The federal government is tightening cybersecurity requirements for contractors. This means compliance with the Cybersecurity Maturity Model Certification (CMMC) is critical.
In 2024, CMMC plays a huge role in ensuring the security of controlled unclassified information. It is also integral in improving the defense industrial base’s overall security.
A contractor working with the DoD must meet specific CMMC requirements to be considered a CMMC compliance contractor and to secure contractors.
However, it is easy for contractors to make mistakes that could affect their certification and business prospects.
Some of the most common mistakes include the following:
Underestimating How Much Time and Resources Are Required for Compliance
Becoming compliant does not happen overnight. Contractors must put time and effort into the process, which can take several months, depending on the CMMC maturity level required.
For example, CMMC 1.0 once had five maturity levels. These included:
- CMMC Level 1: Basic Cyber Hygiene
- CMMC Level 2: Intermediate Cyber Hygiene
- CMMC Level 3: Good Cyber Hygiene
- CMMC Level 4: Proactive Cyber Hygiene
- CMMC Level 5: Advanced Cyber Hygiene
After several businesses complained about the complexity and cost of achieving these levels, the concept of CMMC 2.0 was introduced.
CMMC 2.0 only has three evaluation levels, but these still take a long time to complete and become compliant. CMMC 2.0 levels are:
- CMMC 2.0 Level 1: Foundational
- CMMC 2.0 Level 2: Advanced
- CMMC 2.0 Level 3: Expert
The 2.0 levels are more closely aligned with cybersecurity standards. Moreover, Level 1 and Level 2 certifications allow for self-assessments. While this may save time and money, it increases the risk of wrongfully certifying compliance.
It is also important to note that Level 2 is highly complex, which means self-assessment for this level is not the best idea. Companies that deal with controlled unclassified information must undergo third-party assessments for Level 2 compliance.
Even though 2.0 may be easier compliance-wise, it will still take significant time and effort. Contractors should start the process as early as possible. This will help them create a realistic timeline and find the resources to meet the necessary controls.
Moreover, rulemaking for CMMC 2.0 is still underway, so contractors must stay current with the upcoming changes.
Ignoring the Importance of Documentation
Many contractors also tend to ignore the importance of the relevant documentation. CMMC assessors go beyond reviewing the implementation of cybersecurity controls. They also want to see the documentation that proves the required practices are in place.
Inadequate or incomplete documentation can lead to a certification delay. In some instances, it may prevent a contractor from becoming compliant.
Generally speaking, the documentation should detail an organization’s policies, procedures, and evidence of cybersecurity measures. It is also important for these documents to be updated regularly to reflect changes in security practices.
Neglecting Employee Training on Cybersecurity Protocols
Cybersecurity is about more than just technology. It is about involving people (employees) in the effort against cybercrime. Contractors often make the mistake of not training employees on cyber training policies, etc.
The problem is that unaware or untrained employees can become the weak link in a strong system, leading to unexpected security breaches.
The CMMC framework requires employees to understand and follow all cybersecurity protocols. This means contractors must implement training programs covering all cybersecurity’s main elements.
Moreover, training cannot be a once-off event. Employees should receive regular training on an annual basis to ensure they retain the necessary information and knowledge.
Failing to Implement Monitoring and Assessment Processes
Achieving CMMC compliance is an ongoing process. When a contractor achieves compliance, it does not mean they are ‘done.’ Cybersecurity threats continue to evolve as technology does. This means cybersecurity measures and compliance must continue to evolve as well.
Therefore, contractors must continuously monitor and assess the effectiveness of their cybersecurity systems.
If they fail to do this, they become vulnerable to cyberattacks. Periodic system audits are not enough in 2024. It leaves a large gap in security measures between assessments.
Assuming Self-Assessment Is Enough
While CMMC 2.0 provides for self-assessment, contractors should not rely on this to achieve the highest level of compliance. Attempting to become certified at higher levels through self-assessment can result in a complete failure to meet the required standards.
Contractors who fail their official compliance assessments may also need to wait for a specific time before they can reapply. During that time, they may lose out on business opportunities.
It is always advisable for contractors to work with a qualified C3PAO (CMMC Third Party Assessment Organization) to achieve CMMC compliance. These organizations provide valuable insights that can make it easier for contractors to become CMMC compliant.
Cybersecurity Remains a DoD Priority
The defense department continues to prioritize cybersecurity in 2024. This means CMMC compliance is crucial to a contractor’s efforts to win or retain government contracts. Avoiding the above mistakes can help contractors become CMMC-certified faster. CMMC compliance will also ensure long-term success for contractors hoping to work with the DoD.
