How to Navigate the CMMC Landscape: Defense Contractor Cybersecurity Excellence

Introduction to CMMC: Overview and Importance in the Defense Industry

For most companies, cybersecurity is an intentional best practice. In the defense industry, it's much more.

The Cybersecurity Maturity Model Certification (CMMC) is becoming the gold standard for protecting sensitive, confidential information in the defense industry. Defense contractors are experiencing more cyberattacks. Understanding and achieving CMMC compliance is a top priority for the Department of Defense (DoD). Because when it comes to national security, the stakes are high.

Like the Defense Federal Acquisition Regulation Supplement (DFARS), which oversees material compliance and supply chain management for defense-related fabrications, the CMMC enforces strict requirements for defense contracts. [Link to FVMT's DFARS blog post: An Overview of DFARS Material Compliance for Metal Fabricators]. CMMC builds upon the foundation of DFARS compliance by requiring additional security practices and third-party assessments for higher levels of certification.

At Fox Valley Metal Tech (FVMT), we understand what it takes to be in compliance. Defense contractors and subcontractors with DFARS experience know the importance of following government regulations and safeguarding sensitive information.

What is CMMC?

The Cybersecurity Maturity Model Certification (CMMC) is a program developed by the Department of Defense (DoD) to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the Defense Industrial Base (DIB). CMMC was created to ensure that defense contractors and subcontractors are compliant with information protection requirements and protect sensitive unclassified information shared by the DoD in line with the risks posed by cybersecurity threats.

Structure and Requirements of CMMC:

Three-Tiered CMMC Model | Companies handling sensitive unclassified DoD information must implement cybersecurity standards at progressively advanced levels, depending on the type and sensitivity of the information. The CMMC Model has three levels: Level 1 is the least advanced with 15 requirements, Level 2 has 110, and Level 3 is the most advanced with 134 requirements.

Assessment Requirements | CMMC assessments verify the implementation of cybersecurity standards, each incorporating requirements from regulations and guidelines:

• Level 1: Basic safeguarding of Federal Contract Information (FCI) with annual self-assessment.
• Level 2: General protection of Controlled Unclassified Information (CUI) with either a CMMC Third-Party Assessor Organization (C3PAO) or self-assessment.
• Level 3: Enhanced protection against advanced persistent threats for some CUI, requiring a Defense Industrial Base Cybersecurity Assessment Center (DIBCAC)-led assessment.

Implementation through Contracts | The update to DFARS includes CMMC requirements. Defense contractors and subcontractors must achieve a specific CMMC level to participate in DoD contracts. 

CMMC Timeline: When Will It Appear in Government Contracts?

CMMC is getting closer to full implementation, and recent guidance from the DoD provides further clarity on the path forward. 

Anticipated Implementation Timeline:

Late last year, the Title 32 Rule which implements and authorizes CMMC as a program was published. Currently, the Title 48 Rule which addresses how CMMC will be implemented in contracts is in its last phase of the regulatory process. This indicates that CMMC is moving through the regulatory process and closer to being a contractual requirement.

CMMC Assessments Starting in Early to Mid-2025 | The Department of Defense (DoD) plans to begin formal assessments for CMMC compliance in the first quarter of 2025. Contractors and subcontractors must proactively prepare for these changes to ensure seamless compliance and maintain their eligibility for future contracts.

Phased Rollout in Contracts Beginning Q3 2025 | CMMC requirements are projected to start appearing in DoD contract solicitations and awards beginning in Q3 2025. The rollout will be gradual, with full implementation expected by 2027.

How Defense Contractors are Preparing for CMMC

CMMC affects all tiers of defense suppliers, from prime contractors to subcontractors. Prime contractors are responsible for ensuring that their subcontractors also meet the required CMMC level. Flow-down requirements mean that preparation across the supply chain is critical to avoid a ripple effect.

Currently, the emphasis is on achieving full implementation of NIST 800-171 r2 requirements. This means companies should:

• Have a System Security Plan (SSP) in place.
• Conduct the DoD self-assessment.
• Upload their score to the Supplier Performance Risk System (SPRS).

While there is no minimum required SPRS score yet, the DoD expects companies to continue to clear their Plan Of Actions (POA) as cybersecurity threats continue to grow in sophistication.

How Contractors and Subcontractors Are Preparing for CMMC Compliance

Develop a Plan: Create a detailed plan to address gaps and implement necessary controls.

