Are You Ready for CMMC Compliance Requirements?
The Cybersecurity Maturity Model Certification (“CMMC”) is a unified cybersecurity standard for Department of Defense (“DoD”) acquisitions, aimed at securing the Defense Industrial Base (“DIB”) supply chain. This standard was updated in November of 2021 and is now considered “CMMC 2.0”.
The CMMC Program proposed final rule was published in the Federal Register on December 26, 2023. Comments to the proposed rule must be received by February 26, 2024.
How many CMMC levels are there?
The CMMC framework consists of three levels and can require an independent third-party certification by an accredited organization:
- CMMC Level 1 – Basic safeguarding of Federal Contract Information (FCI)
- CMMC Level 2 – (previous CMMC 1.0 Level 3) Protecting CUI
- CMMC Level 3 – (previous CMMC 1.0 Level 4 and 5) Protecting CUI and reducing risk of advanced Persistent Threats (APT)
CMMC 2.0 encompasses the following:
When will CMMC 2.0 compliance be required for DoD contracts?
The below table outlines DoD’s four implementation phases.
Phase |
Summary |
Timeline |
Phase 1 |
|
Begins on the effective date of the CMMC revision to DFARS 7021. |
Phase 2 |
|
Begins six months following the start date of Phase 1. |
Phase 3 |
|
Beings one calendar year following the start of Phase 2. |
Phase 4 |
|
Begins one calendar year following the start date of Phase 3. |
Cherry Bekaert CMMC Third-Party Assessment Organization Authorization
Cherry Bekaert is an authorized CMMC Third-Party Assessment Organization (C3PAO) by the Cybersecurity Maturity Model Certification (CMMC) Accreditation Body, Inc. (The Cyber AB). We assist Organization’s Seeking Certification (OSCs) with CMMC readiness assessments for Levels 1, 2 and 3. Additionally, as an authorized C3PAO, Cherry Bekaert partners with the Defense Contractor Management Agency (DCMA) Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) under their Joint Surveillance audit program to perform DIBCAC High (NIST 800-171) Assessments which are convertible to CMMC Level 2 Certification if a perfect score is obtained.
Having undergone Level 2 assessment as a Firm, Cherry Bekaert has a deep understanding of the assessment process to guide DoD contractors seeking a CMMC assessment.
Our services include:
- Certification Level Identification & Consultation
- System Boundary Determination
- Assessment Approach Considerations (Entity-Level vs Enclave vs Hybrid)
- Control Definition & Design
- Documentation Development & Review
- Mapping to Existing Frameworks such as NIST 800-53/171 (FedRAMP, FISMA, DFARS 7012), ISO 27001/2, SOC 2, PCI, HITRUST and Others
- Gap Analysis
- Remediation Design & Verification
- DIBCAC Joint Surveillance Audit Program DIBCAC High (NIST 800-171) Assessments in Partnership with DCMA DIBCAC
- Assistance with Level 1 and Level 2 Self-Assessment Scoring and Submission to SPRS
Readiness
Our CMMC Readiness Assessments are designed to assist management with implementing a CMMC Program tailored to the appropriate level. Cherry Bekaert follows a proven readiness process that includes the following phases:
- Scope and Boundary Identification
- Asset Identification and Categorization
- System Security Plan Development
- Shared Responsibility Matrix Development
- Policy and Procedure Development
- Evidence Collection
- Gap Assessment
- Recommendations to address identified gaps
Certifications & Attestations
Our CMMC assessments are streamlined from Planning & Testing though Reporting & Submission to ensure an efficient assessment from beginning to end.
In addition, Cherry Bekaert offers organizations the ability to undergo an attestation to the CMMC Level 1 and Level 2 Standard, NIST 800-171, for those looking for further assurance beyond just a self-assessment. These engagements can be performed individually or in conjunction with an existing SOC 2 audit, e.g., SOC 2+ NIST 800-171.