DoD to contractors: Your cybersecurity is not good enough
The Cybersecurity Maturity Model Certification (CMMC) is an initiative lead by the Office of the Assistant Secretary of Defense for Acquisition. This is an office in the Department of Defense (DoD) which helps set policy for DoD contract requirements.
DoD contractors who handle Controlled Unclassified Information (CUI) are already required to self-certify compliance with the NIST SP 800-171 set of cybersecurity best practices. However, as pointed out by Ms. Kate Arrington during the CMMC Listening Tour this year, self-certification is not working. DoD contractors have been successfully targeted by cyber adversaries because they haven’t fully secured their networks.
To force DoD contractors to implement cybersecurity, the CMMC will require every DoD contractor to get an audit and certification from a third party auditor. It doesn’t matter whether the contractor manages CUI or not. They still need to get audited.
CMMC enforcement timelines
The current timelines (as of May 2020) are:
- Mid 2020: 3rd party auditors begin applying for accreditation
- Late 2020: Several (less than 20) DoD contracts are chosen to be the first ones that will require CMMC certification
- Late 2020: Bidders to the specified DoD contracts start getting audited
- Early 2021??: DFARS 7012 rule is modified to replace NIST 800-171 with CMMC requirement
- Between 2021 and 2024: New Requests for Proposals (RFPs) gradually begin requiring CMMC certification. This means that most DoD contractors won’t be directly affected by CMMC for several years.
CMMC levels and requirements
The DoD recognizes that their contracts have different risk profiles, so each RFP will list a CMMC level requirement from 1-5. Having proof of certification at that level would be a requirement to even submit a bid.
The lower levels (1-2) apply to DoD contractors who don’t deal with Controlled Unclassified Information (CUI). I expect most resellers will fit into this category. Other than purchase orders and possibly human resources information, they don’t hold government information on their corporate networks. The security requirements for these levels are much less stringent.
In middle levels (3-4), DoD contractors handle CUI. This is information like schematics for DoD equipment. Data which lets adversaries reverse-engineer or learn about military capabilities. For example, a shipyard might have maintenance plans for submarine equipment on a CUI network. This requires a level of protection very similar to the current NIST SP 800-171 recommendations.
At the highest levels, (4-5), the CUI being protected is high stakes. These networks will be targeted by cyber adversaries. Examples of this information would be weapon test results or detailed manufacturing schematics. Securing your network up to level 4 or 5 is likely to be very expensive.
Resources to get started with CMMC
Official DoD homepage for CMMC: https://www.acq.osd.mil/cmmc/index.html
Want to contribute to the discussion?
CMMCaudit.org is looking for contributions. We need cybersecurity professionals to write articles about specific practices and topics in the CMMC. Send us an email if you have a thoughtful (non-sales) article you would like to share, we will be glad to credit you and your company!
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