Introduction
In today’s rapidly evolving cybersecurity landscape, Department of Defense (DoD) contractors face increasing pressure to demonstrate robust compliance. Navigating the complexities of CMMC Level 2 Certification Assessment can feel overwhelming, but understanding the key dates, regulatory frameworks, and assessment processes is crucial for your organization’s success. This post distills essential insights from KLC Consulting’s November 2024 “Ask the Experts” webinar, providing actionable guidance to help you confidently approach your CMMC compliance journey and ensure your readiness for the future.
Understanding the 32 CFR and 48 CFR Rules
Why are there two sets of rules? It’s a question we hear frequently. The 32 CFR Part 170 outlines the CMMC program rules, detailing the ecosystem for organizations seeking certification. The 48 CFR Part 204, or the acquisition rule, is designed for DoD contracting officers, specifying contract language. The 32 CFR takes effect December 16, 2024, enabling CMMC Level 2 certification assessments to commence. The 48 CFR’s effective date is expected shortly thereafter, potentially impacting contracts by late 2024 or early 2025.
When is a Third-Party CMMC Assessment Required?
While self-assessment might seem appealing, it’s rarely an option for contracts involving Controlled Unclassified Information (CUI). The contracting officer dictates the assessment type. Most DoD contracts handling CUI will mandate a CMMC Level 2 certification assessment by a C3PAO. Subcontractors must align with their prime contractor’s assessment approach.
Breaking Down the CMMC Level 2 Assessment Journey
The CMMC Level 2 assessment process follows the CMMC Assessment Process (CAP) document. From pre-assessment to final certification, expect approximately three months, assuming no POA&M deficiencies. The pre-assessment begins seven weeks before the formal assessment, with interviews and documentation spanning four weeks. Reporting and DoD review also take roughly four weeks.
What Happens If You Don’t Meet the Minimum CMMC Certification Score?
A minimum score of 88 is required for conditional certification. Failing to achieve this necessitates restarting the entire assessment. Aim for a score above 110 to avoid this. If you score 88 or above, you have 180 days to remediate any deficiencies outlined in your Plan of Action and Milestones (POA&M). Beyond POA&M, understand operational POA&Ms, due to vulnerabilities found during operations, and temporary deficiencies, which address situations like delayed FIPS validation. There are also ‘exceptions’ which cover situations where an older system can not be updated.
Subcontractor Requirements and IT Service Providers
Prime contractors must verify that subcontractors handling CUI also possess current CMMC certifications. This flow-down requirement is critical for maintaining supply chain security. You can continue using your IT service provider, but their scope must be defined within your assessment. Create a shared responsibility matrix, delineating roles and responsibilities. If your IT service provider handles CUI, they must be included in your System Security Plan (SSP).
Addressing Common Concerns: Costs, Scheduling, and CUI Handling:
How Much Does CMMC Level 2 Certification Cost?
Costs vary based on organizational size and scope. KLC Consulting offers a convenient online tool for instant quotes.
When Can I Schedule My Assessment?
CMMC Level 2 certification assessments can be scheduled from December 16, 2024. Plan ahead, as C3PAO schedules are filling rapidly.
How Do I Handle CUI and Data Security?
Proper CUI training and marking are essential. If you’re unsure whether data is CUI, seek clarification from your contracting officer. For cloud-based backups, FedRAMP moderate compliance is necessary unless you own the encryption keys.
Streamlining Certification and Cage Codes for Multiple Locations
Achieving one certification for multiple cage codes requires a proper hierarchy setup. Ensure all entities report to the same highest-level owner. Separate certifications might be needed for independently managed networks.
Ready to Begin Your CMMC Level 2 Certification Assessment?
Navigating CMMC Level 2 compliance requirements can be complex, but with expert guidance, you can streamline the process. KLC Consulting, Inc., is committed to providing comprehensive CMMC Level 2 certification assessment services. Download our free CMMC Level 2 Readiness Checklist to prepare for your assessment. Contact us to schedule your assessment and ensure your organization is prepared for the evolving cybersecurity landscape.
