Contractors face big changes from DOD’s new Cybersecurity Maturity Model (CMMC)

The Department of Defense (DoD) recently announced the development of the ”Cybersecurity Maturity Model Certification” (CMMC), a framework aimed at assessing and enhancing the cybersecurity posture of the Defense Industrial Base (DIB), particularly as it relates to controlled unclassified information (CUI) within the supply chain.

CUI is information the Government creates or possesses, or that an entity creates or possesses for or on behalf of the Government, that a law, regulation, or Government-wide policy requires or permits an agency to handle using safeguarding or dissemination controls. The DoD is planning to release Version 1.0 the CMMC framework in January 2020 and expects to incorporate CMMC requirements in Requests for Proposals (RFPs) beginning in June 2020.  This leaves contractors less than 8 months to comply with the changes.

The concept of a CMMC framework arose in response to a series of high-profile breaches of DoD information.  This caused DoD to reevaluate its reliance on the security controls in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 as enough to thwart the increasing and evolving threat, especially from nation-state actors.  Katie Arrington, Special Assistant to the Assistant Secretary of Defense for Acquisition for Cyber, Office of the Under Secretary of Acquisition and Sustainment, is among those leading this effort .

The CMMC is intended to serve as a verification mechanism to ensure appropriate levels of cybersecurity practices and processes are in place to ensure basic cyber hygiene as well as protect controlled unclassified information (CUI) that resides on the Department’s industry partners’ networks.

Key takeaways include:

  • The initial implementation of the CMMC is for DoD only.  However, the use of CUI terminology rather than covered defense information (CDI), which is used in DFARS 252.204-7012, indicates a potentially broader role for this model beyond DoD.
  • All companies conducting business with the DoD, including subcontractors, must be certified.
  • The CMMC is to combine relevant portions of various cybersecurity standards, such as NIST SP 800-171, NIST SP 800-53, ISO 270001, and ISO 27032, into one unified standard for cybersecurity.  Unlike NIST SP 800-171, which measures a contractor’s compliance with a specified set of controls, the CMMC will more broadly “measure the maturity of a company’s institutionalization of cybersecurity practices and processes.”
  • The CMMC is to designate maturity levels ranging from “Basic Cybersecurity Hygiene” to “Advanced.”  For a given CMMC level, the associated controls and processes, when implemented, are intended to reduce risk against a specific set of cyber threats.  Notably, DoD will assess which CMMC level is appropriate for a particular contract and incorporate that level into Sections L and M of the RFP as a “go/no go” evaluative determination.  This assessment of appropriate maturity levels on a procurement basis is akin to the Cyber Security Model that the United Kingdom’s Ministry of Defence (MoD) currently employs for all MoD contracts.
  • In general, contractors will be required to be certified by a third-party auditor.  Certain “higher level assessments” may be conducted by government assessors, including requiring activity personnel, the Defense Contract Management Agency (DCMA), and the Defense Counterintelligence and Security Agency (DCSA).  What qualifies as a higher level assessment is yet to be explained.
  • How long a certification will remain in effect is still under consideration.  Additionally, certification levels of contractors will be made public, though, details of specific findings will not be publicly accessible.
  • A compromise of a contractor’s systems will not result in automatic loss of certification.   However, depending on the circumstances of the compromise, the DoD intends to authorize program managers to require re-certification if they believe necessary.  It is unclear whether this obligation will be imposed via contract or regulation and what standard will be used to determine that a re-certification is necessary.
  • The cost of certification will be considered an allowable, reimbursable cost.  The FAQs state that the costs “will not be prohibitive.”


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