMMC Marketplace.

CMMC is currently planning on listing CMMC preparedness tools on the CMMC marketplace. We expect this will be available in Q2 2022.

Education & Training

As of January 2021, the CMMC-AB established a small group of Provisional Assessors and will be working with a small group of Provisional Instructors, to start rolling out CMMC-AB approved training. The final learning objectives for the CMMC 2.0 CCP training are expected in February 2022, with most LPPs and LTPs currently delivering the original CCP training now. The Certified CMMC Assessor (CCA) approved training should follow within six months. Prerequisites can be found on the CMMC-AB website.

We offer five-day official CMMC-AB (pending CMMC-AB approval) Certification bootcamp courses as well as a weekly 90-minute facilitated peer discussion groups. Check our training platform for the learning solution that is right for you.

Edwards will include many additional resources with the live, instructor-led CMMC courses. Check our training platform for more information on what we include with each course - materials will range from the official CCP Field Guide, to editable digital workbooks, free download resources, free study groups, and more.

Yes. Participants in the CMMC-AB Certified Assessor 5-Day Course will not be permitted to take the associated exam until they have provided proof of Certified CMMC-AB Professional 5-Day Course and Exam. In other words, the official CMMC-AB courses will build upon each other. You can find links to these courses along with what is included in the registration, on our training platform.

Our courses are updated continuously to provide the most accurate recent information about CMMC.

Once the standard is complete, the training is developed, and Certified CMMC Assessors are certified to conduct assessments, the CMMC-AB will release a publicly available list of CCAs on their website.