CMMC consists of 17 security domains with focus areas such as Access Control, Identification and Authentication, Audit and Accountability, and Risk Management. Within each domain are practices or controls derived from NIST 800-171 for Levels 1 and 2 and NIST 800-172 for Level 3. As of December 2021, the DoD has yet to publish how the previous CMMC 1.0 practices are realigned to the 2.0 three-level model or the new NIST 800-172 practices.
To meet Level 3, a company must have a management plan designed to conduct operations with cyber hygiene best practices in mind, including NIST 800-171 standards. The NIST 800-171 standards are security requirements aimed at protecting controlled unclassified information (CUI).” To “To meet Level 2 or 3, a company must have a management plan designed to conduct operations with cyber hygiene best practices in mind, including at a minimum NIST 800-171 standards. The NIST 800-171 standards are security requirements aimed at protecting controlled unclassified information (CUI).
Managing Subcontractor Access
It isn’t easy to manage subcontractor access and guarantee that they are appropriately scoped and accessed. It can also be a challenge to ensure their access is removed when they leave. Because all DoD contractors and subcontractors will need to be CMMC compliant by October 1, 2025, it’s recommended that prime contractors begin working with their subcontractors to develop the relevant compliance programs. That doesn’t have to be a challenge, however. Vendor access management solutions can oversee contractor access to sensitive materials and manage their access throughout the vendor-subcontractor lifecycle.
Demonstrating CMMC Compliance
Demonstrating full NIST 800-171 and 800-172 compliance can be challenging to maintain, especially when assets reside on-premises and in the cloud. However, automation and risk-based assessment of access requests can streamline the access management process in the face of dissolved network boundaries. This is accomplished by extending governance uniformly throughout the IT ecosystem, making it easy to consistently meet compliance requirements. Likewise, implementing risk-based data governance helps provide consistent controls no matter where the data resides.
Finally, meeting the evidentiary burden of the CMMC requirements can be difficult. You’ll need to prove that you’re constantly and consistently meeting the requirements. That process can be labor-intensive if the proper evidence isn’t readily available or adequately tracked. That’s why it’s in your best interest to automate your evidence collection. Continuous monitoring and tracking of controls provide the evidence auditors will require, minimizing employee time invested.