CMMC for Manufacturers & Machine Shops
First, Are You a COTS Supplier?
Don’t assume CMMC 2.0 requirements apply just because you received one of the many compliance form letters sent out by your prime customers. The DoD created exceptions, and one is for “COTS” products. We’ll help you pursue a COTS exemption and avoid an unnecessary CMMC 2.0 Level 2 or 3 compliance program.
However, if you are not COTS, we provide consulting services to navigate you through the compliance process. Use our requirements flowchart below to determine if NIST 800-171 and CMMC 2.0 apply to you.
COTS, CUI, or FCI Determination Flowchart
CMMC For Manufacturers & Machine Shops Who Handle CUI
$600 billion dollars or about 1% of global gross domestic product each year is lost through cyber theft. Adversaries know that in today’s great power competition environment, information and technology are both key cornerstones and — and attacking a sub-tier supplier is far more appealing than a prime.defense.gov
Because there are fewer controls over CUI as compared to classified information, CUI is the path of least resistance for our geopolitical adversaries. Loss of aggregated CUI is one of the most significant risks to national security, directly affecting the lethality of our warfighters.
Cybersecurity Regulatory Compliance Phase-In
December 31, 2017
The U.S. DoD requires Defense Industrial Base companies to provide “reasonable security” for Covered Defense Information, including CUI via DFARS 252.204-7012. Many small-medium size companies are slow to implement due to a lack of resources and technical expertise.
November 30, 2020
Compliance enforcement strengthens through interim rules (DFARS 252.204 -7019 & -7020) requirements to submit NIST 800-171 self-assessment results into the DoD’s Supplier Performance Risk System (SPRS). The SPRS enables DoD contract officials to consider a company’s self-assessment score (or failure to report it) in their contract award process.
Prime contractors seek confirmation from their subs about their compliance progress and status of their SPRS submission due to compliance flow down requirements.
DFARS 252.204-7021 ushers in CMMC (Cybersecurity Maturity Model Certification) that requires independent certification by an authorized C3PAO company.
November 04, 2021
The DoD releases CMMC 2.0 with the stated intention to simplify the CMMC standard while still safeguarding sensitive information. The previous 5 CMMC maturity levels are reduced to 3 and the number of controls is reduced to align with NIST 800-171.
Call for a Complimentary No-Cost Consultation: 617.314.9721 x158
Determine if you handle CUI
If your products are not COTS, we look to your DoD contracts to determine if you handle Controlled Unclassified Information (CUI). If you don’t handle CUI, your DoD contract information is Federal Contract Information (FCI). You’ll only need CMMC Level 1.
Ok, you handle CUI
Your goal is to differentiate CUI from all other information you handle, segregate it into a dedicated and secure environment, and minimize its footprint. We ascertain the nature and category of your CUI through a review of the DoD’s CUI Registry. And we scope CUI within your business organization using our proprietary Data Lifecycle approach to reduce compliance effort and cost.
We offer a CUI Scoping service to begin your CMMC 2.0 compliance program.
Your progression from NIST 800-171 to CMMC
DFARS 252.204-7012, -7019, and -7020 require you to perform a NIST 800-171 self-assessment, submit summary-level score with POAM information to the DoD’s SPRS web portal, and remediate POAM deficiencies in pursuit of DFARS 252.204-7021 CMMC 2.0 Level 2 compliance.
Have you made your SPRS submission?
If you haven’t made your SPRS submission, we offer an affordable consulting package with a 30-day turnaround time.
Have a low SPRS score? You’re not alone. Let us help you remediate NIST 800-171 POAM deficiencies and develop a CMMC 2.0 Level 2 compliance program just for you.
Want to confirm you’re ready for CMMC 2.0 assessment by a C3PAO? KLC Consulting evaluates readiness by simulating an independent C3PAO assessment.
CMMC for Manufacturers & Machine Shops: Challenges We Solve
- Lack of compliance knowledge
- Inability to remediate POAM deficiencies
- CUI exists in both electronic and physical forms
- Legacy MRP/ERP (Manufacturing Enterprise Resource Planning) systems complicate compliance
- Security of computers, network, file storage, and engineering software that generate code for CNC machines
- Separating manufacturing floor computer systems from the corporate (office) networks
- CUI proliferates across more departments and systems than is needed to perform DoD contract work
- Your design/engineering software processes CUI
- Your Operational Technology (OT) hardware and software may not be acceptable for CMMC Level 2
- Coordinating compliance activities with your MSP/MSSP
- CUI marking and labeling
- Uncertainty about flow down compliance requirements to subcontractors
- Uncertainty responding to compliance-related questions from:
- DoD agencies
- Prime contractors
- Cybersecurity insurers
- Incident response planning and reporting (DFARS 252.204-7012)
- Incident response plan testing (tabletop exercise)
- Penetration testing/vulnerability testing
Sail Through CMMC Compliance With
Our 7-Step Navigator