The Cybersecurity Maturity Model Certification (CMMC) 2.0 framework is the Department of Defense's revised approach to ensuring that contractors protecting sensitive government information, specifically Controlled Unclassified Information (CUI) and Federal Contract Information (FCI), have adequate cybersecurity practices in place. This framework streamlines the previous model into three levels, each with increasing security requirements derived primarily from NIST SP 800-171. Level 1 focuses on basic safeguarding of FCI, Level 2 on protecting CUI with NIST SP 800-171 controls and potential third-party assessments, and Level 3 on advanced persistent threat protection with government-led assessments and NIST SP 800-172 requirements.
A key focus of CMMC 2.0, particularly at Level 2, is the protection of CUI, which includes a wide range of sensitive but unclassified information. The 110 controls within NIST SP 800-171, spanning 15 security domains, provide a comprehensive framework for safeguarding CUI through technical and administrative measures. Understanding how CMMC 2.0 aligns with other security standards like DoD Impact Levels and FedRAMP is crucial for contractors, especially when considering cloud service providers.
For contractors handling CUI, the choice of cloud environment is critical for CMMC compliance. Microsoft's Government Community Cloud (GCC) High environment is recommended for organizations aiming for CMMC 2.0 Level 2 and 3 compliance. GCC High offers features like US-based data residency, restricted access to US personnel, and alignment with necessary certifications, providing a compliant infrastructure. However, contractors remain responsible for configuring the environment and implementing all required security controls.
Tech leaders navigating CMMC 2.0 compliance should determine their required level based on their contracts and the information they handle. They then must assess their current security posture, develop a System Security Plan, and carefully consider their cloud environment. Implementing security controls, preparing for assessments, and establishing processes for continuous compliance are essential.
Ultimately, CMMC 2.0 is a strategic imperative for DIB contractors. By proactively addressing its requirements and understanding its relationship with other security standards, especially concerning cloud solutions like Microsoft GCC High, organizations can meet their contractual obligations, significantly enhance their cybersecurity resilience, and solidify their position as trusted partners within the defense industrial base.
For a more detailed blog, check out https://substack.cpf-coaching.com/p/navigating-cmmc-20-a-strategic-imperative
