Tag: DoD

CMMC Series: The Consequences for CMMC Non-Compliance
You may have thought we finished our series on the Cybersecurity Maturity Model Certification (CMMC) program, but we would be remiss if we didn’t cover the consequences and penalties for not complying with the program if you’re a current Department of Defense (DoD) contractor.

You may be thinking there’s a window to wait and see while rulings proceed on version 2.0 or have seen dates such as 2025 thrown out as the goal post for when the program will be completely finalized. Or maybe you’re just hoping the whole thing goes away, we get it. Looking at all of the controls and tiers can be overwhelming if your business is new to implementing cybersecurity measures.

However, the program is here to stay, and your business will be much better equipped to meet the requirements if you begin working on them now. There is a waiting list already for those wishing to obtain their certification earlier, and we expect the wait times to only grow as nearly 40,000 businesses who must comply with this program rush to get their certification before losing eligibility for existing contracts.

Beyond existing contracts, having your CMMC certification will make your business more competitive when seeking new contracts with the DoD. Progress towards CMMC is an investment in your business’s future, and it also meet the goals of the program which is protecting businesses from cyber threats.

So, what are the consequences for not working on CMMC compliance now, or in the future?

The DoD has said that all Defense Industrial Base (DIB) contractors must be compliant by 2025. There are no direct monetary penalties or fines for not being compliant at this time, however your business will no longer be eligible for defense contracts if you have not successfully completed your accreditation by that date.

Three years may seem like a long time but when you look at the scope of what’s necessary to be compliant with CMMC, it’s really a short window to get your ducks in a row. Tier one could be accomplished relatively easily by most businesses, but if your business handles any Confidential Unclassified Information, you’re really looking at a goal of tier three moving forward (or tier two if/when version 2.0 is released).

That’s also not counting the time spent in a waiting list for a member of the CMMC Accreditation Body to actually complete your assessment, you will need to work on your self-assessment status and POAM (Plan of Action and Milestones) prior to getting on the waiting list for CMMC accreditation.

It’s also important to note that your self-assessment must be confirmed by company leadership, it’s not enough to simply have your IT person or team complete the self-assessment and submit it.

The DoD has said they will randomly test contractor compliance and see if it matches what the contractor has inputted into Supplier Performance Risk System (SPRS). SPRS is a necessary requirement for being compliant with Defense Federal Acquisition Regulation Supplement (DFARS) which many contractors may already be aware of. They will be looking to see if your disclosures for DFARS in regards to CMMC/NIST match.

Submitting false information could make your business at risk for running afoul of the False Claims Act (FCA), which could leave you liable for civil fines and penalties. There is even a program in place to reward whistleblowers who bring to light businesses who are falsifying information about their cybersecurity practices on these forms.

This is all so much to say as there are significant risks involved with ignoring CMMC and we suggest you begin working on it now or we’re afraid you’ll be paying for it later.

If you need assistance with working on your CMMC accreditation, cybersecurity practices and compliance, DFARS forms or more – Valley Techlogic can assist you. Schedule a consultation today to learn how we can help your business meet your CMMC compliance goals for 2022.

Looking for more to read? We suggest these other articles from our site.
This article was powered by Valley TechLogic, IT service provider in Atwater, CA. You can find more information at https://www.valleytechlogic.com/ or on Facebook at https://www.facebook.com/valleytechlogic/ . Follow us on Twitter at https://x.com/valleytechlogic.
February 18, 2022
CMMC Series: Preparing for your assessment
This is our fifth article on this topic and as we bring it to a close, I’d like to first look back at what we’ve covered so far.

We started the series looking at what’s ahead for the Cybersecurity Maturity Model Certification (CMMC) program in 2022. Then we covered tiers one, two and three as they exist in the current 1.0 model of the program. We’re anticipating that tiers two and three will be merged going forward as version 2.0 rolls out (placing a larger burden on defense contractors looking to scale past the beginner controls in tier one and become more competitive in the marketplace).

So, if you’re reading this you’ve hopefully begun the process of implementing the controls within your business and are thinking it’s time to begin the process of obtaining your certification. There are several steps that come before actually obtaining your certification (although it should be noted that the CMMC Accreditation Body is currently in the process of hiring and waiting lists for certification could be lengthy at this time). The sooner you begin implementing the CMMC controls within your business, the sooner you can attempt to get on the waiting list to receive your certification.

