The Cybersecurity Maturity Model Certification (CMMC) has become a pivotal framework within the Defense Industrial Base (DIB). With the proposed CMMC rule being published in the Federal Register on December 26, 2023, a major step has been taken towards CMMC certification being a requirement for defense industry contractors to win bids for Department of Defense (DoD) contracts. It is estimated that this could happen in early 2025.
With this guidance, managed service providers (MSPs), including their security-focused counterparts managed security service providers (MSSPs), are now at a crucial juncture. This article aims to demystify the CMMC proposed rule, explore its impact on MSPs, and illustrate how CMMC Registered Practitioners can facilitate your journey to compliance.
What is the new CMMC guidance for MSPs?
The DoD has outlined clear directives in the new proposed rule, emphasizing the inclusion of MSPs within the assessment scope. The rule categorizes External Service Providers (ESPs), including MSPs, as pivotal in maintaining the cybersecurity resilience of defense contractors.
Under the proposed rule, if an MSP has defense contractor clients subject to CMMC assessments, the MSP must also undergo an assessment at the same CMMC Level as their client. If the MSP fails to become CMMC compliant, the client is considered non-compliant as well.
How does the CMMC proposed rule impact MSPs?
To achieve CMMC compliance, you will need to align your cybersecurity practices with the NIST SP 800-171 framework, consisting of 110 cybersecurity practices. This alignment is crucial, whether your clients process Federal Contract Information (FCI) or Controlled Unclassified Information (CUI), with the level of compliance varying based on the sensitivity of the information handled.
You should strategically start to work towards CMMC Level 2 compliance, which will require you to undergo an assessment by a CMMC Third Party Assessor Organization (C3PAO). The DoD estimates that only around 1% of their contractors will require a level 3 certification, so focusing on the CMMC level 2 compliance is the best starting point.
The implications of the CMMC proposed rule for MSPs are profound. Compliance is no longer optional, but a prerequisite for engaging with defense contractors. The DoD estimates that there are over 220,000 contractors that will require some level of CMMC compliance, so the chances that an MSP will have some customers that serve as DoD contractors is high.
For MSPs, this means adopting government-approved communication and data storage tools, ensuring vendor compliance, and maintaining up-to-date documentation of compliance efforts. The cost implications are significant with estimates suggesting substantial investments required to prepare for and maintain compliance, especially for those new to the defense sector.
What are the core benefits for an MSP to become CMMC certified?
Obtaining CMMC certification not only enhances your cybersecurity posture, but also positions you as a more attractive partner for defense contractors. As the DoD continues to roll out CMMC across its contractors, the value of compliance for MSPs is expected to grow.
Here are some key benefits of CMMC compliance for MSPs:
- Access to Defense Contracts: One of the primary benefits of CMMC compliance is eligibility to work on contracts issued by the DoD. The CMMC framework is a requirement for all DoD contractors and their subcontractors, including MSPs that handle FCI or CUI.
- Competitive Advantage: By achieving CMMC compliance, you distinguish yourself from competitors who have not met these cybersecurity standards. This early compliance can be leveraged in marketing and sales efforts to attract new business.
- Enhanced Cybersecurity Posture: The process of becoming CMMC compliant requires MSPs to implement and adhere to stringent cybersecurity practices and procedures. This not only meets the compliance requirements, but also significantly strengthens your overall cybersecurity posture, reducing the risk of cyber threats and data breaches.
- Trust and Credibility with Clients: CMMC compliance signals to clients that you take cybersecurity seriously.
- Alignment with Other Standards: The practices and processes required for CMMC compliance often align with other cybersecurity standards and frameworks, such as NIST SP 800-171, ISO 27001, and GDPR. Compliance with CMMC can thus facilitate or streamline compliance with these other standards.
Where should an MSP start when planning to become CMMC compliant?
The journey to CMMC compliance is intricate, costly, and requires a deep understanding of the requirements. It is recommended that you partner with a CMMC Registered Practitioner to guide you through the process of preparing for your CMMC assessment. A CMMC Registered Practitioner is an individual who has been officially recognized by the CMMC Accreditation Body (CMMC-AB) as being qualified to provide advice, consulting, and recommendations to organizations seeking CMMC compliance. It is the job of a Registered Practitioner to prepare a company to complete a CMMC compliance assessment.
Primary services offered by a CMMC Registered Practitioner include:
- Gap Analysis: Identifying discrepancies between your current cybersecurity practices and CMMC requirements.
- Compliance Roadmap Development: Crafting a step-by-step plan tailored to your specific needs, ensuring a clear path to compliance.
- Pre-Assessment Preparation: Ensuring you are fully prepared for the third-party assessment, increasing the likelihood of certification.
- Continuous Compliance Monitoring: Providing ongoing support to ensure your practices remain in alignment with CMMC requirements, adapting to any changes in the framework.
If you're interested in CMMC compliance, our team can help. IGI Cybersecurity has the experience and RPAs (Registered Practitioner Advanced) to assist you in your journey. Contact us today at IGIcybersecurity.com/contact to learn more about how our team can help you prepare for CMMC certification and secure your place within the defense sector.
