Cloud and IT services in federal and defense markets are a booming business. The national infrastructure is turning to stable and flexible IT infrastructure to help mobilize the supply chain in a way that can meet modern security and domestic challenges. Accordingly, many businesses are turning to new certification frameworks like CMMC to support contracting in these areas. 

Here we’re talking about what it means to prepare for CMMC certification. Contrary to popular belief, there are steps you can take to prepare before you even meet with a professional auditor to help that partner better serve you and streamline your compliance process. 

What is the Cybersecurity Maturity Model Certification (CMMC)?

CMMC is a relatively new (as of 2021) certification process targeting vendors, contractors and subcontractors serving agencies in the Defense Industrial Base (DIB). These Department of Defense (DoD) and associated organizations typically handle what’s known as Controlled Unclassified Information CUI, which is information that, while not a matter of national security per se, is important for the operation of the DoD. That being said, CUI requires special cybersecurity controls and safeguards to guarantee its safety. 

CMMC is broken into categories of processes and practices. Processes are the capabilities of your organization in terms of what, operationally, you can regularly accomplish as part of your compliance strategy. Practices are the controls and safeguards in place (whether technical, administrative or physical) that meet specific requirements in CMMC, also known as cyber hygiene.

The five levels break down as follows:

1. Level 1 calls for an organization to maintain “Basic” cyber hygiene and demonstrate the ability to perform those practices. This is a minimum level for handling Federal Contract Information (FCI) or controlled information generated as part of an agency-contractor relationship.  
2. Level 2 expects “Intermediate” cyber hygiene and the ability to document your security practices.
3. Level 3 calls for “Good” cyber hygiene and the ability to manage and maintain complex security plans across your organization. This is the minimum level for the handling of CUI. 
4. Level 4 expects “Proactive” cyber hygiene for prevention and response along with the ability to review and remediate security issues across a compliance and security system. 
5. Level 5 focuses on “Advanced” cyber hygiene for the protection of CUI against Advanced Persistent Threats (APTs) as well as the ability to review and optimize your security and compliance system. 

At each level, there are a select series of security controls that cover practices like data security and privacy, physical control of access to data systems, training and continuing education, risk assessment and management, identity access and authorization and other practices. 

The Role of the C3PAO in Certification

To add a bit of support to the process (and to help standardize certification) CMMC also requires you to work with a Certified Third-Party Assessment Organization (C3PAO). Anyone familiar with frameworks like FedRAMP knows that a C3PAO is both a necessity and a huge boon for companies small and large. 

Enterprise clients can benefit from C3PAOs that have the cybersecurity chops to manage parts of the security or the entirety of their compliance auditing. As managed services, including managed security services, are becoming the norm, having a third-party assessor that can also provide expert-level support and audits for their infrastructure is invaluable. 

Likewise, SMBs or non-IT-related businesses entering into the DIB Network (DIBNet) can gain insight and expediency from a seasoned C3PAO who already has a background in audits, security and government compliance frameworks. 

While we won’t get into the details of what a C3PAO does here, we have discussed it in other contexts and how they relate to other frameworks, particularly how to look for the right C3PAO for your organization. 

 How to Prepare for Your First Audit

Considering all these aspects of CMMC, there are a few simple ways to prepare for your auditing process:

• Work with an experienced C3PAO: As articulated above, an experienced organization can streamline your auditing process by educating you on what needs to be done. Likewise, these organizations can also bring several tools to bear, like automation, to take a process that can go for weeks or months and reduce the timeline to days. 
• Clearly understand your needs and the associated CMMC level: It doesn’t help you to stumble into certification. When responding to an RFP that includes CMMC requirements, that document will spell out where they want you to be in terms of certification levels. Get ahead of the game and understand exactly what that means for your organization in terms of preparation and planning before you even talk to a C3PAO. 
• Clarify business goals and how they align with compliance: The best C3PAO in the world cannot tell you what your business wants, or should, do to maximize compliance standards. Have a clear sense of what you want to accomplish from a business standpoint and then bring that to your assessments and audits. 
• Identify and assign key technical and compliance roles: There should always be a point person for compliance, certification, technology adoption and risk management. And, that person should not be a junior IT employee or technical manager. Have a compliance officer, ideally with a dedicated IT and compliance strategist (if they aren’t the same person) that can translate evolving CMMC requirements and C3PAO reports into actionable items for your business. 
• Be prepared to be flexible: Even with all your preparation, you cannot determine what complies with CMMC and what does not. The CMMC Accreditation board and C3PAOs do. If you complete some internal readiness program or assessment and, later, a C3PAO determines different changes and implementations, you need to be able to roll with those punches. 

In general, give yourself 6-8 months to prepare for your first time, unless you already have some background with federal and defense compliance. 

CMMC Certification Automation with Continuum GRC

Are you preparing for your CMMC certification? Do you have the right tools in place to make it happen? Stone-age tools like spreadsheets and email can hinder your process and slowdown certification. 

 Call Continuum GRC at 1-888-896-6207 or through the form below to learn how our automated ITAMS platform can support rapid, effective and accurate CMMC audits for enterprise businesses and SMBs.