- Why so few Defense contractors are compliant𝐇𝐨𝐰 𝐥𝐨𝐧𝐠 𝐝𝐨𝐞𝐬 𝐢𝐭 𝐭𝐚𝐤𝐞 𝐚 𝐜𝐨𝐦𝐩𝐚𝐧𝐲 𝐭𝐨 𝐠𝐨 𝐛𝐚𝐧𝐤𝐫𝐮𝐩𝐭 𝐢𝐭 𝐰𝐡𝐞𝐧 𝐜𝐚𝐧’𝐭 𝐰𝐢𝐧 𝐰𝐨𝐫𝐤? One year? Two? Three? Let me tell you a story about how a system of perverse incentives caused our current cybersecurity situation in the Defense Industrial Base. Back in 2017 (six years ago), new and renewing DoD contracts started including … Read more
- Podcast – increasing the likelihood of passing CMMC assessmentsThis podcast by Omnistruct features Amira Armond, John Riley, and George Usi. Recorded in May-June 2023. They discuss the basics of CMMC, the “hardest” requirement (FIPS of course), the aspects that contractors have the most difficulty with, and the status of the roll-out. Check it out! The link below has the full text transcript: Omnistruct: … Read more
- CMMC Breaking News – July 25, 2023Today we had two big events in #CMMC and US Federal Contractor Cybersecurity. The Rule for CMMC moved to the Office of Management and Budget. That means a timer has started, 90 days or less, for the review to complete. Expect the text to be published by mid-October. There is still a possibility that it will come … Read more
- 3.13.9 FIPS 140-2 Validated CryptographyIt is time, finally, to talk about the #1 “Other than Satisfied” requirement in 800-171, per historic DIBCAC assessments. 😱 💥 💥 𝐅𝐈𝐏𝐒 140-2 𝐕𝐚𝐥𝐢𝐝𝐚𝐭𝐞𝐝 𝐌𝐨𝐝𝐮𝐥𝐞𝐬 💥 💥 😱 Listen up – I’m going to tell you how to succeed at this requirement. It might take money, it might take time, but it CAN be … Read more
