Deep Dive into the Three Levels of CMMC 2.0

CMMC 2.0  (Cybersecurity Maturity Model Certification) is a framework to safeguard private data in the U.S. Department of Defense’s (DoD) supply chain from malicious attacks. The three levels of CMMC 2.0 align NIST 800-171 requirements with its Level 2 practices and plans to incorporate NIST 800-172 for Level 3 practices. To attest to compliance with CMMC 2.0, DoD contractors must undergo self-assessments and engage CMMC Third Party Assessor Organizations (C3PAOs).

The Department of Defense (DoD) disclosed the long-awaited proposed rule for the Cybersecurity Maturity Model Certification Program (CMMC) on December 26, 2023. This regulatory effort in cybersecurity is expected to substantially influence a wide range of government contractors. The rule applies to contractors in processing sensitive data, including Controlled Unclassified Information (CUI) or Federal Contract Information (FCI), within the scope of DoD contracts.

Feedback on the proposed rule for the Cybersecurity Maturity Model Certification Program (CMMC) will be welcomed until February 26, 2023.

Understanding the 3 Levels of CMMC 2.0 and How to Achieve Each

CMMC, established to bolster cybersecurity measures in the Defense Industrial Base (DIB), addresses concerns about the security of Controlled Unclassified Information (CUI) within the supply chain. It applies to all organizations contracting with the DoD, including small businesses, commercial item contractors, and foreign suppliers. The regulation mandates certification across three maturity levels, each specifying cybersecurity practices and processes and different requirements at each level in achieving CMMC 2.0 compliance.

This regulation is a vital standard for implementing cybersecurity uniformly across the DIB, especially concerning sensitive information. Its primary goal is to protect critical proprietary, strategic, and operational data from cyber breaches.

Demonstrating CMMC compliance offers several advantages, such as enhancing national security by safeguarding data, boosting company credibility and marketability through improved cybersecurity practices, and maintaining eligibility for DoD contracts. Additionally, it assists organizations in identifying their cybersecurity strengths and weaknesses, leading to more efficient and effective operations.

The Differences Between CMMC 1.0 and the CMMC 2.0 Framework

CMMC 2.0 builds upon the foundation of CMMC 1.0, incorporating several significant modifications, which include:

  1. Streamlined Capability Domains: CMMC 2.0 enhances the depth of each capability domain while reducing their total count from 17 to 14.
  2. Introduction of New Maturity Levels: CMMC 2.0 simplifies two additional maturity levels initially, labeled 4 and 5, but later reduced to 3, expanding the progressive end of the spectrum.
  3. Revised Security Requirements: CMMC 2.0 updates the security requirements associated with each capability domain and maturity level.
  4. Increased Focus on System Security Plans: CMMC 2.0 emphasizes system security plans, mandating their update to align with the updated CMMC framework.

Implementing and understanding CMMC 2.0 framework equips organizations with enhanced capabilities to defend against cyber threats and ensures adherence to pertinent regulations to meet the requirements of CMMC and achieve level 3 compliance. It is essential to recognize that while CMMC 2.0 offers valuable guidelines, it is not a one-size-fits-all solution and should be customized to meet the unique requirements of each organization.

What Are the CMMC Levels?

The three levels of CMMC 2.0 establish the cybersecurity preparedness of organizations engaged with federal agencies, particularly those in IT contracting. These levels play a critical role in ensuring the robust protection of sensitive data throughout the supply chain.

The implementation of CMMC 2.0 introduces a more streamlined approach by consolidating the previous five levels into three, aiming for clarity and practicality. Each level of CMMC 2.0 model builds upon the foundation of the preceding one, progressively elevating cybersecurity best practices and security controls.

For those thinking about the possibility of self-CMMC certification to achieve compliance requirements, it’s important to note that solely relying on self-assessment will not be good enough when implementing CMMC 2.0. While annual self-assessments will be a requirement for CMMC 2.0 Levels 1 and 2, evaluations conducted by Certified Third-Party Assessment Organizations (C3PAOs) will be a crucial element of the compliance process. Determining the appropriate CMMC level for your organization hinges on the nature of your work and the sensitivity of the information you handle for federal agencies.

CMMC Level 1: Foundational

CMMC Level 1 marks the initial tier in the CMMC 2.0 compliance. This level acts as the fundamental foundation of CMMC compliance, and despite being viewed as the starting point, it holds significant importance.

At Level 1, the focus is on laying the groundwork for an essential set of cybersecurity practices within an organization. The cybersecurity requirements are designed to enable even organizations with limited resources and relatively low cybersecurity risk to safeguard sensitive government data effectively.

Who Needs Level 1?

Level 1 targets organizations responsible for Federal Contract Information that do not fall under critical infrastructure classification. This level of cybersecurity includes a wide range of businesses and government agencies. While these organizations may not handle classified data, they manage government information. To achieve CMMC Level 1 compliance is a crucial measure in securing this data.

CMMC Level 1 Requirements

Getting the CMMC Level 1 certification involves adhering to 17 specific controls outlined in FAR 52.204-21. These controls cover various critical cybersecurity practices of CMMC requirements, including:

  1. Access control: Managing permissions for system and data access.
  2. Password management: Enforcing secure password policies.
  3. System updates: Keeping software and systems current with security patches.
  4. Malware protection: Implementing measures to detect and prevent malware.
  5. Incident response: Developing procedures for addressing and reporting security incidents.
  6. Physical security: Safeguarding physical access to sensitive areas and assets.
  7. Data protection: Implementing measures to ensure data integrity and confidentiality.
  8. Employee training: Providing cybersecurity awareness training to staff.

