CMMC Takes Effect Today : What You Need to Know to Prepare

While the CMMC Program Rule (32 CFR Part 170) is now published, the requirement for full compliance with Cybersecurity Maturity Model Certification (CMMC) is not yet in effect for DoD contractors and subcontractors. However, preparation is key, as enforcement will soon become a reality for organizations handling Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).

What’s Happening Now?

The DoD has published the final rule, but phased implementation of CMMC will begin over the next few years. Organizations that process, store, or transmit CUI and FCI should take steps now to ensure they’re ready when CMMC becomes a contractual requirement.

5 Key Steps to Achieve Compliance

1. Understand Your Scope:

• Determine if your systems handle FCI (Level 1) or CUI (Level 2 or 3) and ensure your System Security Plan (SSP) covers all in-scope components, personnel, and service providers.
• Use the published Scoping Guidance to ensure completeness.

2. Align with CMMC Levels:

• Level 1: Basic safeguarding of FCI via annual self-assessment.
• Level 2: Enhanced protection of CUI, requiring third-party certification for most contractors.
• Level 3: Government-led assessments for high-priority contracts involving critical CUI.

3. Conduct a Gap Analysis:

• Assess your cybersecurity posture against NIST SP 800-171 and identify areas requiring improvement.

4. Engage Prime Contractors:

• Contractors should re-establish connections with DoD Contracting Officers and Program Office personnel.
• Subcontractors should collaborate with their prime contractors to clarify requirements and ensure compliance plans align with DoD expectations.

5. Stay Ahead:

• Update your accounts in Supplier Performance Risk System (SPRS) and Enterprise Mission Assurance Support Service (eMASS) platforms and begin preparations for self-assessments or third-party certifications.

What Should You Do Now?

Navigating the complexities of CMMC can be overwhelming, but you don’t have to do it alone. At Asante Cloud, our team of CMMC Registered Practitioners specializes in helping organizations like yours achieve compliance.

• Contract Analysis: We’ll assess whether you’re required to meet CMMC and, if so, determine the appropriate level (Level 1 or Level 2).
• Gap Assessments: We’ll identify any gaps in your cybersecurity practices and provide a clear roadmap to compliance.
• Expert Guidance: Our practitioners ensure you’re fully prepared for audits and ongoing compliance requirements.

Click here to connect with a CMMC Practitioner or reach out directly to schedule your free contract analysis.