The assessment process will follow these steps:
1. You will need to begin implementing a plan for CMMC within your business, and conduct a self-assessment against the NIST 800-171 (or partner with a provider like Valley Techlogic to assist you with this).
2. As you improve your processes you can submit your score to the Department of Defenses’ (DoD) Supplier Performance Risk System (SPRS).
3. From there you will need to identify the scope you wish to obtain for your business (it’s our opinion maturity level 3 will be required for most defense contractors in the future).
4. Obtain a third-party gap assessment, this will show you where your business is and where it needs to be to achieve your goals.
5. After addressing the gaps found in the assessment, you can look to the CMMC Accreditation Marketplace and choose a CMMC Third-Party Assessment Organization (C3PAO) to conduct your CMMC assessment.
6. The CMMC Accreditation Body will review the assessment submitted by your C3PAO and award you your CMMC certification.
Of course, this is boiling down many months (or even years) of preparation into what looks like 6 easy steps. The process will be time consuming and potentially costly, but for those who wish to continue doing business with the DoD it’s a necessary investment in the future.

As we’ve mentioned in past articles on the topic, defense contractors who refuse to comply with the CMMC process will no longer be eligible for defense contracts in the future. Beyond that, if you reach a higher level of certification, you will be in a better position to receive more contracts as it will be used as a comparative tool going forward.

If you’re like assistance with the CMMC self-assessment process or preparing for your CMMC AB assessment, Valley Techlogic has experience in this area. We have helped businesses begin the process of becoming CMMC ready, if you’d like to learn more schedule a consultation with our experts today.

Looking for more to read? We suggest these other articles from our site.
This article was powered by Valley TechLogic, IT service provider in Atwater, CA. You can find more information at https://www.valleytechlogic.com/ or on Facebook at https://www.facebook.com/valleytechlogic/ . Follow us on Twitter at https://x.com/valleytechlogic.
February 4, 2022
CMMC Series: Tier Two Overview
This is the third week of our Cybersecurity Maturity Model Certification (CMMC) Series. You can find week one, which was a look at what’s happening with CMMC in 2022 here. Last week, we gave you an overview of tier one which you can review here.

Tier one in CMMC really covers the basic foundational steps you must take to move on to tier two and tier three. For some contractors, tier one will be enough to keep and maintain compliance with their Department of Defense (DoD) contracts. Every situation is unique, but broadly speaking if you don’t handle Controlled Unclassified Information (CUI) in your business – tier one will probably be the extent that you need to reach.

If you do handle any CUI data, then we recommend you strive towards tier two or tier three. Many of the protections that come in the later tiers specifically cover how to safeguard this data and it’s in your businesses best interest to meet the requirements. While there are no direct financial penalties at the time of writing for not doing so, the DoD is considering a system of rewarding businesses who achieve greater CMMC maturity levels.

If you and another business are exactly the same in what you do and, in your pricing, – or even if their pricing is a bit higher than yours – if they have achieved tier three cybersecurity maturity model certification and your business is tier one or not certified at all yet, it’s likely your competitor will win the bid.

So, what goes into reaching tier two in CMMC?

Tier two is the next milestone within CMMC, and the difficulty does scale considerably with each level. While tier one had 17 provisions, tier two introduces 55 more for a total of 72 practices you’ll need to cover to meet the requirements (the practices are cumulative).

In addition to more practices tier two also introduces new domains.

First there is Access Control, tier two access control looks to limit access to who can log into your organizations systems (and how much they can access when they do).

Next is Awareness and Training, in tier two you will need to make sure your managers, administrators and anyone else you who would have access to sensitive systems is attending regular cybersecurity training.

In Audit and Accountability, we look to maintain logs of user activity for review.

Security Assessment is where we really begin to see accountability being held on organizations, you will need to conduct regular assessments as you work towards your cybersecurity goals and develop cybersecurity plans based on the assessment results.

Configuration Management covers the need to manage the configurations of your office devices and equipment with cybersecurity best practices in mind.

Identification and Authentication is similar to access control, but it specifically looks to limit sensitive systems to only those who should have authorization to access them.

While tier one in CMMC only covered the basics and didn’t address what happens when you have a cyber incident, tier two starts to cover that with the Incident Response control.

The Maintenance control in tier two actually refers to your devices and how you maintain them, and what you will need to do in case of their failure.

