How supply chain communications prepares contractors for CMMC certification

October 10, 2023

For two years, Department of Defense leaders have pushed hard to address private sector concerns about complexity, cost, and necessity surrounding the Cybersecurity Maturity Model Certification (CMMC).

That has led to a projected finalized rulemaking for CMMC implementation in the first quarter of fiscal year 2025. It’s a deadline that DOD seems determined to hold onto even with a potential government shutdown still looming and the newly announced inspector general accreditation audit.

Contractors can’t sit back and wait for updated timelines or rulemaking guidance. It takes 12 to 18 months to navigate the 110 security controls in the CMMC certification process. Once CMMC rulemaking is complete, contractors who aren’t certified won’t be able to contract with DOD as a prime or subcontractor. That can mean losing current contracts and not being able to bid on new requests for proposals which contain CMMC requirements.

Here’s what DOD contractors need to know to avoid the pitfalls of not being certified, and to turn the investment of certification into long-term growth opportunities.

What CMMC certification means for your company

Companies that become certified will keep existing business and earn a well-deserved reputation within the industry. They’ll also be in the relatively select category of companies that can pursue a broader scope of contracts within DOD in the short term and within certain civilian agencies as the latter implement CMMC.

Companies that fail to be certified will face two levels of problems. The first is that they won’t be able to bid on new requests for proposals that contain CMMC requirements. Secondly, they may have to start over on the certification process if they have critical flaws. Even worse, however, they risk losing current contracts – which will cost them revenue, key cybersecurity talent, and relationships with partners like banks and insurers.

Fiscal 2025 seems like a long way off, but it’s going to come fast. It’s in DOD contractors’ best interests to assume that CMMC is going to be reality sooner rather than later.

Communicate with your supply chain

Much of the CMMC attention has focused on prime contractors because of their role with DOD. But certification goes all the way down the supply chain, to the smallest subcontractor. All it takes is a wayward thumb drive or an employee with donuts instead of documents on his mind to blow up the entire system, taking down contracts worth hundreds of millions of dollars. DOD will require CMMC to be included in mandatory contractual flow clauses.

Many prime contractors send letters to their supply chain partners informing them of upcoming CMMC requirements and their obligation to comply.  But it’s too easy for smaller contractors not plugged into the regulatory apparatus to simply confuse it as just more paperwork from yet another compliance department.

Therefore, contractors higher in the supply chain have to show why compliance matters, and build trusted relationships so that everyone is ready to work together to be CMMC-certified.

One way to do that is ensuring that you and your contractors use only Cyber AB authorized assessors and certified CMMC professionals. Be alert to companies that claim to be part of the ecosystem but are not officially registered.

Second: understand where your subcontractors stand in the approval process. Larger prime contractors may find it worth the investment to pay for, or subsidize the cost of, a mock assessment for their subcontractors so they know what level of risk they might be inheriting.

Also help your subs who don’t have the revenue, time, or other resources to become certified. Donating your learned best practices, volunteering key people’s expertise, or providing enclaves for storage may cost you a little now, but you’ll get yourself as close as anyone can reasonably expect to an impregnable company, safe from hackers as well as fines and other punishments which are common after breaches.

CMMC certification ensures that there is a baseline of high-quality technology and processes for the protection of DOD Controlled Unclassified Information. What may separate your company from the competition is how well you choose to communicate, and invest, up and down your supply chain.

3 approaches to prepare for CMMC certification

The journey to CMMC compliance depends on factors like your expertise (do you have an internal cyber team?), time constraints (is your cyber team bogged down with other tasks?), and finances (what investments are needed in technology, processes, and polices).

Step one is to download a version of NIST 800-172a which can be used to guide an internal team in implementing the 110 controls of NIST 800-171. That will require a certain level of technical knowledge from the internal team.

Second: hire a Registered Practitioner Organization to assist you in preparing your organization for certification. This may be an expensive option, but it offers the advantage of getting specialized experts on your team.

A hybrid approach can also come in handy. Look to your internal team for some matters and outside consultants for others. For example, you may decide to develop your policies and procedures in house but engage an RPO to help implement technical configurations in your network environment.

Whatever approach you choose, start now. It takes anywhere from 12-18 months to fully address all 110 controls of NIST 800-171. When you’re ready, the next step is to sign up with an authorized CMMC Third Party Assessment Organization.

Most C3PAOs offer a mock assessment, which simulates a real assessment and gives you insight into areas where you might still have gaps to fill; and the official assessment where you receive an official result.

There’s also a near-term option which has been very beneficial to DOD contractors which seek CMMC certification. The Pentagon’s interim Joint Surveillance Voluntary Program is offering a voluntary NIST 800-171 assessment conducted by a C3PAO in conjunction with the Defense Industrial Base’s Cybersecurity Assessment Center.

DOD’s stated intent is that contractors which pass the rigorous assessment will earn a Level 2 certification for three years. However, the voluntary program will only be available until rulemaking is finalized.

CMMC 2.0 is here – are you ready?

The Department of Defense has at least 300,000 contractors, with multiple potential cybersecurity breach points endangering every single one. National security concerns aren’t going to wait for the government shutdown threat to end, the election results, or an IG audit.

That’s why DOD leadership is pushing full-bore for CMMC finalized rulemaking. And it’s why being CMMC-compliant is the best way for DOD contractors to turn serving the national defense into a good offense for your business’s future.

Dustin Siggins & Ola Sage originally published this piece at Washington Technology.

Leave a Comment

Your email address will not be published. Required fields are marked *