CMMC Certification Best Practices

The key difference between CMMC compliance and CMMC certification lies in the formal verification process. CMMC compliance refers to an organization that meets the requirements and practices outlined in the CMMC framework. CMMC compliance can be self-assessed or internally evaluated and does not involve a formal third-party assessment or official recognition. CMMC certification, by contrast, involves a formal assessment conducted by an authorized third party assessment organization (C3PAOs). This assessment provides external validation that an organization has met a required CMMC level. CMMC certification is required for a defense contractor seeking to bid on certain Department of Defense (DoD) contracts.

NIST 800-171 compliance and CMMC compliance are closely related, but they are not exactly equivalent. NIST 800-171 is the foundation for CMMC 2.0 Level 2. All 110 security requirements from NIST 800-171 are incorporated into CMMC Level 2. The key differences between NIST 800-171 compliance and CMMC compliance lie in scope, assessment, and maturity. CMMC is broader in scope and includes additional practices beyond NIST 800-171, especially at higher levels. NIST 800-171 allows for self-assessment, while CMMC requires certification from a third party assessment organization (C3PAOs) for certain levels. Finally, CMMC introduces the concept of “maturity” in implementing cybersecurity practices, which is not present in NIST 800-171.

CMMC C3PAO is a CMMC Third Party Assessor Organization (C3PAOs) authorized and certified by the CMMC Accreditation Body (CMMC-AB) to conduct assessments of contractors and subcontractors seeking certification to demonstrate compliance with the CMMC standard. C3PAOs are entrusted with assessing and certifying that companies in the defense industrial base (DIB) supply chain have met the cybersecurity requirements of the CMMC standard. Their responsibilities include evaluating and issuing certificates of adherence to the CMMC standard. The C3PAO must review and certify the contractor or subcontractor’s audit and self-assessment reports based on the DoD’s Cybersecurity Maturity Model. The C3PAO must also be able to recommend and implement corrective actions as needed.

CMMC compliance applies to all defense contractors within the defense supply chain, also known as the defense industrial base (DIB). This includes contractors, vendors, and any other contracted third parties related to the support of the department of defense (DoD). All civilian organizations that do business with the DoD must comply with CMMC 2.0, based on the type of controlled unclassified information (CUI) and federal contract information (FCI) that they handle and exchange. The list of entities includes:

• DoD prime contractors
• DoD subcontractors
• Suppliers at all tiers in the DIB
• DoD small business suppliers
• Commercial suppliers that process, handle, or store CUI
• Foreign suppliers
• Team members of DoD contractors that handle CUI such as IT managed service providers

CMMC 1.0 and CMMC 2.0 are different versions of the Cybersecurity Maturity Model Certification (CMMC) framework. The Department of Defense (DoD) introduced CMMC 2.0 in November 2021 as a streamlined and improved version of the original CMMC 1.0. CMMC 2.0 is designed to reduce costs and complexity while maintaining high security standards. For example, the DoD reduced the number of maturity levels from five for CMMC 1.0 to three for CMMC 2.0. CMMC 2.0 allows annual self-assessment for Level 1 and some Level 2 contracts, as opposed to a third party assessment by a C3PAO for all levels under CMMC 1.0. CMMC 2.0 also introduces Plans of Action & Milestones (POA&Ms) for certain requirements. Finally, the CMMC 2.0 implementation timeline has been revised and extended and is more closely aligned with NIST 800-171.