How to Meet the CMMC Maintenance Requirement: Best Practices for CMMC Compliance

The Cybersecurity Maturity Model Certification (CMMC) 2.0 is a critical framework for ensuring cybersecurity within the defense industrial base. Introduced by the U.S. Department of Defense (DoD), CMMC 2.0 is designed to protect controlled unclassified information (CUI) and federal contract information (FCI) exchanged with defense contractors.

Maintaining the systems that process, share, and store CUI and FCI is crucial for defense contractors, not just to protect this sensitive information but also to demonstrate CMMC compliance. As a result, the Maintenance domain, one of 17 domains in the CMMC 2.0 framework, is a fundamental requirement.

Understanding CMMC Maintainence

Maintenance refers the systematic process of sustaining, servicing, and repairing various assets, machinery, or systems to ensure optimal performance and longevity. It encompasses routine checks, troubleshooting, and corrective actions, aiming to minimize wear and tear, prevent unexpected breakdowns, and reduce costly downtime, thus ensuring smooth and efficient operations.

Understanding the CMMC maintenance definition and its practical application is vital for companies aiming to achieve compliance and protect sensitive data. In this article, we’ll explore the Maintenance requirement, including key components and compliance and implementation best practices, providing defense contractors a comprehensive overview and path to compliance.

CMMC 2.0 Overview

The Cybersecurity Maturity Model Certification (CMMC) framework is a crucial part of ensuring the protection of sensitive information across the defense industrial base (DIB) sector. Developed by the U.S. Department of Defense, the CMMC framework establishes a set of cybersecurity standards to safeguard controlled unclassified information (CUI) and federal contract information (FCI) from cyber threats. The CMMC compliance and certification are required for defense contractors, emphasizing the importance of cybersecurity resilience in safeguarding national security interests.

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

CMMC 2.0, the updated version of the model, streamlines the certification process by reducing the number of maturity levels from five to three: CMMC Level 1 (Foundational), CMMC Level 2 (Expert), and CMMC Level 3 (Advanced). This change aims to improve clarity and simplify the compliance process (but not the requirements) for defense contractors. CMMC 2.0 emphasizes a more flexible and adaptive approach by aligning closer with NIST SP 800-171 standards and introducing self-assessment options for some levels, which was not an option in the original version. This makes it easier for organizations to understand their requirements and work towards achieving compliance efficiently.

There are 14 domains or focus areas in the CMMC framework. Each domain has its own unique set of requirements. These domains are Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Identification and Authentication, Incident Response, Maintenance, Media Protection, Personnel Security, Physical Protection, Risk Assessment, Security Assessment, System and Communications Protection, and System and Information Integrity.

Introduction to the Maintenance Domain Requirement in CMMC 2.0

The CMMC 2.0 framework places a strong emphasis on the significance of implementing effective maintenance practices for organizational systems. These practices are critical for ensuring that cybersecurity measures remain current and are regularly updated to address emerging threats and vulnerabilities. By maintaining robust cybersecurity protocols, organizations can protect sensitive data and maintain the integrity and security of their systems. This involves not only routine updates and patches but also system maintenance administration, namely proactive monitoring and assessment of security measures to adapt to the evolving cyber threat landscape. Implementing these maintenance activities helps organizations align with compliance requirements and safeguard their information assets effectively.

By adhering to these guidelines, organizations can enhance system reliability, reduce vulnerabilities, and ensure compliance with the latest cybersecurity standards.

System Maintenance Administration

System maintenance administration is crucial for ensuring the seamless operation of IT infrastructures. Regular updates and checks help in identifying potential issues before they escalate. Efficient administration minimizes downtime, enhances security, and optimizes system performance, allowing businesses to function smoothly and maintain competitive advantages in their respective markets.

The CMMC Maintenance Requirement

The Maintenance requirement in the CMMC 2.0 framework focuses on regular updates and repairs necessary for the continued security and operational efficiency of systems that interact with CUI and FCI. The Maintenance requirement emphasizes the need for consistent updates and patches, ensuring that security vulnerabilities are addressed promptly to protect CUI and FCI.

Maintenance includes both planned and unplanned activities. Planned maintenance involves scheduled activities aimed at preventing unexpected system failures and maintaining IT infrastructure integrity. This includes regular updates, patches, and software upgrades. Implementing a consistent schedule ensures that cybersecurity measures are continuously enhanced, ultimately meeting the CMMC maintenance controls and promoting robust data protection strategies.

By contrast, unplanned maintenance refers to unexpected repairs and troubleshooting activities triggered by unforeseen system issues or security incidents. These activities are crucial for promptly addressing vulnerabilities and restoring normal operations. Efficient handling of unplanned tasks ensures compliance with CMMC maintenance requirements by swiftly mitigating potential threats and minimizing security risks to the organization.