Media Protection in tier two covers specific provisions around the handling and destruction of removable media, such as flash drives.

We started looking at Physical Protection in tier one by keeping visitor logs, but tier two asks that you actually begin to escort guests through your facilities and screening personnel.

Tier one surprisingly doesn’t ask that you backup your data (even though we would always recommend that) – in tier two Recovery you must have a plan for backing up your data.

In tier two Risk Management, CMMC asks that you begin to conduct risk assessments and fix any vulnerabilities that are uncovered during the process.

Systems and Communications Protection in tier two includes controlling communications within your organization, not just monitoring them.

Finally, the System and Information Integrity domain covers actively monitoring your systems for breaches and quickly resolving any that come up.

As you can see, CMMC maturity tier two dives into the deep end of cybersecurity, but the provisions it covers will make a discernible impact in your cyber readiness throughout your entire business.

Does your business need to meet the requirements for being certified with CMMC? Valley Techlogic can help, we have experience helping DoD contracted businesses reach their cybersecurity and CMMC goals, as well as helping with the certification process itself. Learn more today in a free consultation.

Looking for more to read? We suggest these other articles from our site.
This article was powered by Valley TechLogic, IT service provider in Atwater, CA. You can find more information at https://www.valleytechlogic.com/ or on Facebook at https://www.facebook.com/valleytechlogic/ . Follow us on Twitter at https://x.com/valleytechlogic.
January 21, 2022
Cybersecurity Maturity Model Certification 2.0 has been announced, what it means for you and your business
If you’re a contractor or subcontractor for the Department of Defense (DoD) you probably at least have an awareness of the evolving situation surrounding the CMMC (Cybersecurity Maturity Model Certification) program, or maybe you’ve even begun the self-assessment process.

Announced summer of 2019, version 1.0 was released January 31^st, 2020, and a 5 year roll out was planned to get DoD contractors and subcontractors compliant with the framework. The framework is based on the security controls found in the National Institute of Standards and Technology (“NIST”) Special Publication (“SP”) 800-171, with many of the security controls found in CMMC having a direct correlation to a control found in NIST 800-171.

While the initial CMMC framework was aimed at bringing defense contractors up to speed in their cybersecurity efforts to protect critical Controlled Unclassified Information (CUI), the use of the broad term CUI instead of the defense specific Covered Defense Information (CDI) phrase may indicate that this framework will extend beyond just defense contractors in the future.

The controls found in NIST are applicable to businesses of all sizes and in all sectors so following the CMMC or NIST frameworks whether or not you’re defense contractor/subcontractor will mean your business will be well protected and compliant with rules and regulations set by your vendors, clients, and services for your business such as cybersecurity insurance.

In it’s original iteration there were 5 maturity levels found in CMMC, with levels 1-3 really closely following NIST and 4-5 going beyond the scope of what NIST covers. They were described as “maturity levels” as they were meant to measure the maturity of the cybersecurity practices found within your organization.

For most defense contractors, reaching level 3 of CMMC would be an ideal goal. Levels 4 and 5 covered practices outside the scope of most business’s and would require more specialized (and expensive) security practices. Even in version one of CMMC contractors were allowed to self-certify for maturity level 1, but beyond that would require outside certification. The waiting list to receive that certification is long, so planning to implement the required cybersecurity measures and getting on the waiting list to be certified ASAP is a good idea.

Now, as of November 4^th the DoD has announced an update to CMMC. Version 2 may be removing two of the levels and some of the security measures that were unique to CMMC framework, making the framework match NIST even more closely. Below is the chart we have created with the outlined changes as we know them and as of this posting.

Click to view the full size.

This is an evolving situation and as the rollout progresses it’s imperative that businesses that receive DoD contracts begin or continue to increase their efforts in becoming CMMC certified, which may mean drastically increasing your cybersecurity efforts across the board.

Valley Techlogic has experience in helping businesses meet the goals found within the CMMC framework and we’re ready to help your business meet your certification and cybersecurity goals today. Click here to schedule a quick consultation to find out more.

Looking for more to read? We suggest these other articles from our site.
This article was powered by Valley TechLogic, adns, n IT service provider in Atwater, CA. You can find more information at https://www.valleytechlogic.com/ or on Facebook at https://www.facebook.com/valleytechlogic/ . Follow us on Twitter at https://x.com/valleytechlogic.
November 17, 2021