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CMMC Compliance - Where to Start

For any business operating within the Defense Industrial Base (DIB), CMMC Compliance is no longer an option. It's a mandatory prerequisite for securing and maintaining Department of Defense (DoD) contracts.

Cybersecurity in the Defense Industrial Base (DIB)

Mandated by the Department of Defense (DoD), CMMC compliance aims to enhance the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the defense supply chain.

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Key Aspects of CMMC Compliance:

Tiered Maturity Levels

CMMC features a tiered framework, ranging from Level 1 to Level 3, with increasing requirements at each level.

Domains

CMMC is structured around cybersecurity "domains" (e.g., Access Control, System and Information Integrity).

Practices and Processes

Each domain is further defined by specific "practices" (technical activities) and "processes" (organizational maturity).

Third-Party Assessment

Compliance with CMMC requires an independent assessment by a Certified Third-Party Assessment Organization (C3PAO).

CMMC COMPLIaNCE ROADMAP: KEY STEPS

1. Define Your Scope and Data Flow

  • Identify FCI and CUI: Conduct a thorough assessment to pinpoint where FCI and CUI are created, processed, stored, and transmitted within your organization. This includes all systems, applications, and processes involved.
  • Establish Boundaries: Clearly define the “CMMC boundary” – the specific information systems, networks, and physical locations that handle CUI and FCI and therefore fall under CMMC requirements. An “enclave” approach, segregating CUI to a smaller, more easily secured environment, can be a cost-effective strategy for some.

2. Conduct a CMMC Readiness Assessment (Gap Analysis)

  • Assess Current Posture: Compare your existing cybersecurity practices against the specific controls required for your target CMMC level (e.g., the 110 controls of NIST SP 800-171 for Level 2).
  • Identify Gaps: A readiness assessment, often performed by experienced CMMC consultants like Nexeris, will highlight deficiencies in your current security posture, policies, and procedures. This provides a clear understanding of what needs to be remediated.

3. Develop a System Security Plan (SSP) and Plan of Action & Milestones (POA&M)

  • System Security Plan (SSP): This is your foundational document. It describes how your organization implements and manages each of the required CMMC controls. It’s a living document that should accurately reflect your cybersecurity environment.
  • Plan of Action & Milestones (POA&M): For any identified gaps from your readiness assessment, a POA&M outlines the corrective actions you will take, responsible parties, and target completion dates. While CMMC 2.0 allows for some POA&Ms at the time of assessment, it’s crucial to address as many deficiencies as possible beforehand.

4. Implement Technical and Procedural Controls

  • NIST SP 800-171 Implementation: For Level 2, this means diligently implementing all 110 NIST SP 800-171 security controls. This can involve:
    • Implementing strong access controls and multi-factor authentication.
    • Securing network boundaries with firewalls and intrusion detection systems.
    • Establishing robust data encryption protocols.
    • Implementing vulnerability management and patch management programs.
    • Ensuring secure configuration management for all systems.
  • Policy and Procedure Development: Beyond technical controls, you need documented policies and procedures that demonstrate how your organization consistently applies these security practices. This includes incident response plans, security awareness training programs, and data handling protocols.

5. Leverage the Right Technology and Expertise

  • Government Cloud Solutions: For organizations handling CUI, leveraging government-compliant cloud environments like Microsoft 365 GCC High or Azure Government is often a necessary step to meet CMMC requirements.
  • Managed Security Service Providers (MSSPs): Partnering with a CMMC-focused MSSP can significantly streamline your compliance journey. We offer:
    • Expert guidance throughout the entire process.
    • Implementation and management of required security controls.
    • Continuous monitoring and threat detection.
    • Assistance with documentation and evidence collection.
    • Preparation for third-party assessments.

6. Prepare for Your Assessment (if applicable)

  • Internal Reviews: Conduct internal assessments and mock audits to ensure your team is ready and your documentation is complete and accurate.
  • Train Your Team: Ensure all personnel, especially those who interact with CUI, understand their roles and responsibilities in maintaining CMMC compliance. Prepare subject matter experts (SMEs) to confidently answer assessor questions.

Start cmmc compliance for free

Our free CMMC System Security Plan and CMMC Policy templates below provide defense contractors with a significant advantage in their path to becoming CMMC compliant which can be downloaded instantly. Additionally, Nexeris offers comprehensive CMMC services designed to guide defense contractors through every stage of the CMMC compliance process.

FREE CMMC POLICY TEMPLATES

FREE

FREE SYSTEM SECURITY PLAN TEMPLATE

FREE
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Why Choose Nexeris for cmmc complaince?

Secure Your Future in the Defense Industrial Base. Partner with Nexeris as your CMMC consultant. 

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