Understanding Requirements and Reviewing Contracts | For many companies, the first part of preparing for CMMC includes:

• Familiarizing themselves with the CMMC framework
• Determining the required certification level based on the type of information they handle
• Identifying which contracts require CMMC compliance

Implementing Controls | Based on assessment results, companies are implementing the necessary cybersecurity controls to meet the required CMMC level.

Engage Experts: Consider working with cybersecurity consultants or CMMC Third-Party Assessor Organizations (C3PAOs) to guide the preparation process.

Conducting Readiness Assessments and Gap Analysis | Many organizations are performing self-assessments or hiring third-party consultants to identify gaps in their current cybersecurity practices and assess them against CMMC requirements.

Engaging with C3PAOs | Contractors are working with CMMC Third-Party Assessor Organizations (C3PAOs) to schedule formal assessments and achieve certification.

Stay Informed: Keep up-to-date with the latest CMMC developments and timelines to achieve and maintain compliance.

Training and Awareness | Organizations are investing in training programs to ensure employees understand and follow cybersecurity best practices.

CMMC Compliance as a Competitive Advantage

Developing a Plan of Action and Milestones (POA&M) helps priorities and identify weaknesses. By partnering with experienced metal fabricators like FVMT, defense contractors ensure they can meet and maintain CMMC compliance. Early adopters gain a competitive advantage, demonstrating their commitment to cybersecurity and reliability for building trust in the supply chain.

FVMT's Solid Foundation in Cybersecurity

From DFARS to CMMC: Building on a Strong Foundation

DFARS compliance has laid a strong foundation for CMMC certification by ensuring adherence to cybersecurity standards like NIST SP 800-171. This framework addresses the protection of Controlled Unclassified Information (CUI), which is a critical component of both DFARS and CMMC requirements. By implementing these controls, organizations are already aligned with many of the practices required for CMMC certification.

To meet additional CMMC requirements, companies often take steps such as:

• Conducting a gap analysis to identify areas where current practices fall short of CMMC standards.
• Developing a System Security Plan (SSP) and a Plan of Action and Milestones (POA&M) to address deficiencies.
• Engaging in self-assessments or third-party assessments, depending on the required CMMC level.
• Training employees on cybersecurity best practices to ensure compliance at all organizational levels.

These efforts not only prepare organizations for certification but also enhance their overall cybersecurity posture.

Operational Advantages of CMMC Implementation

CMMC compliance has significantly improved cybersecurity practices and operational efficiency for many organizations. Here are some specific examples:

• Enhanced Data Protection | Companies handling Controlled Unclassified Information (CUI) have implemented stricter access controls, encryption, and monitoring systems. This reduces the risk of data breaches and
  ensures sensitive information is safeguarded.
• Improved Incident Response | By adhering to CMMC requirements, organizations have developed robust incident response plans. This enables them to detect, respond to, and recover from cyberattacks more effectively, minimizing downtime and operational disruptions.
• Streamlined Processes | The compliance process often involves automating repetitive tasks, such as patch management and vulnerability scanning. This not only improves security but also frees up resources for other critical activities.
• Employee Training | CMMC mandates regular cybersecurity training for employees, fostering a culture of awareness and accountability. This reduces human error, a common cause of security incidents.
• Vendor Risk Management | Organizations have strengthened their supply chain security by ensuring that vendors and subcontractors also meet CMMC standards. This reduces the risk of third-party vulnerabilities.

These improvements not only enhance cybersecurity but also build trust with clients and partners, demonstrating a commitment to protecting sensitive information.

The Naval Vessel Connection: Why CMMC Matters

Companies specializing in naval vessel component fabrication align well with CMMC requirements due to their existing focus on safeguarding sensitive technical data, such as hull designs, propulsion systems, and classified technologies. This expertise naturally complements CMMC's emphasis on protecting Controlled Unclassified Information (CUI).

Alignment with CMMC Requirements:

• Data Protection | Fabrication processes often involve handling sensitive information, which aligns with CMMC's stringent data security practices, such as encryption and access controls.
• Supply Chain Security | Naval fabrication companies typically work with complex supply chains, making them adept at implementing CMMC's requirements for vendor risk management.
• Operational Security | The industry's focus on secure facilities and controlled environments supports CMMC's physical and cybersecurity mandates.