The Maintenance requirement contains key components that defense contractors must address in order to demonstrate CMMC compliance. The following are a few of the key principles:

• Regular Review and Update of Maintenance Procedures: Defense contractors must regularly review their maintenance procedures. By conducting frequent assessments, contractors can identify areas needing improvement and swiftly adapt to evolving cybersecurity threats. Regular reviews help ensure systems and processes remain secure and up-to-date. As technology evolves, so do potential vulnerabilities. By consistently updating maintenance practices, contractors ensure they address current threats effectively. This proactive approach supports compliance, protecting sensitive data and maintaining operational readiness.
• Documentation and Tracking of Maintenance Activities: Proper documentation and tracking of maintenance activities are crucial for CMMC compliance as well as operational resilience. By maintaining detailed records of all maintenance actions, including schedules, procedures, and personnel involved, organizations establish a transparent history of maintenance, facilitating audits and minimizing potential vulnerabilities in cybersecurity practices.
• Ensuring Secure Remote Maintenance Practices: By implementing robust security protocols to protect sensitive data during remote access sessions, organizations safeguard their critical systems from unauthorized access, mitigating potential cyber threats in remote environments. Secure remote maintenance encompasses identifying potential vulnerabilities, implementing continuous monitoring, and conducting regular audits.
• Verification of Equipment and Tool Integrity: Defense contractors must ensure each tool and piece of equipment meets the CMMC standards as defined in the Maintenance requirement. Implementing a routine schedule for equipment and tool inspections and audits, ensures tools are functioning as expected. Verifying tools and equipment are operating correctly and securely helps identify and mitigate potential vulnerabilities, thereby strengthening organizational cybersecurity defenses. Be sure to document maintenance procedures, schedule regular assessments, and train personnel to recognize and address issues promptly.
• Personnel Training on Maintenance Security Policies: Familiarizing staff with the CMMC framework’s expectations for maintaining secure operations ensures that personnel understand the critical role of maintenance within the broader context of cybersecurity compliance. Staff must understand specific benchmarks and practices required for maintaining systems securely. This includes knowledge of ongoing assessments and updates, emphasizing the dynamic nature of cybersecurity threats and the need for regular maintenance.

By adhering to elements of the Maintenance requirement, defense contractors can protect the information they share with the DoD, earning and maintaining trust in their cybersecurity practices.

Need to comply with CMMC? Here is your complete CMMC compliance checklist.

Best Practices for CMMC Maintenance Requirement Compliance

Achieving CMMC compliance for the Maintenance domain requires implementing best practices. Here are several strategies defense contractors can employ:

