CMMC Compliance Countdown

CMMC Compliance Countdown

A Brief History of CMMC

CMMC includes the same 110 controls central to NIST 800-171, with one key difference: CMMC mandates an independent third-party assessment by a C3PAO (CMMC Third-Party Assessor Organization).

Since 2017, defense contractors handling controlled unclassified information (CUI) have needed to comply with NIST 800-171. Therefore, the question isn’t about when defense contractors must meet CMMC standards—they’ve been obligated to do so for the past five years. The only uncertainty is when strict enforcement will start.

The Department of Defense (DoD) has made it clear that CMMC is imminent and unavoidable.  Defense contractors must work towards achieving compliance or lose valuable revenue generating contracts with the DOD.  The CMMC Compliance Checklist could assist in preparation for CMMC readiness.

When is CMMC Going to be Integrated in DOD Contracts?

CMMC will likely be codified by the end of 2024 and included in contracts by Q1 2025. However, companies shouldn’t wait to start their CMMC implementation plans. NIST 800-171, which forms the basis for CMMC, is already required. Additionally, prime contractors are beginning to demand CMMC compliance from their subcontractors ahead of the official rule.

Preparing for CMMC Level 2

With CMMC set to appear in contracts by Q1 2025, you need to begin compliance preparations now.  It typically takes 12-18 months for the average defense contractor to become assessment-ready.  Doing nothing is not an option. “If you do not get CMMC Certification, you will not be able to win DoD contracts. I cannot emphasize that enough,” said Travis.

The CMMC timeline below outlines the steps a contractor might take to meet all 110 NIST 800-171 controls by the time CMMC is finalized. There are a few key points from this timeline that will help guide your compliance journey. (Read our blog on the CMMC Compliance Checklist for a comprehensive guide to organizing your company’s compliance efforts.)

First, while the timeline suggests a typical timeframe for each task, the time and effort needed to achieve compliance will vary for each defense contractor. Factors include your baseline cybersecurity maturity level and the resources and prioritization you can dedicate to achieving compliance.

Second, protecting CUI is central to both NIST and CMMC compliance. Additionally, it is not enough to merely protect your CUI; you must also provide adequate documentation to prove your compliance. CMMC assessments, conducted by C3PAOs at levels 2 and 3, will require your System Security Plan (SSP) to demonstrate how you meet each assessment objective, along with sufficient evidence and support.

Additionally, it is not enough to merely protect your CUI

Ensure you address the POAMs, specifying the technologies and procedures needed to close those gaps. C3PAOs will allow limited use of POAMs at the time of assessment, and only for a few of the lowest-scoring practices. You need a minimum score of 80% (88/110) to be eligible for conditional certification, so do not rely on POAMs to pass CMMC.

Once you’ve identified the unmet controls, take the necessary actions to meet those controls. POA&Ms are time-bound and will expire within 180 days after your C3PAO assessment. A POA&M must document all proposed actions to remediate deficiencies and the respective timeframe. Regularly update the POA&M to reflect the progress of corrective actions. It is critical to prioritize closing any security gaps.

While your organization doesn’t need the highest possible assessment score by mid-2024, it should be close to achieving it by then. According to NIST 800-171A, you are already responsible for meeting all the security standards included in CMMC. If you are not yet fulfilling this obligation, the time to act is now.

Defense contractors aim to not only remain eligible for defense contracts but also to minimize business risk and keep CUI out of adversaries’ hands. By starting your compliance journey, you can achieve these objectives and ensure your company is ready for stricter federal cybersecurity regulations.

Let Intech Hawaii Help You Reach your CMMC Compliance Goal

Intech Hawaii offers a CMMC 2.0 assessment timeline to help you meet these goals. To learn more, contact us for a consultation with our compliance experts to answer your questions about NIST SP 800-171 and CMMC 2.0.

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