Guide 101: How to Implement CMMC Policy Templates In 5 Simple Steps
The US Department of Defense (DoD) employs thousands of private contractors every year. To streamline the working relationship and enhance cybersecurity, the department developed a policy model known as Cybersecurity Maturity Model Certification (CMMC).
Initially developed in 2010 through an executive order, the model seeks to create a standardized framework for storing, handling, and transmitting Controlled Unclassified Information (CUI).
Since the creation of CMMC, a lot has changed about data security, whereby contractors must meet strict standards set by the DOD through this policy model. Whether you are a large or small contractor, getting a contract with the DoD requires compliance with the CMMC.
Here’s how to implement CMMC policy templates in 5 simple steps.
5 Steps to Implementing CMMC Policy Template
CMMC implementation varies depending on the organization. So, we’ll focus on the general steps every contractor needs to check when implementing CMMC templates.
1. Understand CMMC Components and Requirements
Before creating and implementing a template, understanding the CMMC policy is the key. This is where CMMC policy templates come in handy, helping you meet compliance requirements by outlining the policies in an easy-to-understand manner.
So far, two versions of CMMC that mainly enforce NIST 800-171 policies better are available. The CMMC 1.0, created in 2019, has 5 maturity levels as follows;
- Level 1 -basic cyber hygiene
- Level 2 -intermediate cyber hygiene
- Level 3 -Good cyber hygiene
- Level 4 -Proactive cyber hygiene
- Level 5 -Advanced and progressive cyber hygiene
The levels address over 100 NIST 800-171 controls that further narrow down to 14 families. According to the DoD, every contractor must meet level one, while the other levels depend on the complexity of the contract.
CMMC 2.0 was rolled out in 2021 and has only level 3 maturity levels.
- Level 1- Foundational
- Level 2- Advanced
- Level 3 – Expert
Just like in the previous version, the complexity goes by the level. While the CMMC 2.0 has eliminated levels 2 and 4, the requirements are incorporated within the other levels.
The essence of understanding the content of all versions of CMMC is to ensure that you can create compliant templates. It is, therefore, easy to check the gaps and fix them before implementation.
2. Scope Organization Areas That Need Compliance
One of the confusing issues people have is that they think the whole organization requires CMMC compliance. However, this is not the case, as the compliance only needs to be on the critical areas that interact directly with DIB.
Eliminating the need to make the whole organization compliant saves time and a considerable amount of money. Since only specific departments need compliance, when implementing the CMMC, it is vital to scope those sections to ensure all the necessary attention is focused there.
Importantly, it is essential to note that any line of business that accesses FCI and CUI must meet CMMC. Therefore, identifying the business areas with this interaction and separating them from the rest of the company can save you a lot. This is because you can treat these departments as separate entities, saving you huge financial implications needed when seeking compliance.
A good example is some companies such as Boeing, GE, Pfizer, and others with separate departments that only deal with DoD. Only the concerned departments need CMMC compliance instead of the whole company, which can be expensive and nearly impossible to meet.
3. Conduct Self-Assessment
For a long time, even before the creation of CMMC, contractors relied on self-assessment on the road to certification. The assessment was based on the implementation of NIST 800-171 standards. This is essential to help an organization gauge compliance before getting third-party assessment and certification.
When a self-assessment process is done correctly, organizations increase the chances of getting certified. This is further complemented by providing correct information, which increases firm credibility. Besides, periodic assessment is crucial as it's easy to remain proactive when it comes to threats and thwarting them.
There are different ways firms can use to achieve self-assessment processes. One is the manual way, where you can use basic tools such as spreadsheets to analyze the data. The work is tedious and requires every data to be kept manually.
The alternative to the manual process is to implement powerful graph analytics tools such as Microsoft Azure Government. These are powerful and effective in assessing large amounts of data accurately. Large contractors with massive data usually utilize such tools to maintain efficiency and accuracy.
Some large contractors also have access to Governance, Risk, and Compliance tools. However, such tools are technical and require serious investments before you see results.
Regardless of the selected method for self-assessment, the process must meet the set criteria. After the process, firms can request a full CMMC audit by the CMMC accreditation body, which authorizes Certified Third Party Assessor Organizations (C3PAOs) to audit and, if compiled, award contractors with certificates.
4. Develop a System Security Plan
After assessing your policy, it's time to develop a system security plan (SSP). An SSP framework contains policies, objectives, technology investment, staffing workforce, and the implementation process. Creating an SSP is one of the requirements of CMMC since it's needed during the audit process.
Generally, a good SSP for CMMC should be able to address organization processes, documented procedures, available security tools, and other vital aspects regarding cybersecurity enhancement. Depending on how your SSP is well elaborated, the higher chances of getting accredited.
5. Get Your Firm Certified
This is the top achievement in your template implementation. Since the whole process is ultra stringent, getting to this point is one of the critical steps toward working as a contractor or sub-contractor in DoD.
The complexity of certification depends on the CMMC maturity level. This means a contractor looking for level 2 requires different fulfillment requirements from those seeking level 3. For instance, level 2 contractors just require authorization of C3PAOs by CMMC-AB to audit issues such as SSP and others.
For higher levels, such as levels 4 and 5, the certification requires government intervention instead of relying only on third-party assessors. During the assessment, the process involves using different tools, staff interviews, and other means to award certification.
Once the contractor is certified, the certificate lasts for 3 years. Maintaining a high level of integrity and adhering to CMMC rules will ensure that subsequent certifications are easy.
Conclusion
Being a defense contractor is a lucrative venture. But, you must demonstrate the ability to meet and adhere to CMMC policy. Though it's a complex process, this guide makes earning a defense contract easy with simple steps.