- 3.5.3 Multifactor AuthenticationMultifactor Authentication: #2 of the top 10 “Other than Satisfied Requirements” for 800-171 assessments by DIBCAC. 𝐔𝐬𝐞 𝐦𝐮𝐥𝐭𝐢𝐟𝐚𝐜𝐭𝐨𝐫 𝐚𝐮𝐭𝐡𝐞𝐧𝐭𝐢𝐜𝐚𝐭𝐢𝐨𝐧 𝐟𝐨𝐫 𝐥𝐨𝐜𝐚𝐥 𝐚𝐧𝐝 𝐧𝐞𝐭𝐰𝐨𝐫𝐤 𝐚𝐜𝐜𝐞𝐬𝐬 𝐭𝐨 𝐩𝐫𝐢𝐯𝐢𝐥𝐞𝐠𝐞𝐝 𝐚𝐜𝐜𝐨𝐮𝐧𝐭𝐬 𝐚𝐧𝐝 𝐟𝐨𝐫 𝐧𝐞𝐭𝐰𝐨𝐫𝐤 𝐚𝐜𝐜𝐞𝐬𝐬 𝐭𝐨 𝐧𝐨𝐧-𝐩𝐫𝐢𝐯𝐢𝐥𝐞𝐠𝐞𝐝 𝐚𝐜𝐜𝐨𝐮𝐧𝐭𝐬. My theory is that most of the time when this requirement is failed, it is because the IT department didn’t know … Read more
- What are Spot Checks for?𝐂𝐌𝐌𝐂 𝐀𝐬𝐬𝐞𝐬𝐬𝐦𝐞𝐧𝐭 𝐒𝐩𝐨𝐭 𝐂𝐡𝐞𝐜𝐤𝐬 “𝘐𝘧 𝘤𝘰𝘯𝘵𝘳𝘢𝘤𝘵𝘰𝘳’𝘴 𝘳𝘪𝘴𝘬-𝘣𝘢𝘴𝘦𝘥 𝘴𝘦𝘤𝘶𝘳𝘪𝘵𝘺 𝘱𝘰𝘭𝘪𝘤𝘪𝘦𝘴, 𝘱𝘳𝘰𝘤𝘦𝘥𝘶𝘳𝘦𝘴, 𝘢𝘯𝘥 𝘱𝘳𝘢𝘤𝘵𝘪𝘤𝘦𝘴 𝘥𝘰𝘤𝘶𝘮𝘦𝘯𝘵𝘢𝘵𝘪𝘰𝘯 𝘰𝘳 𝘰𝘵𝘩𝘦𝘳 𝘧𝘪𝘯𝘥𝘪𝘯𝘨𝘴 𝘳𝘢𝘪𝘴𝘦 𝘲𝘶𝘦𝘴𝘵𝘪𝘰𝘯𝘴 𝘢𝘣𝘰𝘶𝘵 𝘵𝘩𝘦𝘴𝘦 𝘢𝘴𝘴𝘦𝘵𝘴, 𝘵𝘩𝘦 𝘢𝘴𝘴𝘦𝘴𝘴𝘰𝘳 𝘤𝘢𝘯 𝘤𝘰𝘯𝘥𝘶𝘤𝘵 𝘢 𝘭𝘪𝘮𝘪𝘵𝘦𝘥 𝘴𝘱𝘰𝘵 𝘤𝘩𝘦𝘤𝘬 𝘵𝘰 𝘪𝘥𝘦𝘯𝘵𝘪𝘧𝘺 𝘳𝘪𝘴𝘬𝘴. 𝘛𝘩𝘦 𝘭𝘪𝘮𝘪𝘵𝘦𝘥 𝘴𝘱𝘰𝘵 𝘤𝘩𝘦𝘤𝘬(𝘴) 𝘴𝘩𝘢𝘭𝘭 𝘯𝘰𝘵 𝘮𝘢𝘵𝘦𝘳𝘪𝘢𝘭𝘭𝘺 𝘪𝘯𝘤𝘳𝘦𝘢𝘴𝘦 𝘵𝘩𝘦 𝘢𝘴𝘴𝘦𝘴𝘴𝘮𝘦𝘯𝘵 𝘥𝘶𝘳𝘢𝘵𝘪𝘰𝘯 𝘯𝘰𝘳 𝘵𝘩𝘦 𝘢𝘴𝘴𝘦𝘴𝘴𝘮𝘦𝘯𝘵 𝘤𝘰𝘴𝘵. 𝘛𝘩𝘦 𝘭𝘪𝘮𝘪𝘵𝘦𝘥 𝘴𝘱𝘰𝘵 𝘤𝘩𝘦𝘤𝘬(𝘴) 𝘸𝘪𝘭𝘭 𝘣𝘦 𝘸𝘪𝘵𝘩𝘪𝘯 𝘵𝘩𝘦 𝘥𝘦𝘧𝘪𝘯𝘦𝘥 … Read more
- 3.14.1 Identify, report, correct system flawsContinuing the Top 10 “Other than Satisfied Requirements” for 800-171 assessments by DIBCAC. “𝐈𝐝𝐞𝐧𝐭𝐢𝐟𝐲, 𝐫𝐞𝐩𝐨𝐫𝐭, 𝐚𝐧𝐝 𝐜𝐨𝐫𝐫𝐞𝐜𝐭 𝐢𝐧𝐟𝐨𝐫𝐦𝐚𝐭𝐢𝐨𝐧 𝐚𝐧𝐝 𝐢𝐧𝐟𝐨𝐫𝐦𝐚𝐭𝐢𝐨𝐧 𝐬𝐲𝐬𝐭𝐞𝐦 𝐟𝐥𝐚𝐰𝐬 𝐢𝐧 𝐚 𝐭𝐢𝐦𝐞𝐥𝐲 𝐦𝐚𝐧𝐧𝐞𝐫.” This is the third most “Other than Satisfied” requirement. 3.14.1 is both misunderstood and very hard to implement. Both problems cause failures. 𝐖𝐡𝐲 𝐢𝐬 3.14.1 𝐦𝐢𝐬𝐮𝐧𝐝𝐞𝐫𝐬𝐭𝐨𝐨𝐝? Most people read the … Read more
- 3.11.1 Periodically assess the risk to organizational operations3.11.1 𝐏𝐞𝐫𝐢𝐨𝐝𝐢𝐜𝐚𝐥𝐥𝐲 𝐚𝐬𝐬𝐞𝐬𝐬 𝐫𝐢𝐬𝐤…This is the fourth-most “Other than satisfied” #CMMC requirement. Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI. Not hard to do, but often misunderstood. Let’s break it down. 𝐏𝐞𝐫𝐢𝐨𝐝𝐢𝐜𝐚𝐥𝐥𝐲 … Read more
