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CMMC
What to Do After You Complete the Self-Assessment in the CMMC Assessors Guide Copy
Written by
Emre Koksal
Published On
Oct 21, 2024



Working as a contractor for the Department of Defense (DoD) can be a rewarding and lucrative path. However, in order to reap these rewards, you will have to first comply with the Cybersecurity Model Maturity Certification (CMMC) framework, which is overseen by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD-A&S). Achieving CMMC 2.0 compliance is no easy feat. It requires strict adherence to several layers of requirements, all of which are analyzed by an official CMMC assessment performed by an accredited CMMC Third Party Assessment Organization (C3PAO).
In this guide to CMMC compliance, we’ll walk you through the highlights of CMMC and the many traps contractors can fall into during the assessment process.
What Does It Mean to Be CMMC 2.0 Compliant?
Intellectual property and sensitive data theft are national security issues that cost the U.S. economy billions of dollars every year. Many of these attacks happen throughout the Defense Industrial Base (DIB) supplier base. In response, the DoD has established numerous security measures and frameworks over the years. The Cybersecurity Maturity Model Certification (CMMC) is a key framework designed to enhance the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the DIB.
Key Data Types Protected under CMMC 2.0
Federal Contract Information (FCI): Information not intended for public release, generated by or for the government under contract.
Controlled Unclassified Information (CUI): Information that must be protected from unauthorized disclosure according to laws and regulations, such as International Traffic in Arms Regulations (ITAR) data.
Benefits of CMMC 2.0 Compliance
CMMC compliance helps ensure the robust protection of CUI through compliance requirements across various domains. Being CMMC compliant makes an organization a preferred contractor for the DoD and other government branches. Additional benefits include eligibility for Safe Harbor provisions, which protect certified entities from certain penalties and audits. Companies are encouraged to conduct a self-assessment to understand their readiness for certification, evaluating policies and practices against the framework's levels and domains.
Understanding the CMMC 2.0 Framework
CMMC 2.0 simplifies the original CMMC structure, focusing on streamlining the certification process and reducing the burden on DIB companies. The updated model categorizes requirements into fewer levels:
Level 1: Basic safeguarding of FCI.
Level 2: Aligns with NIST SP 800-171 to protect CUI, serving as the necessary certification level for most contractors.
Level 3: Designed for companies handling highly sensitive defense projects, requiring advanced cybersecurity measures.
Each level provides a scalable approach to cybersecurity, ensuring contractors meet specific security requirements based on the sensitivity of the information they handle. Data security related to CUI is critical to address at all levels.
Next Steps in Achieving CMMC 2.0 Compliance
While self-assessment is a valuable starting point, it does not guarantee compliance. A deeper understanding of the CMMC 2.0 framework, its requirements, and the certification process is crucial. Contractors should aim to integrate cybersecurity practices as specified for their required CMMC level, preparing for assessments and potential audits to maintain compliance. CMMC 2.0 represents a critical step towards securing the DIB against evolving threats and ensuring the integrity and security of defense information.
Domains of CMMC 2.0
CMMC 2.0 consists of 17 domains, each representing a distinct set of security practices to safeguard FCI and CUI. These domains are derived from Federal Information Processing Standards (FIPS) 200 and NIST SP 800-171, with three additional domains: Asset Management, Recovery, and Situational Awareness. The domains include:
Access Control (AC): Restrictions on data access.
Asset Management (AM): Identification and management of assets.
Audit and Accountability (AU): Ensuring traceability of activities.
Awareness and Training (AT): Providing cybersecurity awareness.
Configuration Management (CM): Maintaining system standards.
Identification and Authentication (IA): Managing roles and access rights.
Incident Response (IR): Reporting and managing incidents.
Maintenance (MA): Regular system maintenance.
Media Protection (MP): Safeguarding digital and print media.
Personnel Security (PS): Security protocols for personnel changes.
Physical Protection (PE): Restricting physical access.
Recovery (RE): Systematic data backups.
Risk Management (RM): Assessing potential risks.
Security Assessment (CA): Evaluating security measures.
Situational Awareness (SA): Threat monitoring.
System and Communications Protection (SC): Communication security.
System and Information Integrity (SI): Identifying and rectifying weaknesses.
Processes and Practices in CMMC 2.0
Achieving compliance with CMMC 2.0 involves integrating processes and practices for building resilient cybersecurity infrastructure:
Level 1: Basic Cyber Hygiene.
Level 2: Intermediate Cyber Hygiene.
Level 3: Good Cyber Hygiene.
This streamlined structure focuses on essential practices for defense contractors to meet cybersecurity requirements.
Potential Pitfalls of CMMC 2.0 Compliance Assessment for Contractors
Passing the CMMC 2.0 audit is challenging. Here are common issues:
Open items on a Plan of Action and Milestones (PoAM): Unlike NIST 800-171, CMMC does not accept open PoAM items. Close all items before assessment.
Overshooting Your Target Level: Only pursue the certification level needed. Most contractors require Level 2 certification.
Cloud Confusion: Ensure everyone understands cloud security, especially given the remote work environment. Levels 2 and 3 require stringent cloud security measures.
Incomplete Policies and Procedures: Make sure all policies are complete, consistent, and fully implemented to avoid red flags.
Self-assessment is invaluable, but achieving CMMC compliance can be complex. FenixPyre is a CMMC and NIST SP 800-171 compliance solution that can ease the process, satisfying critical requirements.

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solutions
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Suite 224
New Albany, OH 43054

© 2018-2025 FenixPyre Inc, All rights reserved