It may be tempting to put off your journey towards CMMC compliance, given that the regulation is not due to be fully implemented until October 1, 2025, but this would be a mistake. Earning a CMMC certification is no trivial task, especially if you are aiming for higher compliance levels. Starting now will give you plenty of time to get your information security strategy and systems up to scratch.
Before you engage a CMMC auditor in the hope of receiving your maturity level certification, you should first do everything you can to make sure you will be ready to pass the audit. One of the most important first steps is evaluating your existing systems and processes by way of a security gap assessment. This will determine where your vulnerabilities lie and explain what you need to do to patch those gaps.
Evaluating your current conformity with NIST 800-171
You can think of a gap assessment as a mock audit. A CMMC gap assessment will take much the same approach as a formal CMMC auditor. At the end of the assessment, you will have a list of potential weaknesses in your information architecture, and this will become the basis of your remediation strategy. Your auditor will also likely be able to give you an informed estimate of which CMMC level you could expect to achieve in a formal audit.
A gap assessment that aligns with the demands of CMMC will evaluate your conformity with the NIST 800-171 framework. This framework is the basis of CMMC compliance, and it covers all of the same controls. Moreover, if you currently have contracts or subcontracts with the US Department of Defense, then you already need to adhere to this framework. This is mandated by the DFARS 252.204-7012 clause, which is written into all defense contracts involving the handling of controlled unclassified information (CUI).
Assessing the effectiveness of your existing controls
Even if you have the controls in place mandated by the CMMC level you are targeting, this will not necessarily mean they are effective. Precisely how you implement the controls set out in the NIST 800-171 framework is up to you. After all, there are thousands of different security tools out there, and a practically limitless number of ways to document your security policies and apply the rules.
A gap assessment goes beyond just collecting an exhaustive list of your existing controls. It will also evaluate those controls for potential vulnerabilities. For example, you might be using multifactor authentication across all your systems, but they may be compromised by weaker password policies or unencrypted biometric data. If there are any such vulnerabilities in your security systems and protocols, they will need to be remediated before having a formal audit.
Prioritizing remediation to achieve full CMMC compliance
Most organizations have already achieved the equivalent to the first CMMC level, which only includes 17 controls. However, the number of controls that need to be implemented increases significantly with each level, with the highest level (level 5) having a total of 171 controls. This includes the controls from all the previous levels too. Most organizations will want to aim for CMMC Level 3, which is the minimum requirement for those handling CUI. Level 3 consists of 130 controls, which includes those implemented in the previous two levels.
This naturally translates into a rather extensive to-do list. As such, if your existing security only aligns with level one or two, you cannot expect to achieve level three or higher in only a few days. However, a gap assessment does not just pinpoint areas not fully compliant with CMMC, but also evaluates the risk level of each potential vulnerability. This helps you prioritize your remediation plans and patch the most serious vulnerabilities first.
It is important to view CMMC compliance as a journey rather than a destination. Conducting a gap analysis is merely the first step in that journey, and it will serve as the foundation of your long-term compliance roadmap and remediation plan.
Charles IT will help you prepare for CMMC compliance starting with a thorough assessment of your current technology and operational infrastructure. Contact us today to learn where your vulnerabilities lie!
