New changes have been introduced to the cybersecurity requirements DoD contractors must meet for compliance. The first version of the CMMC (Cybersecurity Maturity Model Certification) was released in January 2020, and now all contractors must achieve DoD certification before bidding on government projects.
These requirements can be confusing. CMMC certification is tier-based, meaning contractors must obtain the appropriate level based on the type of Controlled Unclassified Information (CUI) they handle. The DoD determines which level applies to each contractor.
Understanding the required DoD certification level is the first step. Once you know your level, you can take the necessary steps to meet compliance requirements and maintain eligibility for DoD contracts.
In this guide, we’ll walk you through the process for CMMC DoD certification and explain why staying compliant is critical for contractors working with the Department of Defense.
What is CMMC DoD Certification?
Since the passage of DFARS (Defense Federal Acquisition Regulation Supplement)in 2015, DoD contractors have been required to maintain specific cybersecurity protocols. These regulations ensure that private contractors working with the Department of Defense have security measures that align with the NIST SP 800-171 framework.
The Cybersecurity Maturity Model Certification (CMMC) builds on these standards. It verifies that contractors have the appropriate level of security based on the type of Controlled Unclassified Information (CUI) they handle. In essence, CMMC serves as proof that your organization meets the necessary cybersecurity requirements.
Achieving the correct DoD certification level is critical. Without it, contractors cannot bid on DoD projects, which can significantly impact revenue. Before submitting a proposal, organizations must pass a CMMC assessment for their assigned level to remain eligible for government contracts.
Understanding the Five CMMC Levels for DoD Certification
The CMMC model has five levels, each building on the previous one until an organization achieves Level 5 certification. The DoD assigns the required certification level based on the type of information a contractor handles. Here’s a breakdown of each level:
Level 1 – Basic Cyber Hygiene
- Focuses on fundamental cybersecurity practices.
- Contractors must meet requirements outlined in 48 CFR 52.204-21.
- Sets the foundation for all higher levels.
- Level 1 and Level 2 certification allow contractors to manage Federal Contract Information (FCI), which is government information not intended for public release.
Level 2 – Intermediate Cyber Hygiene
- Introduces more advanced security protocols to protect against moderate threats.
- Contractors must document their security practices, policies, and implementation plans.
- Establishes a stronger foundation for managing CUI.
Level 3 – Good Cyber Hygiene
- Implements all security controls from NIST SP 800-171.
- Contractors handling Controlled Unclassified Information (CUI) must achieve Level 3 certification.
- Protects against most cyber threats, though Advanced Persistent Threats (APTs) may still pose risks.
- Contractors must also comply with DFARS 252.204-7012, including documenting and reporting cybersecurity incidents.
Level 4 – Proactive Cyber Hygiene
- Requires a proactive approach to cybersecurity.
- Contractors must continuously upgrade their TTPs (tactics, techniques, and procedures) to counter APTs.
- Security protocols must be reviewed regularly, with issues reported promptly to upper management.
Level 5 – Advanced and Progressive Cyber Hygiene
- The highest tier in the CMMC model.
- Demonstrates an organization can protect CUI and adapt its cybersecurity program to evolving threats.
- Security processes must be standardized across all networks, including third-party associates.
Each level builds upon the previous one, ensuring contractors develop a comprehensive and mature cybersecurity program. Once a contractor knows their required DoD certification level, the next step is to prepare for the audit.
How to Prepare for a CMMC DoD Certification Audit
Preparing for a CMMC audit is essential for all DoD contractors, even for Level 1 certification. While a self-assessment cannot replace the official certification, it helps identify gaps in your cybersecurity program before the third-party audit.
1. Focus on NIST SP 800-171 Controls
The primary area to review is the controls outlined in NIST SP 800-171 Rev 1. Contractors with these controls in place should be ready for certification up to CMMC Level 3.
2. Choose Your Path: In-House or Consultant
Not all organizations are immediately ready to meet DoD CMMC requirements. There are two main options:
In-House Preparation
- Use your internal IT staff to implement required security controls.
