
Recent studies have shown that organizations are not ready for CMMC. The Aware but not Prepared report from Redspin states that only half of the Defense Industrial Base (DIB) are even moderately prepared for a Level 2 certification. Despite a five year roll out for the final rule from the Department of Defense (DoD) DIB members, both large and small, site costs, a lack of technical expertise, and confusing information from the DoD as challenges for Cybersecurity Maturity Model Certification (CMMC) compliance.
Management Commitment
A recurring theme in studies and guidelines in cybersecurity of management commitment and organizational support were echoed in the report. Unfortunately, in many organizations, the proception that cybersecurity is an IT function remains in place. A functional information security system involves participation in all levels of the business. This especially true for management, where risk assessments and continual improvement must be driven through communication of commitment and provision of adequate resources.
Getting Started
The first step in achieving compliance is to ascertain the organization’s cybersecurity status. This can be accomplished by performing a Gap Assessment. Finding for each control should be broken down into the following categories: Fully Compliant, Partially Compliant, and Non-Existent Controls. Then an effort should be made to target the low hanging fruits to demonstrate progress and enhance the organization’s cybersecurity effectiveness.
Implementing External Service Providers (ESPs)
The report recommends that organizations utilize External Service Providers to mitigate risks and maintain the information security system. A cybersecurity external service provider is a third-party organization that offers cybersecurity services to other companies, helping them protect their information systems from threats. These services can include monitoring, threat detection, incident response, and vulnerability management.
System Security Plans (SSP)
A majority of participants in the study reported having a System Security Plan in place though less than half have finalized this document. A System Security Plan (SSP) is a formal document that outlines the security requirements for an information system and describes the security controls in place or planned to meet those requirements. It serves as a comprehensive overview of how an organization protects its systems and data from unauthorized access and threats.
The Redspin report found that organizations that use the SSP to address each objective and then actively work through those objectives had a higher rate of success in achieving and maintaining compliance.
CMMC in the Trump Administration
CMMC 2.0 is not expected to be eliminated as a result of Trump administration deregulatory efforts. CMMC requirements are seen as a necessary measure for cybersecurity in the defense sector. While there may be discussions about regulatory burdens to smaller organizations, the program is likely to continue due to its importance in protecting Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
Issues Beyond the DIBs
Beyond the fact that organizations are not ready for CMMC, there may not be enough accredited Third Party Assessment Organization C3PAO auditors to meet the growing demand for CMMC certification. The process for granting C3PAO status is stringent and has resulted in a limited number of organizations being approved. This could lead to logistical challenges for defense contractors seeking certification in the near future.
The Bottom Line
Organizations are not ready for CMMC. CMMC compliance presents several challenges, particularly for small and medium businesses, including high costs for achieving and maintaining certification, complex requirements, and the need for significant investments in technology and processes. Additionally, the evolving nature of cybersecurity threats makes it difficult for organizations to keep up with the necessary standards and practices.
CVG Strategy Information Security Management System Consultants
CVG Strategy can assist your organization meet the challenges in meeting the CMMC final rule. We are dedicated to helping small businesses navigate federal regulations and contract requirements for Quality Management, Cybersecurity, Export Compliance, and Test and Evaluation. We can help you meet your information security management system goals. CVG Strategy QMS experts can provide the training required to understand and engage in a ISMS and make it meet desired objectives.
Identify CUI Areas with CVG Strategy Signs
CVG Strategy provides signs to identify areas containing CUI and export controlled items. These signs should be posted at all facility entrances where products are being produced or services are being performed that are under the control of the U.S. Department of State Directorate of Defense Trade Controls (DDTC) and are subject to the International Traffic in Arms Regulations per title 22, Code of Federal Regulations (CFR), Parts 120-130.