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Overview of CMMC Level 4 Requirements

Welcome to the fourth installment of our series on the Cybersecurity Maturity Model Certification (CMMC), a framework required for companies contracting with the US Department of Defense (DoD). In this guide, we’ll break down everything you need to know about CMMC Level 4. For information about other levels of the CMMC, see our guides, levels 1, 2, 3, and 5.

Overview of CMMC Level 4 Requirements

The key to complying with CMMC requirements at all levels is understanding exactly what is required. To that end, this blog (and the whole series) is built around descriptions of all practices for each given level, sourced directly from CMMC Volume 1.02 from March 2020.

Like all articles in the series, we’ll begin with an overview (or recap) of the CMMC Framework, including baseline definitions and concepts that apply across all levels. Then, like the past few installments, the structure below breaks down as follows:

Let’s get started!

 

Overall CMMC Framework at a Glance

The CMMC is a robust system of interlocking cybersecurity controls, spread across various categories, that track the ongoing growth of an organization’s cybersecurity. In particular, the main structural elements of the framework are:

This scheme is intended to increase a company’s overall cyberdefense posture. But it is also intended to safeguard two particular categories of information. Namely:

These forms of information are relatively unique to a certain sector, the Defense Industrial Base sector (DIB), which comprises the vast network of DoD contractors that make up its supply chain. Given the importance of this information to the DoD, and how critical the DoD is to the security of all Americans, the stakes of safeguarding FCI and CUI are incredibly high.

That’s why the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD(A&S)) worked together with University Affiliated Research Centers (UARCs) and Federally Funded Research and Development Centers (FFRDs) to develop the CMMC.

Importantly, the CMMC also incorporates controls from a variety of other sources, and Level 4 involves the addition of new sources not present at earlier levels. Let’s take a quick look.

 

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Breakdown of Control Sources at Level 4

As we’ve touched on in earlier installments, The CMMC framework is not a completely new set of controls with no precedents. Instead, much of its substance is a patchwork of various other cybersecurity frameworks; the CMMC collects and integrates them in one cohesive whole.

In particular, the other frameworks include, but are not limited to:

The primary focus of the first three levels is protecting FCI and CUI, which culminates at Level 3 with the implementation of all of NIST SP 800-171. But at Level 4, a key new source text is introduced: Draft NIST SP 800-171B, recently superseded by NIST SP 800-172.

This new draft builds on CUI protections detailed in SP 800-171, modernizing those controls in response to the increasing prevalence of Advanced Persistent Threats (APT). The focus at Level 4 shifts to prioritize APT, which necessitates advanced controls from this novel source.

Synopsis of CMMC Level 4 Controls

Level 4 of the CMMC adds just 26 new practices, for a total of 156 — this is a drastic change from the previous 2 levels, each of which added over 50 new controls. However, the lower number of new practices is offset by their relative depth and breadth, as well as the cumulative challenge of balancing all 156. Of the 26 new Level 4 practices, 11 come from SP 800-172.

Another major challenge in Level 4 is the advancement in the institutionalization of processes. Whereas Level 3 brought the challenge of management to its 130 practices, Level 4 adds another layer, “reviewed,” to its 156. This involves the systematic assessment of implementation and management, as well as regular and prompt corrective actions taken when issues arise.

This dimension of review is meant to counteract APTs. By definition, these adversaries “possess sophisticated levels of expertise” and leverage “multiple attack vectors.” So, enhanced visibility and transparency, in real-time, is needed to combat them. That’s what Level 4 accomplishes.

Let’s take a look at the practices, broken down by domain.

 

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Level 4 Access Control Practices

There are 3 new AC controls introduced at Level 4:

 

Here are a few more articles to help you learn more about CMMC :

 

Level 4 Asset Management Practice

There is just 1 new AM control introduced at Level 4:

 

Level 4 Audit and Accountability Practices

There are 2 new AU controls introduced at Level 4:

 

Level 4 Awareness and Training Practices

There are 2 new AT controls introduced at Level 4:

 

Level 4 Configuration Management Practices

There is just 1 new CM control introduced at Level 4:

 

Level 4 Incident Response Practices

There are 2 new IR controls introduced at Level 4:

 

Level 4 Risk Management Practices

There are 4 new RM controls introduced at Level 4:

 

Level 4 Security Assessment Practices

There are 3 new CA controls introduced at Level 4:

 

Level 4 Situational Awareness Practices

There are 2 new SA controls introduced at Level 4:

Level 4 System and Communications Protection Practices

There are 5 new SC controls introduced at Level 4:

 

Level 4 System and Information Integrity Practice

There is just 1 new SI control introduced at Level 4:

 

How to Meet CMMC Level 4 Requirements

As we went over above, Level 4 adds relatively few new practices. However, the challenge of certification comes with the need to manage and review all 156 current practices, cumulatively.

Like all prior levels, the only way to achieve certification at Level 4 is through a Certified Third Party Assessment Organization (C3PAO). Assessors qualified by the CMMC Accreditation Body are your ticket to proving to the OUSD(S&A) and DoD that your organization is safe enough to work with. But that’s not all; a C3PAO can also help you build everything you need to pass.

For instance, RSI Security is a C3PAO. Our suite of CMMC services goes way beyond just certifying your company; we’re also fully equipped to build up your cyberdefenses from the ground up. We can help you perform, document, manage, and review all the practices listed above as well as all 130 from lower levels, assuring full process institutionalization for Level 4.

 

Protect CUI and Reduce APT Threats

Plus, RSI Security isn’t just happy to help you comply with everything CMMC requires, at Level 4 and beyond. We’re also happy to help with any and all elements of your infrastructure, from niche areas like cloud security to more holistic elements, like managed IT. Need a cybersecurity technical writer or even a virtual CISO? No matter what you need, we have you covered.

For CMMC Level 4 made simple and robust overall cyberdefense, contact RSI Security today!

 


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