Certification
Getting CMMC certified involves understanding your specific requirements and then undergoing an assessment by a certified body. Getting CMMC certified involves understanding your specific requirements and then undergoing an assessment by a certified body. Getting CMMC certified involves understanding your specific requirements and then undergoing an assessment by a certified body.
Impact of CMMC
Regulatory Requirements and Compliance:
DFARS 252.204-7012: Your business needs to provide adequate security for Covered Defense Information (CDI) and must comply with NIST SP 800-171 for safeguarding this information. DFARS 252.204-7019 and 7020: These clauses require your business to complete a basic assessment of NIST SP 800-171 compliance and submit this assessment to the DoD Supplier Performance Risk System (SPRS) before a contract is awarded.
Levels of CMMC Compliance:
Level 1 (Foundational): If your business deals only with Federal Contract Information (FCI) and not with Controlled Unclassified Information (CUI), you would need to comply with 17 basic cybersecurity practices from NIST SP 800-171. This level does not require third-party certification, but an annual self-assessment must be documented in the SPRS.
Level 2 (Advanced): If your business holds CUI, particularly Critical National Security Information, you will need to adhere to the security controls in NIST SP 800-171. Depending on the criticality of the information, either third-party assessments every three years or self-assessments may be required.
Level 3 (Expert): This highest level involves more than 110 practices based on NIST 800-172 and is necessary for contractors involved in the most critical defense programs. These assessments will likely be conducted by the DCMA every three years.
Economic Impact:
Compliance Costs: Implementing the necessary cybersecurity practices, particularly for Level 2 and Level 3 compliance, can involve significant costs. These might include hiring cybersecurity experts, investing in secure IT infrastructure, and undergoing periodic assessments.
Contractual Opportunities: Meeting these compliance requirements could open up more opportunities to bid on and secure DoD contracts, potentially leading to increased business.
Penalties for Non-Compliance: Failure to meet these requirements can result in penalties, including the inability to compete for or retain defense contracts.
Strategic Considerations:
Assessment and Certification: Depending on the level of CMMC required for your business, you might need to invest in obtaining certifications and periodic re-assessments.
Supply Chain Compliance: You will also need to ensure that any subcontractors you work with are compliant with these standards, as the responsibility to validate compliance flows down the supply chain.