- 3.11.2 Scan for VulnerabilitiesScan for vulnerabilities….This the fifth-most “Other than satisfied” #CMMC requirement with an 18% fail rate. 3.11.2 𝐒𝐜𝐚𝐧 𝐟𝐨𝐫 𝐯𝐮𝐥𝐧𝐞𝐫𝐚𝐛𝐢𝐥𝐢𝐭𝐢𝐞𝐬 𝐢𝐧 𝐨𝐫𝐠𝐚𝐧𝐢𝐳𝐚𝐭𝐢𝐨𝐧𝐚𝐥 𝐬𝐲𝐬𝐭𝐞𝐦𝐬 𝐚𝐧𝐝 𝐚𝐩𝐩𝐥𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬 𝐩𝐞𝐫𝐢𝐨𝐝𝐢𝐜𝐚𝐥𝐥𝐲 𝐚𝐧𝐝 𝐰𝐡𝐞𝐧 𝐧𝐞𝐰 𝐯𝐮𝐥𝐧𝐞𝐫𝐚𝐛𝐢𝐥𝐢𝐭𝐢𝐞𝐬 𝐚𝐟𝐟𝐞𝐜𝐭𝐢𝐧𝐠 𝐭𝐡𝐨𝐬𝐞 𝐬𝐲𝐬𝐭𝐞𝐦𝐬 𝐚𝐧𝐝 𝐚𝐩𝐩𝐥𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬 𝐚𝐫𝐞 𝐢𝐝𝐞𝐧𝐭𝐢𝐟𝐢𝐞𝐝. “𝒐𝒓𝒈𝒂𝒏𝒊𝒛𝒂𝒕𝒊𝒐𝒏𝒂𝒍 𝒔𝒚𝒔𝒕𝒆𝒎𝒔”…This is an example of a broadly-applicable requirement – something that is expected to be applied 𝘩𝘰𝘭𝘪𝘴𝘵𝘪𝘤𝘢𝘭𝘭𝘺 from boundary to … Read more
Resources to get started with CMMC
Check the menu above for dozens of articles about CMMC, how to prepare your company, and how to become an assessor yourself.
Below are the top 10 links / resources for CMMC and 800-171, ranging from official to informal.
The Department of Defense owns the CMMC program. The Department of Defense is the organization that requires cybersecurity and (in the future) CMMC certification for their contractors. You can find an FAQ, and more importantly, the official documents published by the DoD which identify their expectations for cybersecurity.
The CMMC Accreditation Body, recently rebranded to “Cyber-AB”, is a private-sector organization which has the responsibility to manage and accredit CMMC assessment companies. The Cyber-AB is mandated to follow the ISO 17011 standard to be an accreditation body. If you want to be a CMMC professional, this organization offers certification and marketplace listings.
