Demystifying CMMC (and NIST)

If you’ve been in the world of cybersecurity or government supply chain recently, you have heard about the Cybersecurity Maturity Model Certification (CMMC). Even if you haven’t heard of CMMC, if you currently sell products or services that are used by others to deliver products or services to the government or otherwise receive government funding, you need to understand it. If you dig in, you will find lots of details around the regulation, timing, and impact of the new CMMC 2.0 model that went live on Monday December 16th, but it can be very overwhelming. Let’s look at what CMMC really is and how it relates to things you may or may not be doing today.

What Exactly Is CMMC?

At its core, CMMC is a framework designed to ensure the protection of sensitive information. Think of it as a set of rules to help organizations tighten their cybersecurity game. It’s built on existing standards, which have been around for a while as the go-to guide for safeguarding sensitive data.

CMMC focuses on protecting Federal Contract Information (FCI) and Controlled Unclassified Information (CUI), categories of information critical to U.S. national interests. This isn’t classified data, but it’s still sensitive enough to need strong protection. CMMC takes the principles of NIST and turns them into a certification model with three maturity levels, with each level representing a step up in cybersecurity sophistication.

(NOTE: For a more in depth look at the CMMC levels and regulation check out our previous article: CMMC Compliance is coming, are you ready?)

Why does this matter? Because organizations working in the Department of Defense (DoD) supply chain must comply. No certification? No contracts. Simple as that.    

Why you should care!

If you have federally funded contracts, or want to in the future, whether directly or indirectly through intermediary, you need to get ahead of CMMC requirements. Do you want to receive a call from your largest customer informing you that they will have to stop purchasing from you because you are not CMMC compliant? Do you want to receive a call from your panicking sales leader asking if you have CMMC compliance to meet requirements for one of the biggest opportunities this quarter?

If not, you should care about CMMC.

Additionally, if CMMC goes the way of previous, DoD backed standards, it will soon become an expected industry good practice in the United States and beyond. This can already be seen with speculation that NASA and the General Services Administration (GSA) are also expected to start including CMMC as a mandatory contract requirement.

Even if your organization isn’t required to meet CMMC standards, implementing these practices can:

  • Reduce the risk of cyberattacks
  • Build trust with customers and partners
  • Meet growing expectations for data security in various industries

NIST: The Blueprint for CMMC and Beyond

CMMC is based on NIST 800-171 and NIST 800-172, and it’s not just a government checklist, it’s a practical guide to building robust cybersecurity practices. The framework lays out 14 families of requirements, covering everything from access control to incident response. While this might sound technical many of these practices boil down to things any mature IT organization should already be doing.

These practices can be grouped into 4 categories:

  • Cybersecurity Governance Framework:
    • Sensitive data blueprint
    • Policies
    • Control objectives & controls related to Policies
    • Standards, procedures, and guidelines to secure the baseline (tech) related to controls
    • Controls related back to risks, threats, and metrics
  • Risk Management Program
    • Risk steering committee and quarterly review and planning
    • Change control & configuration management
    • Risk assessment and POA&M
    • Internal audit and accountability
    • Third-party risk management
  • Security Program
    • System Security Plan (SSP)
    • Identity & Access Management (IAM)
    • Secure baseline (system hardening)
    • Centralized device management (e.g. GPOs in active directory)
    • Data security & governance
    • Asset management
    • Network security
    • Business continuity
    • Physical security
    • Personnel Security
    • Security awareness training
    • System maintenance (patching and third-party providers)
  • Security Operations Center
    • Threat and vulnerability response
    • Incident response
    • Situational awareness (real-time risk)
    • Security continuous monitoring (SIEM)
    • Threat intelligence
    • Anomaly and event detection
    • Response planning
    • Recovery planning

These are the kinds of practices that don’t just protect sensitive data; they protect your organization from breaches, reputational damage, regulatory headaches, and even outages caused by system compromises. In a way, NIST is a cybersecurity Swiss Army knife, a versatile tool for any organization looking to up its game.

Cybersecurity is no longer optional, and frameworks like these provide a solid foundation for any business looking to mature its security posture.

The quest for IT maturity

Building a mature and secure technology foundation for your business is a never-ending journey. If you have been working towards IT maturity, you might already have many of these practices in place. Whether you are starting from scratch or just looking to align to the newest and most complete industry standards, CMMC offers a roadmap and a way to benchmark your efforts and identify areas for improvement.

For example, mature IT organizations often:

  • Regularly update and patch their systems (CMMC Level 2 requirement).
  • Train employees on recognizing phishing attempts (part of NIST 800-171’s awareness requirements).
  • Monitor systems for suspicious activity (another NIST staple).

These aren’t revolutionary practices, but they’re essential.

So, Where Do We Go From Here?

By now, you’re probably wondering: What’s the next step? Whether you’re a small business trying to secure a DoD contract, your products are used by your customers in their government contracts, or a large enterprise wanting to strengthen your security posture, here’s some advice:

  1. Assess Your Current Practices: Identify where you’re already meeting the standards and where you’re falling short and prioritize practices to mature. Workpact has partnered with FarWell to offer a fast and comprehensive assessment that can help. Contact us for additional information!
  2. Seek Help If Needed: There are plenty of resources, we can point you to tools, and offerings to help guide you through the process.
  3. Think Long-Term: Cybersecurity isn’t a one-and-done project. It’s an ongoing effort and needs to be part of the day-to-day operations of your business.

A Final Thought

CMMC isn’t just about checking boxes; it’s about fostering a culture of security. Whether you’re aiming for compliance to protect existing or grow future sales or simply trying to improve your cybersecurity posture, the principles behind CMMC and NIST offer a clear path forward. And who doesn’t want a little more clarity in a complex world?

So, roll up your sleeves and get started. The future of your organization’s security, and success, might just depend on it.

Citations

December 19, 2024