As outlined in the Proposed Rule published in December of 2023, The Department of Defense (DoD) retains the right to audit your organization’s security controls using either Cybersecurity Maturity Model Certification (CMMC) or the existing DFAR 7012 requirements during the transitional period after the Final Rule (32 CFR) is released. Your organization must be prepared to prove compliance. The process of going from "noncompliance" to being "assessment ready" for CMMC can take anywhere from 10 to 18 months. Acting now gives your organization a significant competitive advantage. As stated in the Proposed Rule: “OSAs (Organization Seeking Assessment) may elect to complete a self-assessment or pursue a certification assessment at any time after issuance of the rule to distinguish themselves as competitive.”

To remain in the Defense Industrial Base (DIB), organizations are strongly advised to conduct a cost-benefit analysis to find the most cost-effective way to meet CMMC requirements. We have simplified the process by providing four (4) key steps to take for CMMC readiness.

1. Identify the Scope. This is arguably the most critical step in your CMMC compliance journey. It is imperative that you know exactly where your organization stores, processes, and transmits Controlled Unclassified Information (CUI) and/or Federal Contract Information (FCI). Once this has been identified, you must determine how the data is being handled within the organization and by whom. To minimize the scope of a CMMC assessment, your organization should seek to separate this data physically and logically by restricting its storage, processing or transmission to a specific department or facility to prevent unnecessary or unauthorized access.

2. Create Comprehensive Policies and Procedures. Policies provide a roadmap of what you are trying to accomplish, while procedures outline the specific steps that your organization intends to take to comply with CMMC requirements. By having well-defined policies and procedures in place, you can formulate a consistent approach to compliance, outline clear standards that everyone must follow and provide an unobstructed vision to the organization.

3. Identify Controls. As of today, organizations are highly advised to comply with all the requirements of NIST 800-171 R2 and meet all the Assessment Objectives requirements of NIST 800-171A to determine their compliance level. This will allow your organization to identify the controls currently in place and determine if they are effective in their application in meeting compliance requirements.

4. Implement Controls and Procedures. Technology can only take you so far. To be CMMC compliant, a culture shift is mandatory. Once your organization has identified any gaps/vulnerabilities, the next step is to address them. Sometimes, that requires a change in tools (i.e., Software, application, etc.). Most times, it requires a behavior change (i.e., Process shift). Employees will have to adjust to new processes, procedures, and a new way of doing things. This takes time. From explaining the “Why” behind the decisions to outlining the new processes, your employees will need time to adjust to the new processes outlined to ensure long-term compliance.

Conducting a CMMC self-assessment is the best way to prepare your organization. Although the journey to full compliance may seem long, delaying compliance only makes the process more expensive and time-consuming later. By taking proactive steps today, you can ensure your organization is prepared, gains the competitive advantage discussed in the Proposed Rule, and stands out among its peers.

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Our CMMC experts are here to guide you through this process every step of the way. Contact us to learn more today.