This page on the Defense Contract Management Agency’s (DCMA) website has several great resources for defense contractors in the final stages of preparation for 800-171 or CMMC assessment. In particular, the self-assessment database and pre-assessment packages provide insight into the assessment process.
This website is an official DoD website, even though it doesn’t look like it. The page has an FAQ document which has some of the best technical clarifications for what the DoD expects their contractors to do for cybersecurity. It is written for existing DFARS 252.204-7012 and NIST SP 800-171 compliance requirements, but these overlap CMMC requirements almost perfectly.
This document gives instructions for performing a NIST SP 800-171 self-assessment and scoring the self assessment so that the results can be entered into SPRS. CMMC uses this document to identify which practices cannot be failed in order to pass a CMMC assessment (the 5-point practices). The document also gives advice about Not Applicable practices.
This is a page on cmmcaudit.org (this website), with links to other good cybersecurity resources that will help you get ready.
This page gives simple descriptions of many terms and resources related to CMMC. Very helpful to read through when you are starting out.
This is a Discord server which focuses on CMMC, CUI, 800-171 compliance, and other topics of interest to defense contracting cybersecurity. Most of the top level people in CMMC contribute in this forum. Best source of peer-to-peer information available.
This is the website of the C3PAO Stakeholder Forum, an industry group of CMMC assessment companies. The Positions page has articles with recommendations for how to assess CMMC, as well as high-level recommendations for the program as a whole.
This page is relevant for all companies who are currently contractors for the DoD. It explains existing requirements for cybersecurity, which happen to look a lot like the new requirements for CMMC.
This page has all articles on the site. Remember that CMMC has changed over time, and articles written before 2022 may be outdated.
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. Katie Arrington during the CMMC Listening Tour in 2019, 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 many DoD contractors to get an audit and certification from a third party auditor if they have CUI on their information systems.
We talk about 800-171 too!
Although this website is named “CMMC Audit”, almost all our articles are also relevant to NIST SP 800-171 and DFARS 252.204-7012 compliance. Check our NIST 800-171 menu above for specific information about these current requirements. Articles that discuss CMMC Level 2 or Controlled Unclassified Information will be helpful for your 800-171 journey today.
What you need to know about CMMC
CMMC enforcement timelines
The current timelines have shifted right significantly since 2020. As of November 2022, we still have not had any real CMMC assessments of defense contractors. Here is the current timeline (guesstimate)
- Mid 2022 – 20 C3PAOs have been “Authorized”, but cannot yet perform CMMC assessments.
- Mid 2022 – Mid 2023: A few C3PAOs are allowed to do “joint” assessments of 800-171 alongside the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). So far the rate has been 1 completed per month. These are not CMMC assessments.
- Mid 2023 or Mid 2024 – New DFARS rule introducing CMMC is published.
- After the rule: Authorized C3PAOs are able to perform CMMC assessments on their own schedule. Possibly up to 100 assessments per month will occur, with perhaps 600 performed in the first year after the DFAR rule is released ( <1% of total )
- Mid 2024? The Cyber-AB is accredited as an ISO 17011 Accreditation Body, and begins accrediting C3PAOs as inspection bodies.
- Gradual and accelerating expansion over time.
CMMC levels and requirements
The DoD recognizes that their contracts have different risk profiles, so each RFP will list a CMMC level requirement from 1-3. Having proof of compliance at that level would be a requirement to even submit a bid.
The lower level (1) applies 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 the middle level (2), 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 level, (3), 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 3 is likely to be very expensive.
For more details about the CMMC as an overall program, see CMMC Basics – the Full Details
Does CMMC apply to your business?
This infographic describes different types of sensitive but unclassified Federal data and their related cybersecurity requirements.
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Are you just looking for help preparing for the CMMC?
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CMMCaudit.org is not a representative of the Department of Defense, the CMMC Accreditation Body, or the CMMC Assessors and Instructors Certification Organization. This website is meant to be community resource for CMMC audit (or assessment!) preparation.