It would appear that more often than not, hackers choose to go after the manufacturing industry, considering that in 2023 it had the highest share of cyberattacks among the leading industries around the world. In fact, there were reportedly 260 data violation incidents that year, where in some cases the cybercriminals would demand money or sell the data on the dark web.
Fortunately, a way for those in the manufacturing sector to ensure that their data is protected is to be CMMC compliant. For those unfamiliar with CMMC, it stands for Cybersecurity Maturity Model Certification, which is a framework developed by the U.S. Department of Defense (DoD) for contractors within the Defense Industrial Base (DIB) sector to adequately protect sensitive information.
CMMC is crucial for manufacturers who work with the DoD because they must achieve the required level in order to bid on or continue existing contracts. It’s also important in that it strengthens a manufacturers cybersecurity posture and allows them to better manage and mitigate cybersecurity risks. It additionally ensures that all tiers of the supply chain uphold strong cybersecurity practices, and in turn gives them a competitive advantage since it displays their commitment to protecting data.
In this blog, we’ll cover a basic understanding of CMMC, as well as the key features of its 2.0 and 2.1 versions, and how manufacturers can implement a roadmap to achieve compliance.
Understanding CMMC
The Cybersecurity Maturity Model Certification (CMMC) standardizes cybersecurity practices across the Defense Industrial Base (DIB) sector. It is designed to ensure that contractors and subcontractors protect sensitive information, including Controlled Unclassified Information (CUI) and Federal Contract Information (FCI), from cyber threats. The CMMC framework consists of three maturity levels, each with specific cybersecurity practices that range from basic to advanced security measures. The purpose of CMMC is to enhance the overall cybersecurity of the DIB by requiring third-party assessments and certifications, which ensures a reliable defense supply chain.
Initially, defense contractors were required to self-assess their compliance with the NIST 800-171 standard. However, due to the limitations of that model, the DoD announced the development of CMMC in 2019, which introduced a third-party certification to ensure a more reliable assessment process. The first version, CMMC 1.0, was implemented in November 2020, requiring contractors to upload a Supplier Performance Risk System score in compliance with NIST 800-171 and various DFARS requirements.
CMMC 2.0 was then announced in November 2021, to streamline the certification process by reducing the number of maturity levels from five to three. Most recently, on June 27, 2024, the DoD completed its review of the CMMC "proposed rule" and submitted it to the Office of Information and Regulatory Affairs (OIRA) as a "final rule." OIRA has 90 days to review this final rule, with the expectation that CMMC 2.1 will be published in the federal register by October 2024.
Why is all this important? Well, in an industry where sensitive data and intellectual property are frequently targeted by cybercriminals, a strong cybersecurity posture is essential. Non-compliance with CMMC standards can also lead to severe consequences, including data breaches that can result in significant financial losses, legal liabilities, and damage to a company’s reputation. Moreover, non-compliance can lead to the loss of valuable contracts, as adherence to CMMC standards is a prerequisite for doing business with the Department of Defense.
What Are the Key Features of CMMC 2.0?
The Cybersecurity Maturity Model Certification (CMMC) 2.0 introduced key features designed to make it more accessible for defense contractors. One of the most significant changes was the reduction of compliance levels from five to three, streamlining the model to focus on the most critical requirements.
The streamlined assessment process allows all companies at Level 1 and a subset of companies at Level 2 to demonstrate compliance through self-assessments, significantly reducing assessment costs. Furthermore, CMMC 2.0 enhances the reliability of assessments by increasing oversight of third-party assessors.
The flexible implementation of the program encourages collaboration, allowing companies to develop Plans of Action & Milestones (POA&Ms) to achieve certification. This feature aim to make the compliance process more manageable for contractors and subcontractors.
CMMC 2.0 also places a strong emphasis on the National Institute of Standards and Technology (NIST) standards, specifically NIST SP 800-171 and NIST SP 800-172. For Level 2 (Advanced), the 110 security controls from NIST SP 800-171 are incorporated, covering 14 domains that include access control, incident response, and system and communications protection. At Level 3 (Expert), in addition to NIST SP 800-171 controls, companies must also implement a subset of controls from NIST SP 800-172, to reduce vulnerabilities to advanced persistent threats (APTs).
In terms of the CMMC 2.0 framework specifically, it mandates self-assessments for companies at Level 1. For Level 2, while self-assessments are allowed for some companies, many will require third-party assessments to validate compliance. At Level 3, third-party assessments are mandatory, reflecting the critical nature of protecting controlled unclassified information (CUI) in high-priority DoD programs. Combining NIST's detailed implementation guidance with CMMC's tiered certification helps organizations safeguard their systems and meet cybersecurity requirements.
Introduction to CMMC 2.1
The introduction of Cybersecurity Maturity Model Certification (CMMC) version 2.1 brings several new additions and changes that will impact defense contractors, including those in the manufacturing sector. On December 26, 2023, the Department of Defense released a proposed rule that, if adopted, will incorporate CMMC 2.1 into defense contracts. This new version maintains the tiered structure with three levels but introduces a phased implementation plan. Starting from the effective date of the final rule, expected in late 2024 or early 2025, all applicable DoD solicitations and contracts will require CMMC Level 1 and Level 2 self-assessments as a condition. Another important new requirement is the annual affirmation, where organizations must name an affirming official and submit an affirmation statement attesting that they have implemented and will maintain the required CMMC security measures.
These changes significantly impact manufacturing companies, especially those working with sensitive unclassified information. The allowance of Plans of Action and Milestones (PoA&Ms) allows companies to address gaps in compliance within 180 days though. This is particularly relevant for CMMC Level 2 and Level 3 requirements.
Manufacturing companies that utilize external service providers for IT services must also ensure these providers obtain a CMMC certification at least equal to the level the company is seeking. Additionally, if cloud service providers are used for controlled unclassified information (CUI), they must meet additional security standards. These requirements ensure that all aspects of the supply chain adhere to strict cybersecurity standards.
Compliance Roadmap for Manufacturers in Connecticut
Achieving compliance with CMMC 2.1 requires a strategic approach. Manufacturers should begin with a Gap Assessment to identify weaknesses in their business's security posture. This assessment will pinpoint areas where their cybersecurity measures fall short of CMMC requirements and recommend improvements.
Once gaps are identified, manufacturers should implement the necessary controls to address them. Key areas to focus on include Backup and Disaster Recovery, which ensures their document management and storage processes are robust, with reliable backup solutions in place. Dark Web Monitoring is also important in that it uses monitoring tools to receive notifications if their credentials are compromised. Manufacturers should also implement endpoint encryption to prevent classified information from being stolen or decrypted. They should regularly scan for external vulnerabilities to identify and mitigate potential threats to their network as well. Lastly, it’s key to conduct regular training sessions to educate employees on best practices for safeguarding classified information too.
Managed Service Providers (MSPs), like Charles IT, can be invaluable partners in achieving CMMC compliance. We offer expert guidance, manage complex IT environments, and provide critical services like those mentioned above.
Conclusion
All in all, it’s evident that manufacturers can effectively achieve the latest version of CMMC compliance by enhancing their cybersecurity measures. For more detailed information on navigating the CMMC requirements and how Charles IT can support you through the process, visit Charles IT where we have tons of information on CMMC including blogs and an e-book.
To discuss your specific needs and how we can assist in securing your compliance requirements, schedule a call with one of our experts today!
