How to Achieve CMMC 2.0 Compliance in 8 Steps: A Step-by-Step Guide

For organizations seeking to work with the U.S. Department of Defense (DoD), the Cybersecurity Maturity Model Certification (CMMC) has emerged as a crucial framework developed by the DoD to ensure robust cybersecurity practices among government contractors. If your organization aims to win or keep DoD contracts, achieving CMMC compliance is non-negotiable.

The path to compliance, however, can be complex and daunting. In this comprehensive guide, we will provide you with a step-by-step roadmap to help you understand the CMMC framework, identify the necessary actions, and successfully achieve CMMC compliance. By following this guide, you will gain the knowledge and insights needed to bolster your organization’s cybersecurity posture and confidently pursue DoD contracts in an increasingly competitive and risk-averse environment.

The CMMC certification process is arduous but our CMMC 2.0 compliance roadmap can help.

CMMC Compliance Overview

The Cybersecurity Maturity Model Certification (CMMC) is a critical framework designed to enhance the protection of controlled unclassified information (CUI) within the Defense Industrial Base (DIB). Instituted by the United States Department of Defense (DoD), CMMC compliance represents a pivotal shift towards a more unified and standardized approach to cybersecurity, encapsulating a comprehensive blend of processes, practices, and strategies aimed at bolstering the defense against cyber threats.

At its core, the CMMC 2.0 framework categorizes cybersecurity readiness into three progressive levels, ranging from basic cyber hygiene practices at Level 1 to advanced and progressive capabilities at Level 3. This stratification ensures that contractors and subcontractors within the DIB can incrementally enhance their cybersecurity posture, aligning with the specific requirements and threats pertinent to their level of operation and the sensitive nature of the information they handle.

Achieving CMMC compliance is not merely a regulatory hurdle but a competitive advantage in the DoD contracting landscape. It necessitates a thorough assessment by authorized CMMC third party assessment organizations (C3PAOs) to validate the implementation of requisite cybersecurity practices and processes. This certification process underscores the DoD’s commitment to safeguarding sensitive defense information, effectively mitigating risks posed by cyber adversaries.

CMMC compliance also reflects an ongoing commitment to fortify the defense sector’s cyber resilience. Through periodic updates and iterations, the CMMC framework adapts to the ever-changing cyber threat landscape to ensure defense contractors always embrace the latest cybersecurity best practices. As a result, DIB contractors are encouraged to view CMMC compliance not as a static benchmark but as a continuous journey towards achieving and maintaining the highest standards of cybersecurity.

8 Steps to CMMC Compliance

The table below provides a high-level overview of the CMMC compliance process, providing a brief description of the eight steps.

Now let’s take a deep dive into each of these steps to better understand what you need to do to achieve CMMC 2.0 compliance.

Step 1: Understand CMMC Levels

CMMC 2.0 introduces a new approach to maturity levels, reducing them from five in CMMC 1.0 to three tiers. These tiers align closely with the NIST 800 standards and eliminate the maturity processes and unique security practices of CMMC 1.0.

The three CMMC 2.0 tiers are:

CMMC 2.0 Level 1: Foundational

At this level, organizations are required to conduct an annual self-assessment that must be attested by a corporate executive. The focus is on meeting the basic safeguarding requirements for Federal Contract Information (FCI) as specified in the Federal Acquisitions Regulations (FAR) Clause 52.204-21.

CMMC 2.0 Level 2: Advanced

Aligned with NIST SP 800-171, the Advanced level necessitates triennial third-party assessments for contractors involved in transmitting, sharing, receiving, and storing critical national security information. These assessments are conducted by CMMC Third Party Assessor Organizations (C3PAOs). However, select contractors falling into Level 2 only need to perform annual self-assessments with corporate attestation. Level 2 encompasses the security requirements for CUI outlined in NIST SP 800-171 Rev 2, according to Defense Federal Acquisition Regulation Supplement (DFARS) Clause 252.204-7012.

For Level 3, there are 134 required controls (110 from NIST SP 800-171 and an additional 24 from NIST SP 800-172). These controls are a means of managing risk that includes policies, procedures, guidelines, practices, or organizational structures, which can be of an administrative, technical, management, or legal nature, and are specified by NIST SP 800-171, NIST SP 800-172, and FAR 52.204-21. These practices sit under 14 different domains that are a subset of NIST SP 800-172. CMMC 2.0 requires the contractor to go beyond mere documentation of processes and instead have an active role in the management and implementation of the controls in order to provide the highest level of security possible.

CMMC 2.0 Level 3: Expert

For Level 3, there are 134 required controls (110 from NIST SP 800-171 and an additional 24 from NIST SP 800-172). These controls are a means of managing risk that includes policies, procedures, guidelines, practices, or organizational structures, which can be of an administrative, technical, management, or legal nature, and are specified by NIST SP 800-171, NIST SP 800-172, and FAR 52.204-21. These practices sit under 14 different domains that are a subset of NIST SP 800-172. CMMC 2.0 requires the contractor to go beyond mere documentation of processes and instead have an active role in the management and implementation of the controls in order to provide the highest level of security possible.

