Information Technology Navigator

The Cybersecurity Maturity Model Certification (CMMC) program journey started back in 2019, which eventually led to DFARS Case 2019-D041. Since then, it has gone through several changes and program evolutions. Nearing 4 years in the making and getting closer to being finalized, companies are wondering what is next. What is the target date for the new rule?

CMMC Rulemaking Timeline

The rulemaking process illustrated in the graphic below shows a high-level workflow from the Government Accountability Office (GAO).

Figure 1: GAO Federal Rulemaking

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Companies performing work in the Defense Industrial Base (DIB) often contemplate whether they should use a cloud service provider for their business, then wonder which version of the cloud service they should consider. The rules and regulations passed down to the DIB from the Federal Government are quite confusing when it comes to trying to figure out what their requirements are. In this article, we will try to clear some of that up!

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Many companies are currently evaluating how they might fund initiatives necessary to move their businesses towards compliance with the Cybersecurity Maturity Model Certification (CMMC). There are a few ways to fund these initiatives, but many key items have the potential to impact the amount of funding needed to prepare your organization for certification. So, where do you start to appropriately scope the project, and how do you know how much it will actually cost?

Whether your company plans to meet the CMMC objectives or to stop doing business with the Federal Government, keep in mind that cybersecurity is an important part of maintaining your business health and ensuring resiliency in the future. When businesses suffer a cyberattack and cannot afford the cost to recover, they often go bankrupt. In addition to the new federal regulations being pushed out by the Defense Federal Acquisition Regulations (DFARS), many states have laws requiring levels of protection for different types of information. Other federal governments have also enacted cybersecurity protection measures for their citizens (such as GDPR). Not doing so can also leave you open to lawsuits in the event of a breach or incident.

5 Phases for Cybersecurity Compliance

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It’s been almost a year since we wrote about the risks of delaying CMMC (Cybersecurity Maturity Model Certification) compliance. The only thing that has remained constant since then is that CMMC is not going away. There have been many noteworthy recent developments in the DoD supply chain news space related to updates for DIB contractors to comply with the DFARS 7012 requirements to safeguard CUI (controlled unclassified information) data. The CMMC 2.0 final rulemaking timeline continues to shift from over the horizon to right around the corner, and the recently released NIST 800-171 revision 3 draft amplifies concerns about upcoming changes to the framework requiring additional protections for prime and subprime organizations supplying the DoD.

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An Introduction to Cybersecurity for the Defense Industrial Base:

In today's digital age, cybersecurity is of paramount importance, particularly for organizations within the Defense Industrial Base (DIB). In January 2020, the United States Department of Defense (DoD) introduced the Cybersecurity Maturity Model Certification (CMMC) framework, building upon established cybersecurity standards from National Institute of Standards and Technology (NIST) Special Publication 800-53 and NIST Special Publication 800-171. These publications are closely aligned with the CMMC 2.0 requirements, providing essential guidelines for protecting Controlled Unclassified Information (CUI) in non-federal systems and organizations. In addition, DFARS 252.204-7020 clause requires contractors to undergo an assessment of their implementation of NIST SP 800-171 controls by an accredited third-party assessment organization to evaluate a DIB contractor's compliance with the security requirements outlined in NIST SP 800-171 and provide assurance that adequate safeguards are in place to protect CUI.

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Adoption of Microsoft’s 365 Government Community Cloud (GCC) High sovereign cloud solution is on the rise as organizations in the Defense Industrial Base (DIB) work to ensure compliance with the stringent regulations related to the Cyber Security Maturity Model (CMMC) v2.0 and current NIST 800-171 framework. GCC High is an excellent option for DIB contractors who handle Controlled Unclassified Information (CUI) and International Traffic in Arms Regulation (ITAR) data in their cloud or hybrid environments.

Microsoft continuously improves and enhances features and capabilities to the GCC High platform. Just like updates to Microsoft 365, it can be hard to keep up with them all. Daymark’s Government Community Services Team has carefully selected updates we believe are worth paying attention to with our own GCC High Roadmap.

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Preparing for a Cybersecurity Maturity Model Certification (CMMC) 2.0 assessment can be completely overwhelming. Here’s the good news: If you’re NIST 800-171 compliant, you’re more than halfway there. If you’re not, you’ve got some work to do for sure, but it’s not as complicated or daunting as you may fear.

NIST 800-171

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The Cybersecurity Maturity Model Certification (CMMC) 2.0 is the DoD framework designed to enhance cybersecurity and protect against compromise of sensitive defense information on contractors’ systems. Some defense industrial base organizations (DIB) have mistakenly taken a “wait and see” attitude about preparing for CMMC compliance, believing that they will wait until the government finalizes 2.0 requirements. While holding off on the time, resources and budget to prepare for CMMC may seem prudent (and frankly easier to delay), the risks of waiting could have a significantly negative impact on contractors’ revenue. Here’s why: 

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If your organization has been working towards NIST 800-171 and is now on the journey to achieve CMMC 2.0 (the Cybersecurity Maturity Model Certification) it can be difficult to understand what you’ve already achieved and what’s left to do. Both standards are intended to reduce threats and strengthen cybersecurity for sensitive government data. Here’s some details on how they relate to each other and what’s involved to take the next steps toward CMMC compliance.

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Microsoft’s Azure Government has become a trusted cloud for US government agencies, contractors and the Defense Industrial Based (DIB), providing unified security to protect the nation's data, and solutions for secure remote collaboration. Microsoft’s Azure Government uses the same underlying technologies as Azure, which includes the core components of Infrastructure-as-a-Service (IaaS), Platform-as-a-Service (PaaS), and Software-as-a-Service (SaaS). The increased security is achieved because it is a physically isolated sovereign cloud environment dedicated to US federal, state, local, and tribal governments, and their partners. It provides an extra layer of protection to mission-critical workloads through contractual commitments regarding storage of customer data that is subject to various US government regulations such as Export Administration Regulations (EAR) and International Traffic in Arms (ITAR). Azure Government offers additional security by relying on screened US personnel.

Azure Government and CMMC

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