- Reference the Self-Assessment Handbook – NIST Handbook 162, valid up to CMMC Level 3.
- Saves money but may require significant time and expertise.
- Limitation: For NIST SP 800-171 Rev B or higher CMMC levels, an in-house approach may not suffice.
Working with a CMMC Consultant
Many contractors find it more effective to partner with a certified MSSP or CMMC consultant. Benefits include:
- Faster and more efficient compliance preparation.
- Access to tools and documentation for Gap Analysis and System Security Plans.
- Assistance with remediation steps to meet CMMC controls.
- Complete documentation proving compliance during the DoD certification audit.
Outsourcing often provides peace of mind, as consultants take responsibility for ensuring compliance. This approach reduces the risk of non-compliance fines or project delays while ensuring your organization is audit-ready.
DoD CMMC Readiness Assessment
Once your security protocols are in place, the next step toward DoD certification is a CMMC Readiness Assessment conducted by a third-party MSSP or certified consultant. This assessment evaluates how close your organization is to meeting the required CMMC level standards.
Key Areas a Readiness Assessment Covers:
- Access Controls: Is access to information properly restricted and monitored?
- Training: Are system administrators and managers adequately trained?
- Data Security: Are data records securely stored and protected from breaches?
- Security Controls: Are all cybersecurity controls and measures correctly implemented?
- Incident Response: Are response plans in place and effectively executed during security incidents?
This process, often referred to as a gap analysis, is crucial. Without it, organizations may not know what changes are required to achieve DoD certification. While a gap analysis can be performed in-house, bringing in a third-party consultant offers several advantages:
- Provides an objective, expert evaluation of your cybersecurity posture.
- Helps create a remediation plan to address gaps efficiently.
Ensures your organization is fully prepared for the CMMC audit, reducing the risk of delays or failed assessments.
What is a CMMC Remediation Plan for DoD Certification?
A CMMC remediation plan is created based on the results of a Readiness Assessment. Its purpose is to address all gaps in your cybersecurity program, from small, cost-effective improvements to major system upgrades.
The remediation plan serves as a step-by-step guide for implementing the necessary changes. Everything is documented for easy reference, making it simple for your IT team, or a consultant, to track progress and ensure all security protocols are updated.
Implementing the remediation plan is critical for DoD contractors preparing for a CMMC audit. Passing the audit is essential: without DoD certification, an organization cannot bid on government contracts. Additionally, the certification process can take time, and audit schedules may have waiting lists. By following a remediation plan, contractors increase their chances of passing the audit on the first attempt, avoiding delays and compliance risks.
Important DoD Certification Dates for Contractors
To avoid delays in the CMMC audit process, DoD contractors should be aware of key milestones in the Cybersecurity Maturity Model Certification timeline. Missing these dates could delay eligibility for government contracts.
Key Milestones:
- January 2020: CMMC levels and requirements released, including auditor training materials.
- February – May 2020: Training begins for the first group of accredited CMMC assessors.
- June – September 2020: Initial CMMC audits start for contractors assigned specific certification levels. Contractors must be CMMC certified before submitting bids.
- October 2020 and Beyond: All DoD contractors must hold CMMC certification to bid on new government projects. Audits must be performed by an accredited assessor.
Consequences of Missing Milestones:
Failing to meet these deadlines may prevent a contractor from working with the Department of Defense until certification is achieved. Staying on schedule ensures compliance and uninterrupted access to DoD projects.
CMMC DoD Certification Made Easy
All DoD contractors must obtain CMMC certification by October 2020 to remain eligible for new government contracts. Achieving DoD certification requires both robust cybersecurity protocols and proper documentation. While in-house IT teams can implement these measures, partnering with an accredited MSSP or CMMC consultant is often faster and more efficient.
RSI Security helps organizations become fully compliant with NIST 800-171, DFARS, and CMMC standards. Our team ensures your CUI and CDI information is protected and meets all DoD requirements. Don’t risk delays or lost contracts—contact RSI Security today to streamline your path to DoD certification
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