These fundamental requirements lay the groundwork for your organization’s cybersecurity full compliance. Level 1 is a crucial starting point, ensuring data security and establishing readiness for higher CMMC levels. Implementing CMMC Level 1 compliance ensures government compliance and strengthens overall cybersecurity. Progressing to higher levels further builds on this foundation, advancing security maturity.

CMMC Level 2: Advanced

CMMC Level 2 represents the middle stage within the CMMC 2.0 framework, indicating that organizations should have a more robust cybersecurity posture compared to Level 1.

While Level 1 concentrates on foundational practices, Level 2 goes further into advanced cybersecurity hygiene. Level 2 compliance is a notable stride in improving an organization’s capacity to protect sensitive information.

Who Needs Level 2?

Adhering to Level 2 compliance is essential for organizations responsible for managing Controlled Unclassified Information (CUI) within critical infrastructure sectors such as energy, water, and transportation. This is crucial in sectors where safeguarding sensitive government data holds significant importance. Organizations that attain Level 2 have showcased their dedication to securing CUI and fortifying the resilience of their critical systems.

CMMC Level 2 Requirements

CMMC Level 2 incorporates a comprehensive array of cybersecurity practices derived from NIST SP 800-171. These practices consist of 110 requirements addressing various facets of cybersecurity, such as:

  1. Access control: Implementing strict controls on system and data access.
  2. Incident response: Establishing robust procedures for detecting, reporting, and responding to security incidents.
  3. Risk management: Effectively identifying, assessing, and mitigating cybersecurity risks.
  4. Physical security: Strengthening controls for physical access to secure critical assets.
  5. System and information integrity: Ensuring the integrity and authenticity of system information.
  6. Audit and accountability: Maintaining detailed records of system activities for analysis and review.
  7. Security training: Providing advanced cybersecurity training to personnel.
  8. Configuration management: Controlling system configurations to minimize vulnerabilities.

Level 2 requires the implementation of advanced cybersecurity measures to safeguard critical data and infrastructure. Achieving Level 2 certification reflects a robust commitment to cybersecurity, enhancing eligibility for federal contracts with Controlled Unclassified Information (CUI) requirements.

CMMC Level 3: Expert

CMMC Level 3 stands as the epitome of cybersecurity readiness in the CMMC 2.0 framework. This certification represents the highest attainable level, showcasing an elite level of expertise and rigorous cybersecurity measures.

Building upon the groundwork laid in Level 2, Level 3 introduces additional layers of security, making it particularly appropriate for organizations entrusted with the most sensitive government information.

Who Needs Level 3?

Adherence to Level 3 compliance is obligatory for organizations engaged in critical Department of Defense (DoD) contracts that involve handling Controlled Unclassified Information (CUI). Operating within critical infrastructure, these organizations oversee CUI and manage highly sensitive DoD projects. Level 3 certification guarantees the highest level of security for CUI.

CMMC Level 3 Requirements

CMMC Level 3 encompasses an extensive set of cybersecurity prerequisites, drawing from FAR 52.204-21 and NIST SP 800-171 while integrating additional practices from NIST SP 800-172. To attain Level 3 compliance, organizations must satisfy more than 110 security practices covering various domains:

  1. Access Control: This involves implementing comprehensive access protection through authentication, encryption, and session termination.
  2. Awareness and Training: Organizations must conduct thorough security awareness training to identify and report insider threats effectively.
  3. Audit and Accountability: Regular event reviews, audit information protection, and correlation for incident investigation are integral components.
  4. Configuration Management: Emphasis is placed on defining system access, minimizing access, and employing blacklisting and whitelisting measures.
  5. Identification and Authentication: Multi-factor authentication (MFA), prevention of credential reuse, and disabling idle accounts are enforced.
  6. Incident Response: This requires incident tracking, documentation, reporting, and regular testing of response capabilities.
  7. Maintenance: Mandates equipment sanitization and media monitoring to prevent malicious code.
  8. Media Protection: Encompasses media marking, disallowance of ambiguous storage devices, use of cryptography, and restricted access to media with Controlled Unclassified Information (CUI).
  9. Personnel Security: Screen and clear personnel to minimize insider threat risk.
  10. Physical Protection: Extends safeguards to alternative work sites to secure information.
  11. Risk Management: Involves risk assessments, mitigation planning, and managing unsupported vendor products.
  12. Security Assessment: Monitors existing controls and conducts independent security assessments.
  13. Situational Awareness: Involves collecting, analyzing, and sharing external cyber threat intelligence to enhance security awareness.
  14. System and Communications Protection: Encompasses cryptography, user functionality separation, and secure network traffic management.
  15. System and Information Integrity: Requires spam detection, forgery prevention, and sandboxing for email security.

Level 3 signifies the highest cybersecurity maturity, focusing on advanced aspects such as threat detection, response, and secure data handling. Certification at this level demonstrates a commitment to excellence and establishes trust for Department of Defense (DoD) contracts requiring top-tier security.

Achieve Your CMMC Compliance With Intech Hawaii

With its formal adoption, adherence to CMMC standards serves as your protective barrier in federal contracting and opens the door to federal opportunities. At Intech Hawaii, our primary focus is attaining CMMC 2.0 levels.

Whether you are venturing into CMMC compliance, need specialized training, or are preparing for a thorough CMMC assessment, Intech Hawaiin provides tailored services. Our specialists will evaluate your cybersecurity posture, formulate robust policies and procedures, and implement the necessary controls for complete compliance.

Ensure the security of your federal contracts with certainty. Contact Intech Hawaii today to help you start your journey toward CMMC excellence.