Final CMMC Rule Is Coming Soon—Here’s What Contractors Must Do Today 

By and large, technology has changed our world for the better, but the positives come with other complicated side effects—including cybersecurity risks. Security breaches can damage any business’s bottom line, but in more sensitive sectors like the federal government, cybercrime can have a far-reaching and dangerous impact. 

To combat cyber theft and better safeguard government contractors, the U.S. Department of Defense (DoD) has introduced a pivotal legislative protection: the Cybersecurity Maturity Model Certification (CMMC) 2.0 framework. The CMMC 2.0 initiative aims to protect sensitive data across the defense industrial base. 

With the final CMMC 2.0 rules set to drop soon, the clock is ticking for defense and government contractors to comply. Here is a breakdown of CMMC 2.0 and immediate actions contractors should take today to ensure compliance. 

How CMMC 2.0 affects defense contracting

With the introduction of the CMMC 2.0 framework, the defense contracting landscape will undergo a transformative shift. This new set of standards is designed to better protect contractors that handle critical and sensitive defense information, helping them strengthen their cybersecurity posture. Unlike the self-attestation requirements that contractors use currently, the CMMC 2.0 framework requires contractors to undergo a third-party audit to verify compliance. With this change, the DoD has renewed its mission to safeguard national security and tighten up the defense contracting landscape through the deployment of more stringent cybersecurity measures.

Preparing for CMMC compliance

Government contractors need to start preparing for CMMC 2.0 now to implement the new rules properly and stay compliant. The first step contractors should take is to understand which of the three CMMC 2.0 compliance levels they will fall under. 

The CMMC framework consists of three cybersecurity maturity levels, each with its own specific requirements for contractors to meet based on the type of work they are performing and the sensitivity of the data they are managing. Contractors must determine the level that is most applicable to their operations and ensure they meet the corresponding requirements. The levels range from basic cyber hygiene practices to advanced and progressive security measures designed to protect against sophisticated threats.

To better understand which maturity level applies to them, contractors should review their contracts and what CUI protection clauses they are responsible for. This exercise may require contractors to update their existing policies, implement new security controls, and provide additional cybersecurity training to employees. Contractors should consider engaging with a third-party assessor early in the process to make sure they choose the appropriate maturity level within the framework and ensure they are on the right track to achieving compliance.

The Third-Party CMMC 2.0 Audit process

For government contractors, completing the third-party audit process is critical to achieving CMMC 2.0 compliance. Here’s a detailed look at how the audit flows from start to finish:

1. Start the audit: The process begins when a contractor — formally called an Organization Seeking Certification (OSC) under the DoD — contacts an authorized CMMC Third-Party Assessment Organization (C3PAO). The C3PAO is responsible for conducting official CMMC 2.0 assessments.
2. Plan and prepare for the assessment: Next, the C3PAO and the OSC plan and prepare for the assessment. During this phase, they will review the scope of the assessment, understand the specific CMMC-level requirements, and gather necessary documentation.
3. Conduct the assessment: During this phase, the C3PAO will evaluate the OSC’s CMMC compliance readiness with the required practices and controls for their respective CMMC level. The C3PAO will perform a thorough review of the OSC’s cybersecurity practices, policies, and procedures.
4. Report results: After the assessment, the C3PAO will compile a report that details its findings. This report will outline any cybersecurity deficiencies or areas that the OSC must improve to achieve the desired CMMC level. 
5. Close out the audit and remediate issues: If the C3PAO identifies any cybersecurity deficiencies as part of the assessment, the OSC must take immediate steps to address those issues and participate in a follow-up assessment if necessary. Once the OSC has met all appropriate requirements, the C3PAO will issue the CMMC 2.0 certification.

Contractors can have peace of mind in knowing that C3PAO assessors are vetted thoroughly. The CMMC Accreditation Body (CMMC-AB) oversees the authorization process for C3PAOs, ensuring they meet specific criteria and maintain the highest standards of assessment.

Looking forward: how Government contractors can stay ahead of the curve

To succeed in the ever-evolving defense contracting environment, contractors should adopt a proactive approach to cybersecurity, one that goes beyond the scope of CMMC 2.0. As technology continues to advance, new threats will emerge. Contractors must keep a pulse on the latest threats and cybersecurity best practices, while continuously monitoring their security posture and fostering a culture of cybersecurity awareness within their organization.

Additionally, contractors should leverage available resources and seek guidance from knowledgeable industry professionals to navigate the complexities of the CMMC framework. Starting this summer, CMMC compliance will be the critical prerequisite for contractors to win and maintain contracts that support the DoD. By choosing the appropriate CMMC level, preparing for compliance, and adopting practical strategies to fill cybersecurity gaps, contractors will be well-equipped to meet the new standards and thrive in the defense contracting landscape — today and tomorrow.

This article originally appeared on Washington Technology.