The CMMC Final Rule is Here: What It Means for the DIB

Hello Cyber Explorers!

The Department of Defense (DoD) has officially published the final rule for the Cybersecurity Maturity Model Certification (CMMC) Program—32 CFR Part 170. With this, the government has put a significant milestone in place to verify that contractors are implementing the necessary cybersecurity measures to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).

But here’s the real question: can we continue to navigate the complexity of compliance in isolation, or is there a more strategic, collective approach that we haven't fully explored yet? What if we could tackle CMMC compliance through alliances that not only reduce costs but strengthen the entire defense supply chain?

In this article, we will explore how building strategic alliances for CMMC compliance could be a game-changer, offering a collaborative solution to the financial and operational challenges faced by the Defense Industrial Base (DIB). This isn't about managing compliance alone; it's about leveraging shared resources, collective intelligence, and strategic partnerships to bolster national security while keeping costs manageable.

The Link Between 48 CFR Part 204 and 32 CFR Part 170

The CMMC final rule, outlined in 32 CFR Part 170, ties directly into existing regulations like 48 CFR Part 204, which deals with administrative matters in defense contracting, including safeguarding Covered Defense Information (CDI). Specifically, 48 CFR Part 204 includes requirements for contractors to implement adequate security measures to protect CDI and to report cyber incidents to the DoD.

These regulations work together to create a comprehensive framework for cybersecurity within the DIB. While 48 CFR Part 204 has long required contractors to adopt safeguards to protect sensitive information, 32 CFR Part 170 takes it a step further by mandating formal certification of those cybersecurity practices. Essentially, 48 CFR Part 204 sets the foundational security requirements, while 32 CFR Part 170 ensures that these requirements are being rigorously implemented and validated through the CMMC program.

For contractors, understanding the connection between these two regulations is crucial. 48 CFR Part 204 establishes what needs to be protected and provides general guidance, whereas 32 CFR Part 170 requires demonstrable proof of compliance through certification. Together, these regulations reinforce the idea that cybersecurity is not just a contractual obligation but a core element of eligibility for defense contracts. Compliance with both parts is now a critical pathway for maintaining business relationships with the DoD.

The Objective Overview

The CMMC program started as a response to evolving cybersecurity threats faced by the DIB. It moves away from the "self-attestation" model of security, where companies simply stated they were meeting cybersecurity standards, towards a more rigorous verification approach. The final rule outlines specific requirements for defense contractors based on the level and sensitivity of the information being processed.

The final rule presents a tiered system, comprised of three levels, each demanding progressively higher standards. Level 1 is based on self-assessment, while Level 2 requires third-party certification, and Level 3 adds further government validation. Essentially, if you are in the DIB and handling CUI, you're now expected to take these standards seriously enough to prove it, and not just say it.

From a governance perspective, the rule introduces more accountability and transparency throughout the supply chain. For some, it's a layer of additional bureaucracy, but for others, it's about protecting the sensitive data we rely on to keep national defense resilient. The phased implementation plan gives companies time to prepare, but the message is clear: compliance is no longer optional, and the DoD has every intention to enforce it.

Strategic Alliances: A Fresh Perspective on CMMC Compliance

One of the biggest challenges posed by the CMMC final rule is the cost burden, particularly for small to medium-sized businesses (SMBs). According to the National Defense Industrial Association (NDIA) , many SMBs within the DIB are struggling to absorb the financial impact of compliance, which includes investments in technology, third-party assessments, and workforce training. The NDIA has called for more specific guidance and support to help ease this burden, particularly for subcontractors, who are often left behind due to resource constraints.

However, instead of tackling these challenges alone, there's an opportunity to take a different approach—strategic alliances. What if compliance wasn't just an individual company effort but a collaborative, collective undertaking? Here's how building alliances could transform the CMMC compliance landscape:

Shared Compliance Resources Among SMBs

A practical solution for mitigating costs is to develop resource-sharing alliances among SMBs. In such an alliance, companies could pool together to secure third-party assessment organizations (C3PAOs), share cybersecurity expertise, and even distribute the financial burden of achieving and maintaining compliance.

