Information Technology Navigator

On October 15, 2024, the final rule for the Cybersecurity Maturity Model Certification (CMMC) program was officially published. This rule, codified as 32 CFR, becomes effective on December 16, 2024. The CMMC journey began in 2019 with DFARS Case 2019-D041, and after four years of development, the rule is now finalized. Let’s take a look at the history of the CMMC timeline, what's to come, and how organizations can prepare for what is next.

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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Protecting sensitive and classified information when working for the Federal Government requires constant vigilance. When the government issues a contract, it must specify to the performing contractor when covered defense information (CDI) or controlled unclassified information (CDI) will be generated under the contract. Many prime contractors “flowdown” every FAR and DFARS clause to subcontractors and vendors without considering if that subcontractor or vendor will be processing, storing, or transmitting CDI. Anticipating where CDI may reside once awarded a contract can be a challenge. Here is guidance on ways CDI can flowdown to subcontractors and the defense industrial base (DIB), and steps those organizations should take before signing an agreement.

An Introduction to DFARS

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DMARC (Domain-based Message Authentication, Reporting & Conformance) is an email authentication, policy, and reporting protocol. It builds on the widely deployed SPF and DKIM protocols, adding linkage to the author (“From:”) domain name, published policies for recipient handling of authentication failures, and reporting from receivers to senders to improve and monitor the domain’s protection from fraudulent email.

DMARC is designed to fit into an organization’s existing inbound email authentication process. The way it works is to help email receivers determine if the purported message “aligns” with what the receiver knows about the sender. If not, DMARC includes guidance on how to handle the “non-aligned” messages. Because cyber security continues to be a top priority for businesses, DMARC adoption is on the rise for several good reasons.

Top 3 Reasons to Implement DMARC

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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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On October 30, 2023, the US Securities and Exchange Commission (SEC) announced fraud charges against SolarWinds and its former chief information security officer (CISO), alleging that “SolarWinds’ public statements about its cybersecurity practices and risks were at odds with its internal assessments.” This comes on the heels of the SEC’s newly implemented rules for disclosures relating to cyber risk. Publicly traded companies (along with pre-IPO and foreign private issuers) must now adhere to new and prescriptive rules requiring the disclosure of “material cybersecurity incidents” as well as annual disclosures relating to “cybersecurity risk management, strategy, and governance.”

There is a lot going on with all the recent SEC and cyber headlines, so let’s break it down piece by piece. This blog outlines several high-level calls to action that CISOs and their stakeholders should consider as they work through their cyber risk strategy and their cyber and/or directors and officers (D&O) insurance renewals.

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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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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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