1. Conduct Regular System Audits: Systematically review and evaluate your technology infrastructure to detect and address any issues related to system maintenance, which could potentially compromise the functionality and security of the systems. Maintenance-related issues might include outdated software, malfunctioning hardware, and misconfigured settings, among others. By identifying these problems early, organizations can take proactive measures to correct them, thereby minimizing downtime and preventing potential security breaches or operational disruptions. Audits help verify that maintenance activities, such as updates, patches, and repairs, are consistently tracked and documented. Audits also provide an opportunity to assess the current security posture, identify vulnerabilities, and implement necessary improvements, enabling a cycle of continuous improvement, where potential threats are promptly identified and mitigated.
2. Deploy Automated Patch Management: Implementing automated systems that are designed to automatically detect, download, and install the latest security patches and updates for software and operating systems. This ensures that all systems remain up-to-date with the latest security enhancements, significantly reducing the risk of cyber threats. Automated patch management minimizes the window of opportunity for attackers by quickly addressing these vulnerabilities. It also reduces the burden on IT staff, freeing them to focus on other critical tasks.
3. Document Maintenance Processes: Document every step and action taken during maintenance, including the date and time of the activity, the individuals involved, the specific tasks performed, and any materials or parts used. These detailed records create a transparent and easily traceable history of maintenance efforts, aid in ensuring ongoing operational integrity and safety, and help identify trends, mitigate risks, and improve future maintenance processes. Additionally, having a well-organized record system can facilitate smoother communication and collaboration among maintenance teams, management, and external auditors or regulatory bodies.
4. Train Employees: Employees should be kept up-to-date with emerging cybersecurity threats and best practices for mitigating these risks. A structured training program educates staff about the latest maintenance procedures, emphasizing the significance of security measures in their daily tasks. Well-crafted training sessions might include workshops, online courses, and hands-on activities that reinforce the importance of following protocols meticulously. By doing so, employees will become proficient in recognizing potential security vulnerabilities and taking appropriate action to prevent cyber incidents.
5. Enlist Third-party Assessments: Utilizing certified third-party assessor organizations (C3PAOs) to review maintenance practices help organizations identify areas that might not meet industry standards or could be optimized for better efficiency and reliability. C3PAOs conduct thorough and objective assessments of the current maintenance protocols and procedures in place. They offer an unbiased perspective, highlighting potential weaknesses that internal teams may overlook due to familiarity or routine. Additionally, these assessments provide actionable recommendations for improvements, helping organizations enhance their maintenance practices, ensuring CMMC compliance but also increasing equipment lifespan, reducing downtime, and overall operational efficiency.
6. Perform Regular Backups: Data backups provide organizations a safety net, enabling restoration of systems, minimizing downtime, and ultimately ensuring business continuity. Start by identifying all critical data and applications that need to be backed up. Choose appropriate backup solutions, such as cloud storage, external hard drives, or dedicated backup servers, depending on their needs, budget, and security requirements. Organizations should establish a backup schedule – daily, weekly, or even real-time – that aligns with their operational demands. Automating the backup process can enhance reliability and ensure that backups are consistently performed without requiring manual intervention. Organizations should also verify the integrity and functionality of their backup systems. Periodically testing data restoration processes ensures that backups are not only being created but are also usable and complete.
7. Implement Change Management Procedures: Clearly defining the changes that need to be made, whether they involve updates, modifications, or fixes to the existing system. Each proposed change should be meticulously documented to create a comprehensive record that outlines the specifics of what the change entails, its purpose, and its expected impact on the system. The documentation process should include detailed descriptions of the change, the rationale behind it, the components of the system that will be affected, and the anticipated outcome. This ensures that every change is transparent, traceable, and open to scrutiny. Once changes are approved, the implementation phase should follow a structured approach, often involving a step-by-step deployment plan. After deployment, thorough monitoring is essential to ensure that the changes have the desired effect without introducing new issues. If problems arise, there should be a plan to revert to the previous stable version.
8. Deploy Access Control Measures: Establish strict protocols and guidelines that determine who is permitted to access various system functionalities and perform specific tasks. This ensures that only authorized personnel, like IT administrators or designated maintenance staff, have the ability to carry out maintenance activities on critical systems and infrastructure. This restriction is crucial because maintenance tasks often involve modifying system configurations, updating software, and managing sensitive data, all of which can have significant implications for system performance and security. By controlling access to these tasks, organizations can minimize the risk of malicious activities and errors that may arise from unqualified individuals making changes to the system. Implement access control measures and technologies like role-based access control (RBAC) or attribute-based access control (ABAC) to help manage permissions. Perform regular audits and monitoring of access logs to track who accesses the systems, ensuring accountability and providing insights into any unauthorized access attempts.
9. Establish Incident Response Planning: Develop and maintain a comprehensive incident response plan that is specifically designed to address any security incidents related to maintenance activities. These plans should outline clear procedures and roles for team members, ensuring a coordinated and efficient response to potential threats. It is crucial to regularly review and revise these plans to incorporate new insights, emerging threats, and evolving industry best practices. By doing so, the organization can react promptly and effectively, minimizing potential damages or disruptions. Additionally, conducting regular drills and training sessions can help ensure that all team members are familiar with their responsibilities and can execute the plan seamlessly during an actual incident.
10. Collaborate with Vendors: Extensive collaboration with vendors strengthens their adherence to the CMMC framework’s Maintenance requirement. Establish clear communication channels and regular check-ins to discuss compliance expectations and progress. Provide vendors with detailed guidelines and resources to help them understand the maintenance criteria defined by CMMC. A robust vendor risk management program includes conducting audits and reviews of vendor processes and systems to identify any gaps or areas needing improvement. Lastly, offer support and guidance to vendors to address any compliance issues and ensure they have the necessary tools and information to meet the certification standards.

How to Enforce Maintenance in Your Organization

Establishing a robust maintenance plan is crucial for organizational efficiency. It involves setting clear protocols, routine checks, and empowering staff with training and resources. Leadership plays a pivotal role in ensuring staff adheres to CMMC Maintenance best practices. Technology helps, too. It can streamline processes, ensuring that maintenance tasks are executed efficiently and on-time, ensuring disruptions are minimized.

Invest in Maintenance Personnel

Maintenance personnel play a crucial role in ensuring the smooth operation of facilities and equipment. These skilled professionals are responsible for performing routine inspections, troubleshooting issues, and implementing preventive measures. Their expertise is vital in minimizing downtime and ensuring that all systems function efficiently, contributing significantly to operational excellence and safety.

Investing in qualified maintenance personnel is crucial for meeting CMMC 2.0 maintenance requirements. Skilled professionals ensure that your systems are compliant with CMMC control maintenance standards, contributing to a robust security posture. To align with CMMC maintenance definitions and overviews, organizations should prioritize finding candidates with a strong background in IT infrastructure and cybersecurity.