For example, SolCyber and Carahsoft Forge Alliance to Expedite CMMC Compliance recently launched a CMMC Readiness Program aimed at streamlining the compliance process for SMBs through a managed services model. This approach suggests that by partnering and creating managed compliance solutions, the operational burden can be significantly reduced. Expanding this idea into a more community-driven model—where SMBs work collectively—could take it even further, making compliance accessible to companies that might otherwise be excluded.

Creating a Subcontractor Compliance Hub

For prime contractors, ensuring subcontractor compliance is a significant challenge. The rule makes it clear that compliance requirements flow down the supply chain, meaning the responsibility for verifying compliance doesn't end with the prime contractor. A novel approach would be for primes to develop a centralized compliance hub for their subcontractors.

Such a hub could provide standardized training, shared tools, and direct guidance to simplify subcontractor compliance, reducing redundancy and building stronger supplier relationships. This model has the potential to not only ease compliance burdens but also to improve overall supply chain resilience. It creates a shared responsibility model that benefits the entire defense ecosystem by raising the bar collectively.

Regional Compliance Support Networks

Another idea to consider is the establishment of regional compliance support centers. These centers could be government-backed initiatives where SMBs can access subsidized CMMC support, including assessment services, training, and implementation tools. By leveraging such a model, regional support networks could help ensure supplier diversity is maintained while promoting higher cybersecurity standards across the board.

Engaging Industry Associations for Collective Advocacy

Industry associations such as the NDIA have an important role to play in advocating for collective funding mechanisms. The NDIA, for instance, has highlighted the challenges smaller contractors face in complying with evolving CMMC requirements and has emphasized the need for financial support programs that go beyond individual grants【97?source】. By encouraging collective funding pools aimed at helping SMBs achieve compliance, industry associations can help maintain a diverse and competitive DIB.

Key Takeaways for the DIB

1. Accountability Through Collaboration: Moving from self-attestation to certified verification means more than just checking a box. By collaborating, contractors—particularly SMBs—can share resources and reduce the overall cost and complexity of meeting CMMC requirements.
2. Three Levels of Compliance: The CMMC is structured in three levels:
3. Phased Implementation Timeline: Collaboration can make the phased implementation more manageable. By forming strategic alliances, companies can align their timelines, share progress, and support each other throughout the journey.
4. Flow-Down Requirements Made Simpler: By leveraging subcontractor compliance hubs or regional centers, primes can more effectively ensure that subcontractors are meeting their requirements without overwhelming each link in the chain.

How to Get Ahead of This Rule

1. Form Alliances Now: Identify companies within your region or sector that are facing similar challenges and explore opportunities for collaboration. This could include cost-sharing for compliance tools or group engagements with assessment organizations.
2. Engage Industry Support Networks: Make use of existing industry associations, such as NDIA, to gain access to collective resources and advocate for shared compliance initiatives.
3. Develop a Supply Chain Compliance Plan: Whether you are a prime or a subcontractor, proactive engagement with your partners is crucial. Work towards a collective plan that addresses the compliance requirements for all entities involved.

What It Means Moving Forward

The final CMMC rule represents more than just a compliance hurdle; it's an opportunity to rethink how we, as an industry, approach cybersecurity. The challenges of cost, subcontractor compliance, and supply chain security are real, but they also present an opportunity to leverage community-based solutions that elevate the entire ecosystem. By removing the option for self-attestation and instituting mandatory verification, the DoD has set a new bar, but how we meet that bar—whether individually or collaboratively—will define our industry's future resilience.

For the DIB, the rule reveals a challenging question: how do we balance compliance costs while ensuring security? The answer may lie in strategic alliances—by pooling our strengths, sharing our resources, and working together to raise our collective security posture. Let's make sure we're ready to walk this talk, Cyber Explorers. The future of our defense contracts, and our national security, depends on it.