Step 2: Conduct a Gap Analysis

Performing a gap analysis involves comparing your organization’s current cybersecurity posture to the requirements of the relevant CMMC level. Identify the areas where your organization falls short and determine the specific actions needed to bridge those gaps. This analysis helps you understand the scope of work required to achieve compliance.

KEY TAKEAWAYS

1. Understand CMMC’s Significance:
   Compliance also offers businesses a competitive advantage, showcasing a commitment to robust cybersecurity practices.
2. CMMC 2.0 Framework has Changed:
   CMMC 2.0 offers a streamlined approach, including just three maturity levels, tailored to the sensitivity of information handled.
3. Achieve CMMC Compliance in 8 Steps:
   Key actions include conducting a gap analysis, developing a SSP, implementing security controls, and establishing a POA&M.
4. Engage with C3PAOs:
   C3PAOs identify weaknesses, develop remediation strategies, and prioritize compliance efforts effectively.
5. Compliance Requires Continuous Effort:
   Organizations must continuously monitor and update their security measures to adapt to evolving threats and requirements.

Step 3: Develop a System Security Plan (SSP)

A System Security Plan (SSP) is an essential document for organizations seeking compliance with CMMC. The SSP provides a comprehensive overview of the security controls and safeguards implemented within an organization’s systems. The key components in an SSP for CMMC typically include:

1. Introduction: Provide an introduction to the SSP, including the purpose, scope, and objectives of the document. Clearly state the system or systems being covered by the plan.
2. System Overview: Describe the system(s) being addressed in the SSP, including its purpose, functionality, and any unique characteristics. This section should provide sufficient context to understand the security requirements.
3. System Boundaries: Clearly define the boundaries of the system, including its connections to external systems, networks, and data flows. Identify any dependencies or interdependencies that impact the security posture.
4. Security Control Implementation: Present a detailed description of the security controls implemented within the system. Align these controls with the specific CMMC requirements for the desired level of certification. Provide an overview of how each control is implemented and any supporting procedures, tools, or technologies employed.
5. Control Objective Statements: For each security control, provide a concise objective statement that describes the intended outcome or purpose of the control. These statements should be aligned with the control objectives specified in the CMMC framework.
6. Control Implementation Status: Indicate the status of each control’s implementation, specifying whether it is fully implemented, partially implemented, or planned for future implementation. Include any relevant notes or explanations for controls that are not yet fully implemented.
7. Control Responsibility: Identify the roles and responsibilities of individuals or teams responsible for implementing, operating, and maintaining each security control. Assign accountability for control implementation and ongoing monitoring.
8. Control Monitoring: Describe the processes and mechanisms in place to monitor the effectiveness of the implemented controls. Explain how control performance is measured, evaluated, and reported on a regular basis.
9. Incident Response and Reporting: Outline the incident response procedures in place for the system. Include steps for reporting security incidents, contact information for responsible parties, and any required notifications or reporting to external entities.
10. Continuous Monitoring: Describe the procedures for ongoing monitoring of the system’s security posture. Explain how security events, vulnerabilities, and system changes are assessed and addressed over time.

The SSP should be regularly updated to reflect changes in the system’s security posture, new threats, or changes in compliance requirements. It is also important to ensure that the SSP is aligned with other compliance documents, such as the System Assessment Plan (SAP) and the Plan of Action and Milestones (POA&M), to provide a comprehensive view of the organization’s security measures.

Step 4: Implement Security Controls

Based on the results of the gap analysis and the requirements outlined in the CMMC framework, begin implementing the necessary security controls. These controls cover various areas, including access control, identification and authentication, media protection, incident response, system and communication protection, and more. Ensure that your technical systems, processes, and policies align with the specified security controls.

Step 5: Establish a Plan of Action and Milestones (POA&M)

A POA&M is a document that outlines the specific actions, responsible parties, timelines, and milestones for addressing the residual risks and deficiencies identified during the implementation process. It provides a roadmap for achieving compliance and helps track progress toward closing the identified gaps. A POA&M for CMMC should include these activities:

1. Identify and Prioritize Weaknesses: Review the results of your gap analysis or security assessments to identify weaknesses or vulnerabilities in your cybersecurity controls and practices. Prioritize them based on their severity and potential impact on your organization’s security posture.
2. Define Remediation Actions: For each identified weakness or vulnerability, determine the specific actions required to address and remediate them. Clearly define the steps, tasks, and activities needed to implement the necessary improvements.
3. Set Timelines: Establish realistic timelines for completing each remediation action. Consider factors such as resource availability, complexity of the action, and the level of effort required. Ensure that the timelines are achievable and align with your organization’s priorities.
4. Assign Responsibilities: Assign clear responsibilities to individuals or teams for implementing each remediation action. Clearly communicate the assigned roles and ensure that the responsible parties understand their duties and expectations.
5. Specify Milestones: Break down the remediation actions into smaller milestones or checkpoints to track progress. Set specific milestones that indicate key stages or significant steps in completing the overall remediation process.
6. Include Mitigation Strategies: Develop mitigation strategies for any weaknesses or vulnerabilities that cannot be immediately addressed due to resource limitations, dependencies, or other factors. These strategies should outline temporary measures to reduce risk while working toward a permanent resolution.
7. Document Supporting Information: Include relevant details and supporting information for each remediation action in the POA&M. This can include additional documentation, references to standards or best practices, or any necessary technical information.
8. Establish Monitoring and Reporting: Define a process for monitoring the progress of the POA&M, including regular updates and reporting on the status of remediation actions. Establish mechanisms to track completion, monitor effectiveness, and communicate any changes or updates to relevant stakeholders.
9. Review and Update: Regularly review and update the POA&M to reflect changes in the cybersecurity landscape, emerging threats, or evolving compliance requirements. Assess the effectiveness of implemented remediation actions and make adjustments as necessary.
10. Align With Other Compliance Efforts: Ensure that the POA&M is aligned with other compliance-related documents and activities, such as the SSP (outlined in step 3) and ongoing risk management processes. Consistency and integration among these elements help to maintain a comprehensive approach to cybersecurity.

