Did you know that the CMMC Program’s final rule (32CFR Part 170) came into effect on 16th December 2024? This means that you need to undergo a CMMC audit to certify that your business meets the utmost cybersecurity standards.
A CMMC will also put your business in good standing with the Department of Defense. You need this good standing to qualify as a contractor or subcontractor for DoD. Besides, you’ll be on the good side of the law- something every business wants to have.
It will give your clients confidence that they are working with a company that is compliant and dedicated to protecting sensitive data.
Therefore, you need to ascertain that your business is ready for a CMMC audit. Here is how to tell your level of preparedness.
1. Understand What A CMMC Audit Is
A CMMC audit is a test that a CMMC auditor conducts on your business and is an initiative that the Department of Defense uses to enhance cybersecurity across the Defense Industrial Base.
The audit is crucial in ensuring that your business adheres to standard security procedures and ultimately guarantees the protection of federal information.
Compliance with CMMC is a must-have for DoD contractors and sub-contractors. Failure to have CMMC compliance means not being able to bid for contracts, losing ongoing contracts, and, in the worst case, a legal case should you experience a data breach.
To standardize CMMC audits, the Department of Defense has set out key components of a CMMC that you need to know ahead of the audit.
One is the Tiered Model, which calls for your business to implement cybersecurity progressively. The advanced progression depends on the sensitivity and type of unclassified DoD information you deal with.
Second is the assessment requirements that the auditor will use to assess your business. The CMMC assessments allow the DoD to verify how your business is implementing existing cybersecurity procedures.
Third is the CMMC level your business needs to be at. Remember that as a DoD subcontractor or contractor handling any unclassified information, you must attain a specific level as a precondition for a contract award.
Now that you know what a CMMC is, it is time to assess your business readiness for a CMMC audit. To do that, you can hire a CMMC audit service that will thoroughly check your organization’s security structure and offer you a detailed report. This saves you a lot of time and money in the long term.
2. Confirm Your CMMC Level
The CMMC auditor will adhere to these three CMMC levels before they can confer you with a CMMC certification.
Level 1
While assessing for compliance at this level, the CMMC auditor will look at a business’s basic cybersecurity hygiene practices. These could include issues of incident reporting or access controls. If your organization handles Federal Contract Information, it is the target for this level.
The assessment is done annually, after which the organization affirms its cybersecurity compliance. FAR 52.204-21 has the 15 requirements that your business needs to fulfill to affirm it complies with this CMMC level.
Level 2
This second level of compliance is targeted at businesses that handle Controlled Unclassified Information (CUI). Owing to the information these organizations handle, the Department of Defense requires them to comply with 110 practices that align with NIST SP 800-171.
Level 3
Level 3 CMMC compliance applies to businesses involved in critical DoD programs. The Department of Defense has outlined 110 security requirements in NIST 800-171 that these organizations must fulfill to be considered compliant.
Therefore, these organizations must take a DIBCAC assessment and make an annual affirmation to verify their compliance.
3. Define Your Business CUI Environment
By this time, you know what CMMC level your business is at. Guided by your level, proceed to understand your scope. Set a CMMC assessment boundary that will help you measure your compliance levels.
Look at your personnel, systems, facilities and technologies that handle CUI to check for their suitability. You could measure this mapping data flow to check for your CUI storage, processing, and even transmission.
4. Identify Compliance Gaps
Use the requirements for each level to identify gaps in your compliance systems. For instance, if your business is at CMMC level 2, conduct a gap analysis against NIST SP 800-171.
Basic checks on access controls, incident response, configuration management, risk assessment, security training, and communication and systems protection.
As you carry out these checks, identify where your business is not compliant and develop an action plan to address these deficiencies. The assessment guides for each level are key to implementing the right measures.
5. Implement Necessary Security Practices
Implement some obvious security practices to prepare your business for a CMMC audit. For example, enforce multi-factor authentication.
Apply the least privilege access principle. Do some patching and continually conduct vulnerability assessments and management. Train your security teams on incident responses and take on incident response exercises.
Ensure that these controls are mature and fully operational before you get a CMMC auditor to conduct the audit. As you do this, keep evidence of this operation’s ability. Evidence could be in the form of system logs, screenshots, and training records.
6. Procure A C3PAO
Once you have done a self-check and are confident of your compliance based on your business’s required level of compliance, it is time to get a C3PAO. Ensure they are authorized by checking the CyberAB Marketplace.
While you procure an auditor, get your processes and personnel ready. Ensure staff understand their place in CUI protection. Make them appreciate the need for continuous compliance.
Conclusion
CMMC audits are rigorous but important in securing your business’s long-term security. Being CMMC compliant can make your business more competitive and credible. Compliance protects your organization against cyber threats, contractual losses, and reputational damages.
So, look at the benefits that come with this compliance as opposed to the tough requirements and prepare adequately to be certified. Make cybersecurity one of your operational fabrics, and you’ll be CMMC audit-ready.