Consider leveraging online platforms and specialized agencies to source talent with relevant expertise. Training is equally important. Encourage ongoing education and certifications to keep personnel updated on the latest CMMC maintenance requirements and best practices. Retention strategies, such as offering competitive salaries and fostering a supportive work environment, can help maintain a dedicated team.

Nonlocal Maintenance

Nonlocal maintenance refers to the practice where maintenance tasks are managed or executed from a remote location. Nonlocal maintenance involves securely managing IT systems remotely. Implement encryption protocols and multi-factor authentication to maintain compliance. Regularly update control configurations to ensure effective monitoring and incident response capabilities. Documenting procedures enhances transparency and accountability.

Nonlocal maintenance still requires effective maintenance personnel. To effectively manage nonlocal maintenance, IT personnel must document all access and control activities to ensure compliance with CMMC maintenance requirement, and regularly review and update nonlocal maintenance practices. Technological advancements have significantly facilitated this method, leading to reduced downtime and improved operational efficiency.

Kiteworks Supports the CMMC Maintenance Requirement with a Private Content Network

By focusing on timely updates, thorough documentation, and regular audits, defense contractors can effectively safeguard CUI and FCI. Embracing the best practices we’ve shared will not only ensure CMMC compliance as it pertains to the Maintenance requirement, but also strengthen your organization’s overall security posture against evolving cyber threats.

Kiteworks is built on a hardened virtual appliance that helps defense contractors comply with the CMMC Maintenance requirement in several ways:

• Zero-trust Least Privilege Access: Administrators have just a few privileged user accounts, each with narrowly defined permissions and no access to the OS. Folder managers set permissions like Manager, Collaborator, View only, etc. to restrict access to authorized personnel. They can also set expiration dates that limit file accessibility for periods of time.
• Automated System Updates: Software stack upgrades are automated.
• Enterprise-level Security: Kiteworks comes with a built-in network firewall, WAF, intrusion detection, and strong encryption in transit and at rest. The appliance also features authentication hardening and embedded antivirus protection. Periodic penetration tests and regular security audits are conducted.
• Regular Security Patch Management: Each release is scanned for vulnerabilities prior to deployment and contains security and bug fixes. Patches and hot fixes are deployed quickly.
• Comprehensive Monitoring and Logging: Kiteworks’ CISO dashboard monitors all file activity – who sent what to whom and when – and capture this activity in detailed, audit logs that can be fed and analyzed by your SIEM system.
• Advanced Intrusion Detection and Alerts: Kiteworks monitors the behavior of all executables, file systems, and web traffic. It enforces strict policies, sending alerts and shutting down unexpected activity before an attacker can damage or exfiltrate sensitive content.

By integrating these capabilities, Kiteworks supports defense contractors in meeting the CMMC Maintenance requirements, ultimately bolstering their overall cybersecurity compliance and readiness.

The Kiteworks Private Content Network, a FIPS 140-2 Level validated secure file sharing and file transfer platform, consolidates email, file sharing, web forms, SFTP, managed file transfer, and next-generation digital rights management solution so organizations control, protect, and track every file as it enters and exits the organization.

Kiteworks supports nearly 90% of CMMC 2.0 Level 2 requirements out of the box. As a result, DoD contractors and subcontractors can accelerate their CMMC 2.0 Level 2 accreditation process by ensuring they have the right sensitive content communications platform in place.

With Kiteworks, DoD contractors and subcontractors unify their sensitive content communications into a dedicated Private Content Network, leveraging automated policy controls and tracking and cybersecurity protocols that align with CMMC 2.0 practices.

Kiteworks enables rapid CMMC 2.0 compliance with core capabilities and features including:

• Certification with key U.S. government compliance standards and requirements, including SSAE-16/SOC 2, NIST SP 800-171, and NIST SP 800-172
• FIPS 140-2 Level 1 validation
• FedRAMP Authorized for Moderate Impact Level CUI
• AES 256-bit encryption for data at rest, TLS 1.2 for data in transit, and sole encryption key ownership

Kiteworks deployment options include on-premises, hosted, private, hybrid, and FedRAMP virtual private cloud. With Kiteworks: control access to sensitive content; protect it when it’s shared externally using automated end-to-end encryption, multi-factor authentication, and security infrastructure integrations; see, track, and report all file activity, namely who sends what to whom, when, and how. Finally demonstrate compliance with regulations and standards like GDPR, HIPAA, CMMC, Cyber Essentials Plus, IRAP, and many more.

To learn more about Kiteworks, schedule a custom demo today.

Additional Resources

• Blog Post CMMC Compliance for Small Businesses: Challenges and Solutions
• Blog Post If You Need to Comply With CMMC 2.0, Here Is Your Complete CMMC Compliance Checklist
• Blog Post CMMC Audit Requirements: What Assessors Need to See When Gauging Your CMMC Readiness
• 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 Compliance