The POA&M should be regularly reviewed, revised, and communicated to key stakeholders to ensure its effectiveness in addressing identified weaknesses and vulnerabilities. It serves as a roadmap for improving your organization’s security posture and achieving compliance with the CMMC requirements.

Step 6: Conduct Internal Assessments

Regularly perform internal assessments to evaluate your organization’s adherence to CMMC requirements. These assessments can be conducted by internal teams or external consultants and should include reviewing policies, conducting technical audits, and verifying that security controls are effectively implemented. Internal assessments help identify areas that require improvement and ensure ongoing compliance.

Step 7: Engage With a Third-party Assessor

To achieve CMMC compliance, your organization must engage with a CMMC Third Party Assessor Organization (C3PAO). The C3PAO will conduct an official assessment of your organization’s cybersecurity practices and provide the certification necessary to bid on DoD contracts.

C3PAOs play a crucial role in assisting organizations with achieving CMMC 2.0 compliance by providing independent and unbiased assessments. Being certified by the CMMC Accreditation Body (CMMC-AB), these organizations possess the expertise and knowledge required to evaluate an organization’s cybersecurity practices accurately. Their external perspective enables a thorough and objective assessment of an organization’s compliance readiness.

Another significant benefit of working with a C3PAO is their ability to conduct comprehensive assessments. C3PAOs perform in-depth evaluations of an organization’s security controls, policies, and procedures. Through rigorous testing and analysis, they identify any gaps or vulnerabilities that may hinder compliance with CMMC requirements. This helps organizations gain a clear understanding of their current security posture and take the necessary steps to address deficiencies.

Once weaknesses are identified, C3PAOs offer recommendations and strategies for improvement. They help organizations develop a Plan of Action and Milestones (POA&M), providing a roadmap to enhance their cybersecurity practices and align with CMMC requirements. This guidance helps organizations prioritize remediation efforts and establish a solid foundation for achieving and maintaining compliance.

Step 8: Maintain Compliance

CMMC compliance is an ongoing process. Once certified, it is imperative for organizations to maintain compliance by continuously monitoring and updating their security measures to adapt to changing threats and evolving CMMC requirements. Conduct regular internal assessments, review and update policies and procedures, provide ongoing training to employees, and stay informed about the latest guidelines and updates from the DoD.

Take a Huge Leap to Achieve CMMC 2.0 Compliance With Kiteworks

The Kiteworks Private Content Network offers support for nearly 90% of the practice controls in CMMC 2.0 Level 2, surpassing any other technology solution currently available. Kiteworks is also FedRAMP Authorized for Moderate Level Impact. In addition, Kiteworks supports various compliance requirements, including ISO 27001, 27017, and 27018, SOC 2, Cyber Essentials Plus, FIPS 140-2, Information Security Registered Assessors Program (IRAP) assessment at the PROTECTED level controls, and other measures.

These achievements ensure robust protections, addressing identified risks and collaborating with a C3PAO for assessment and accreditation.

A hardened virtual appliance, secure deployment options, authentication mechanisms, automatic end-to-end encryption, integrations with security infrastructure, and robust logging and audit reporting capabilities provide further protection for sensitive content like CUI, customer records, financial information, intellectual property, and others.

Kiteworks empowers organizations to send this content securely and in compliance, whether it’s shared through email, file sharing, managed file transfer (MFT), web forms, or application programming interfaces (APIs). All file sharing activity is tracked and logged so organizations can prove to regulators they know who is accessing sensitive content.

Schedule a custom demo today to understand how Kiteworks can accelerate your CMMC 2.0 compliance.

Additional Resources

• Blog Post Choosing Which CMMC Level Is Right for Your Business
• Video Join the Kiteworks Discord Server and Connect with Like-minded Professionals for CMMC 2.0 Compliance Support
• Blog Post A Roadmap for CMMC 2.0 Compliance for DoD Contractors
• Guide CMMC 2.0 Compliance Mapping for Sensitive Content Communications
• Blog Post 12 Things Defense Industrial Base Suppliers Need to Know When Preparing for CMMC 2.0