What is the Cybersecurity Maturity Model Certification (CMMC)?
The Cybersecurity Maturity Model Certification (CMMC) is the Department of Defense’s (DoD) newest verification mechanism designed to ensure that cybersecurity controls and processes adequately protect Controlled Unclassified Information (CUI) that resides on Defense Industrial Base (DIB) systems and networks.
The DoD implemented requirements for safeguarding Covered Defense Information (CDI) and cyber incident reporting through the release of Defense Federal Acquisition Regulation Supplement (DFARS) 252.204–7012 in October 2016. The DFARS directed DoD Contractors to self-attest that adequate security controls were implemented within contractor systems to ensure that CDI confidentiality was maintained. The security controls required to be implemented by the DFARS are defined within National Institute of Standards and Technology (NIST) Special Publication (SP) 800–171, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations. The Office of the Undersecretary of Defense for Acquisition and Sustainment (OUSD (A&S)) started the process of creating the CMMC in March 2019, with the finalization of the CMMC v1.0 expected in January 2020.
CMMC in the Near-Term
CMMC will not be required for all contractors immediately and will be phased in for certain DoD-identified contractors beginning in September 2020. When fully operational, the CMMC will be mandatory for all entities doing business with the DoD at any level. Prime contractors, and their subcontractors, will be required to meet one of the five CMMC trust levels, and demonstrate that cybersecurity has been sufficiently implemented through the completion of independent validation activities. Initial Award, or continuance, of a DoD contract will be dependent upon CMMC compliance. No contractor organizations will be permitted to receive or share DoD information related to programs and projects without having completed the CMMC process. At the time that a contractor’s contract is up for renewal they must be CMMC compliant.
In January 2020 the CMMC will release a checklist for contractors which will allow them to identify how well they currently comply with the framework, and to assist with planning and implementing security maturity tasks. The CMMC will be included as a component of Requests for Information (RFIs) in mid-2020 and is expected to be included in Requests for Proposal (RFPs) by late 2020. The required CMMC compliance level will be contained in sections L & M of RFPs, making cybersecurity an “allowable cost” in DoD contracts.
CMMC will combine elements of various cybersecurity control standards such as NIST SP 800–171, NIST SP 800–53, ISO 27001, ISO 27032, AIA NAS9933, and others, into one unified standard for CUI cybersecurity.
CMMC Timeline
May 2019: Version 0.1
July 2019: Version 0.2 identified and reviewed
September 2019: Version 0.4 released
October 2019: CMMC implemented requirements released
November 2019: Version 0.6 to be released for public review
January 2020: Version 1.0 finalization expected; compliance checklist released
June 2020: CMMC will begin appearing in RFIs
September 2020: CMMC Will Begin Appearing in RFPs
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