The Department of Defense (DoD) published the Cybersecurity Maturity Model Certification (CMMC) Final Rule on October 15, 2024. This newly issued regulation (CFR 32) can be viewed in the Federal Register and will go into effect on December 16, 2024. It introduces key changes for organizations handling Controlled Unclassified Information (CUI). This blog is intended for organizations that handle CUI and are therefore required to meet CMMC Level 2.
Key Points
- Third-party assessments will be required for organizations seeking CMMC Level 2, ensuring they protect CUI using the 110 controls of NIST SP 800-171 Rev2.
- A minimum score of 88 is necessary for compliance, with limited flexibility for deferring certain controls through Plans of Action and Milestones (POAMs).
- The rule outlines the compliance obligations for Cloud Service Providers (CSPs) and External Service Providers (ESPs), such as Managed Service Providers (MSPs), that are used by Organizations Seeking Certification (OSCs) to meet CMMC standards.
- A phased rollout of CMMC contract requirements begins as early as Q2 2025, gradually increasing the number of contracts mandating compliance.
- Organizations must establish a rigorous program based on the NIST 800-171 framework, including thorough documentation such as System Security Plans (SSPs), to demonstrate compliance.
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CMMC Timeline and Rollout
The CMMC Final Rule becomes effective on December 15, 2024, at which point C3PAO assessments may begin. This rule empowers the DoD to incorporate CMMC into contracts once 48 CFR is finalized, expected in Q2 2025. Thus, contractors must be ready to demonstrate CMMC compliance starting mid-2025.
The CMMC program will be rolled out in four phases starting in Q2 2025. Each phase will last a year:
- Phase 1 (2025): DoD will begin requiring CMMC level 2 compliance in some contracts. Organizations wishing to participate in these contracts will either need to self-certify that they meet CMMC Level 2 or may be required by DoD to obtain C3PAO certification.
- Phases 2-4: The number of contracts requiring Level 2 compliance will increase, with all applicable contracts mandating CMMC certification by Phase 4.
Key Requirements for Organizations Seeking CMMC Level 2 Compliance
1. Meet NIST 800-171 Requirements
OSCs must implement all 110 NIST 800-171 controls to safeguard CUI. Key focus areas include access control, incident response, and physical security.
2. Achieve a Minimum Score of 88
While organizations may defer some non-critical, 1-point controls, the ability to use POAMs is limited and those POAMs must be completed within 180 days. Most controls must be fully implemented before certification can be achieved.
3. Cloud Service Providers (CSPs)
If an OSC uses a CSP to store, process, or transmit CUI, the CSP must meet FedRAMP Moderate Baseline Equivalent requirements as specified by the DoD in its December 21, 2023 equivalency memo or have an official Authorization to Operate (ATO). CSPs that only provide services categorized as Security Protection Assets are exempt from FedRAMP requirements but will fall within the organization’s compliance boundary and be subject to their assessment.
4. External Service Providers (ESP)
If External Service Providers (ESPs), such as Managed Service Providers (MSPs), deliver services that function as Security Protection Assets—like SIEM services, antivirus, or multi-factor authentication (MFA)—those services will fall within the organization’s compliance boundary and be subject to assessment. In these cases, the MSP is not required to obtain a separate CMMC certification, as the responsibility for compliance lies with the organization utilizing those services.
5. Flow-Down Requirements for Subcontractors
CMMC imposes flow-down obligations, meaning all subcontractors handling CUI must adhere to the same cybersecurity standards as prime contractors, ensuring protection throughout the supply chain.
6. Virtual Desktop Infrastructure (VDI) Clarifications
The final rule clarifies that host computers accessing and displaying CUI from a CMMC-compliant VDI environment via Keyboard, Video, or Mouse (KVM) may be considered out of scope for CMMC assessments. However, the VDI configuration itself is in scope and must comply fully with CMMC, including meeting applicable endpoint controls.
Achieving Compliance
Organizations seeking CMMC Level 2 compliance must focus on two key initiatives:
- Implementation of IT Systems and Policies
OSCs must implement and secure IT systems to protect CUI, following the NIST SP 800-171 framework. This includes putting in place cybersecurity practices and ensuring continuous monitoring. - Robust Documentation
Accurate documentation is crucial, with the System Security Plan (SSP) serving as the core document demonstrating compliance. The Customer Responsibility Matrix (CRM) also plays a key role, outlining shared responsibilities between the OSC and CSP/ESP. Regular updates to the SSP will be essential to maintain contract eligibility, as only a limited number of controls can be deferred through POAMs.
Regulatory Implications for OSCs
The era of deferring compliance is over. OSCs must now strategically prepare for CMMC requirements to maintain eligibility for future contracts. Key points include:
- Prepare for CMMC Now
Organizations should not delay preparation, as the regulation clarifies that the DoD may modify existing contracts or renewals to require CMMC compliance. - C3PAO assessments start on December 16, 2024
For those ready, third-party assessments can help demonstrate competitiveness in contract bids. For others, a rigorous self-assessment is the first step, followed by third-party certification once they are confident in meeting the 88-point threshold.
Conclusion
The CMMC Final Rule introduces a significant shift in cybersecurity expectations for defense contractors. By preparing now, organizations can position themselves for success in future contract opportunities. Developing a comprehensive cybersecurity program and maintaining accurate, up-to-date documentation are critical steps for compliance.
Next Steps
If your organization wishes to stay in the Defense Industrial Base, then you will need to become CMMC compliant. PreVeil can help.
PreVeil is used by over 1,200 defense contractors and provides a comprehensive solution to expedite CMMC compliance. It includes:
- Technology Platform: Our Email and Drive platform protects CUI with end-to-end encryption and meets FedRAMP Moderate Equivalent, FIPS 140-2 and DFARS 7012 c-g.
- Compliance Accelerator: We provide pre-filled CMMC documentation, assessor-validated videos and 1×1 support from our compliance experts.
- Partner Network: We support your organization through the entire compliance journey – from prep to assessment – with our network of CMMC consultants and auditors.
PreVeil provides support for 102/ 110 NIST 800-171 controls and offers videos, documentation, and advice to help walk you through how to meet the remaining controls. Our proven solution has been used by over 10 defense contractors and C3PAOs to achieve perfect 110 scores in CMMC and DoD assessments.
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