In today’s evolving cybersecurity landscape, the Department of Defense (DoD) created the Cybersecurity Maturity Model Certification (CMMC) to safeguard sensitive data within the Defense Industrial Base (DIB). This includes both Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
With the rollout of CMMC 2.0, many contractors must now determine whether they need a Level 2 CMMC Assessment. Understanding the requirements for Level 2 is critical for maintaining compliance, protecting sensitive information, and securing eligibility for future DoD contracts.
Understanding CMMC 2.0 and Level 2 Requirements
CMMC 2.0, which was finalized in October of 2024, streamlines the certification process into three levels, each reflecting a higher degree of cybersecurity maturity:
- Level 1 (Foundational): Basic cybersecurity practices to protect FCI.
- Level 2 (Advanced): Advanced cybersecurity practices to protect CUI, aligned with NIST SP 800-171.
- Level 3 (Expert): Expert-level cybersecurity practices to safeguard CUI and counter advanced persistent threats (APTs).
Level 2, the focus of this discussion, encompasses advanced practices derived from the 110 security requirements specified in NIST SP 800-171 Revision 2. This level is designed to ensure that contractors have robust measures in place to protect CUI from sophisticated cyber threats.
Who Needs a Level 2 CMMC Assessment?
Contractors Handling CUI
Any organization within the DIB that handles Controlled Unclassified Information (CUI) is required to achieve at least Level 2 CMMC certification. CUI includes sensitive information that, while not classified, still requires safeguarding due to its potential impact on national security if disclosed. Examples of CUI can include technical drawings, blueprints, specifications, and other data critical to defense operations.
Subcontractors Working with Prime Contractors
Prime contractors on DoD contracts frequently extend CMMC requirements to their subcontractors, ensuring the entire supply chain meets cybersecurity standards. If a subcontractor handles CUI as part of their contractual obligations, they must also achieve Level 2 certification.
This ensures that all entities within the supply chain adhere to the same rigorous cybersecurity standards, maintaining the integrity and security of the information throughout its lifecycle. Third-party risks are a significant consideration; subcontractors must implement secure practices to protect shared CUI, reducing the overall risk to the supply chain.
Organizations Seeking a Competitive Advantage
Even if not explicitly required by contract, achieving Level 2 CMMC certification can be a significant competitive advantage. Demonstrating compliance with advanced cybersecurity standards can differentiate your organization in the defense market, showcasing your commitment to safeguarding sensitive information and bolstering your reputation as a trusted partner.
Companies Transitioning from CMMC 1.0
Organizations that were previously preparing for CMMC Level 3 under the original model will need to transition to the new Level 2 requirements. The updated CMMC 2.0 framework has streamlined the levels, making it essential for these companies to understand the new criteria to ensure compliance.
Steps to Prepare for a Level 2 CMMC Assessment
1. Conduct a Self-Assessment
Begin by conducting a thorough self-assessment to identify gaps in your current cybersecurity practices compared to the Level 2 requirements. This assessment will help you understand the scope of work needed to achieve compliance.
2. Develop a System Security Plan (SSP)
First and foremost, a System Security Plan (SSP) is a comprehensive document outlining how your organization implements the required security controls.
Specifically, it should detail the system boundary, operational environment, and how each security requirement is met. To stay compliant, ensure your SSP is up-to-date and accurately reflects your current security posture.
3. Implement Necessary Controls
Based on the self-assessment, implement the required controls to meet Level 2 standards. This may include:
- Enhancing access controls and user authentication
- Implementing multifactor authentication (MFA)
- Encrypting data both at rest and in transit
- Conducting regular security awareness training for employees
- Establishing incident response procedures
4. Conduct Internal Audits
To maintain compliance, regular internal audits ensure that implemented controls are effective and consistently applied. Additionally, use these audits to verify compliance with your SSP and identify new risks or vulnerabilities. Afterward, document findings and take corrective actions as needed.
5. Engage a Consultant
Consider engaging a CMMC consultant or advisory service for expert guidance. At RSI Security, we offer comprehensive CMMC consulting services to help organizations navigate the complexities of compliance, from gap analysis to control implementation and pre-assessment readiness.
6. Train Your Team
Ensure your team is well-prepared for the assessment. Provide training on CMMC requirements, specific controls, incident response procedures, and handling CUI. Well-trained personnel are crucial for maintaining compliance and demonstrating your security posture during the assessment.
7. Prepare Documentation
To ensure success, maintain comprehensive and accurate documentation, including an updated SSP, POA&M, security policies and procedures, evidence of implemented controls, and records of security training. As a result, well-organized documentation greatly facilitates a smooth assessment process.
8. Conduct a Pre-Assessment
A pre-assessment simulates the actual C3PAO assessment and helps identify any remaining gaps or issues. Leverage pre-assessment findings to address deficiencies, ensure documentation completeness, and conduct mock interviews with your team to simulate real assessment scenarios. Once you’ve addressed all identified gaps and are confident in your preparedness, schedule your official C3PAO assessment to achieve your desired CMMC certification level.
9. CMMC Post-Assessment Remediation: Plans of Actions and Milestones
The plan of actions and milestones (POA&M) closeout assessment identifies and resolves unmet requirements from the initial evaluation, ensuring compliance gaps are addressed within the 180-day remediation period. Organizations must complete this follow-up assessment within 180 days of receiving Conditional CMMC Status.
If they fail to close the POA&M successfully within this period, the Conditional CMMC Status for the information system will expire. To review specific requirements and critical elements excluded from a POA&M, refer to §170.21 of the 32 CFR CMMC Program final rule.
Prepare Your Organization for CMMC 2.0
Achieving Level 2 CMMC certification is essential for organizations handling CUI within the Defense Industrial Base. To begin with, conducting thorough self-assessments, implementing necessary controls, maintaining detailed documentation, and engaging with expert consultants like RSI Security will help you enhance your cybersecurity posture and ensure a successful assessment.
Furthermore, not only does this prepare you for compliance, but it also strengthens your overall security practices, ultimately positioning your organization as a trusted partner in the defense supply chain.
For expert guidance and support in achieving CMMC Level 2 certification, contact RSI Security today. Let our experienced team help you navigate the complexities of CMMC compliance and ensure your organization’s readiness for a successful assessment.
Get a clear roadmap to CMMC compliance, download our checklist and prepare for certification with confidence.