Unique Challenges:

• Long Project Lifecycles | Naval projects can span decades, requiring sustained compliance and continuous monitoring to protect data over time.
• Complex Supply Chains | Managing cybersecurity across a vast network of subcontractors and suppliers poses significant challenges.
• Advanced Technologies | The use of cutting-edge technologies, such as sonar systems or classified propulsion designs, demands heightened security measures to prevent breaches.
  

Unique Experiences:

• Cross-Disciplinary Expertise | Companies often integrate mechanical, electrical, and software engineering, providing a holistic approach to meeting CMMC standards.
• National Security Impact | Their work directly supports national defense, adding a layer of responsibility and urgency to achieving compliance.

FVMT's Approach to CMMC Compliance

FVMT is committed to meeting and exceeding CMMC requirements through ongoing efforts to enhance our cybersecurity posture. Our collaborative approach involves working closely with IT experts and industry partners to stay ahead of evolving threats. We are investing in continuous training, advanced security measures, and intensive monitoring to ensure the highest level of protection for our clients' sensitive information.

Securing Success: The Competitive Benefits of CMMC Readiness

Early adoption of CMMC compliance measures offers several competitive advantages for companies, particularly those in the defense industrial base (DIB). Here are some key benefits:

• Preferred Partner Status | Early adopters demonstrate a proactive commitment to cybersecurity, making them more attractive to prime contractors and government agencies seeking reliable partners.
• Market Differentiation | Achieving CMMC compliance ahead of competitors positions companies as leaders in cybersecurity, setting them apart in a crowded marketplace.
• Reduced Risk | Early compliance helps identify and address vulnerabilities, minimizing the risk of data breaches and ensuring smoother operations.
• Access to Contracts | With CMMC becoming a requirement for many Department of Defense (DoD) contracts, early adopters are better positioned to secure lucrative opportunities.
• Enhanced Reputation | Companies that prioritize cybersecurity build trust with clients, partners, and stakeholders, strengthening their overall image.
• Operational Efficiency | The process of achieving compliance often involves streamlining cybersecurity practices, which can lead to improved efficiency and cost savings.

These advantages not only enhance a company's competitive edge but also contribute to long-term success in the defense sector.

Navigating the CMMC Journey: Lessons from the Field

Based FVMT's and other companies' experiences navigating CMMC compliance, here’s some advice for other defense contractors beginning their journey:

• Start with a Gap Analysis | Conduct a thorough review of your current cybersecurity practices against CMMC requirements. Identify gaps early and prioritize remediation efforts.
• Develop a Detailed Plan | Create a System Security Plan (SSP) and a Plan of Action and Milestones (POA&M). These documents outline your current practices, highlight deficiencies, and provide a roadmap for
  achieving compliance.
• Focus on High-Impact Areas | Prioritize requirements related to Controlled Unclassified Information (CUI) protection and access controls, as these are central to compliance and the most scrutinized.
• Engage Leadership and Employees | Ensure buy-in from senior leadership and involve employees across all departments. Regular training programs are essential to build a culture of cybersecurity awareness.
• Partner with Experts | Consider hiring consultants or cybersecurity firms with experience in CMMC compliance. Their insights can save time and help you avoid costly mistakes.
• Invest in Continuous Monitoring | Compliance is not a one-time task. Establish systems to monitor your network, regularly update software, and address vulnerabilities promptly.
• Address Supply Chain Risks | Work with vendors and subcontractors to ensure they also meet CMMC standards. Your compliance depends on the security of your entire supply chain.
• Start Early | Achieving compliance takes time and effort. Starting sooner rather than later helps avoid last-minute scrambling and potential penalties.

The Wisconsin Procurement Institute (WPI) Resource

The Wisconsin Procurement Institute (WPI) is a valuable resource for defense contractors seeking to navigate the CMMC landscape. WPI provides training, consulting, and resources to help contractors understand and implement cybersecurity best practices. Contractors can leverage WPI's expertise to prepare for CMMC assessments and ensure they meet the required standards.

The Bottom Line

The cybersecurity journey and CMMC compliance are ongoing. Defense contractors must be proactive and stay vigilant. Embracing CMMC compliance requires dedication, expertise, and a forward-thinking approach. FVMT is committed to leading the way while supporting our partners in achieving and maintaining cybersecurity excellence. By prioritizing CMMC compliance, we're not just meeting requirements – we're safeguarding our defense capabilities for years to come.

You can trust FVMT as a partner in the success and security of major defense projects, including CMMC compliance. Download our helpful RFQ checklist to ensure you cover all the details, or contact our team of experts today to discuss your next project and CMMC compliance needs.