What is CMMC?

On March 18, 2020, the Department of Defense (DoD) released Version 1.02 of the Cybersecurity Maturity Model Certification (CMMC), as a replacement for Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012. As an interim rule effective November 30, 2020; DoD contractors must have a current (not older than three years) National Institute of Standards and Technology SP 800-171 DoD Assessment on record. This interim rule helps to close the gap between DFARS and CMMC requirements.

CMMC will require a Certified 3rd Party Assessment Organization (C3PAO) to independently audit your organization and certify your compliance at a Maturity level commensurate with the data you handle. Processes to establish C3PAOs and specific audit criteria are still being developed; however, once defined, the demand for audits will be high.

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.

Maturity
Level 1

Basic Cyber Hygiene
Level 1 entails 17 basic cyber hygiene practices. Requirements include basic cybersecurity practices such as changing passwords regularly and using antivirus software to protect Federal Contract Information (FCI).

Maturity
Level 2

Intermediate Cyber Hygiene
Level 2 ups the requirements to include two processes that address documentation of policies and procedures for all CMMC domains, as well as adding 55 intermediate cyber hygiene practices. The majority of these requirements are derived from the National Institute of Standards and Technology's SP 800-171 Revision 2.

Maturity
Level 3

Good Cyber Hygiene
Level 3 requires that Cybersecurity policies and procedures are not only documented, but that they are also managed and supported by appropriate projects and resource plans. There are 110 practices sourced from NIST SP 800-171 Revision 2 standards, and an additional 20 CMMC specific practices that promote good cyber hygiene.

Maturity
Level 4

Proactive
Level 4 requires contractors to continue to progress in their process maturity and review and measure their security practices for effectiveness. Maturity Level 4 Security practices focus on proactive measures to repel Advanced Persistent Threats (APTs).

Maturity
Level 5

Advanced/Progressive
Level 5 ensures contractors standardize and optimize their cybersecurity processes and practices across the organization as needed. There are an additional 15 practices that further address the identification and removal of APTs.

Edwards & the CMMC Ecosystem

While CMMC will only apply to new contracts, it is critical to prepare for compliance now. High audit demand means you must be prepared to pass the first time or risk being waitlisted – potentially foregoing large DoD contract opportunities. CMMC compliance will be a go-no-go decision gate at the time of the contract award.

Our team of cybersecurity experts bring more than a half century’s worth of deep understanding and experience in assessing and interpreting standards, guidelines, and best practices to improve cybersecurity programs.

Edwards will play a role in nearly every aspect of the CMMC ecosystem. Currently, we provide Quick Look Assessments and develop training as a Licensed Partner Publisher (LPP). We also plan to be a Licensed Training Provider (LTP), Registered Provider Organization (RPO), and Certified 3rd Party Assessment Organization (C3PAO). Check out our CMMC FAQ page!

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