Compliance with CMMC and NIST 800-171 standards is non-negotiable for any contractor or subcontractor that works for the US Department of Defense. With the advent of a more complex cyber threat landscape and the CMMC 2.0 framework, CMMC isn’t just for the defense industry anymore— organizations working with the US Department of Health and Human Services and other agencies are also frequently asked to step up and meet these higher standards.
However, from scoping and identifying sensitive information to preparing for formal assessment, there is no shortage of challenges companies of all shapes and sizes face on the often-bumpy road to CMMC certification. Compliance isn’t easy, but it is increasingly necessary in the modern government contracting environment, even for small organizations.
Cask Government Services has been helping organizations prepare for formal CMMC assessments and ensure their compliance for years. In this blog, we will share our tips for managing compliance with the CMMC and NIST standards your sector demands so you can continue to be cyber secure and competitive.
Understanding CMMC and NIST 800-171 Standards
The Cybersecurity Maturity Model Certification 2.0 framework is now in effect and is being progressively rolled out across new and renewing DoD contracts. CMMC 2.0 has a more simplified structure compared to its predecessors—down from five levels of cybersecurity to only three—and its cybersecurity controls are closely aligned with established NIST 800-171 controls.
Standards for assessment have also changed—and pivoting to align with these changes can make headaches for compliance managers, especially in small organizations where resources are already stretched thin.
For a refresher on the specifics of the CMMC 2.0 framework, you can refer to our previous blogs, “What Is CMMC?” and “Understanding the New CMMC 2.0 Compliance Requirements.”
How to Solve the Challenges of CMMC Compliance Management
Now, let’s break down the common challenges cyber compliance management professionals face in organizations of all shapes and sizes, as well as strategies for overcoming these challenges.
Scoping and Identifying Controlled Unclassified Information (CUI)
One of the primary purposes of CMMC certification is to prove you can handle CUI safely by tracking and controlling where it lives in your systems and who has access to it. Many organizations struggle to properly identify where CUI resides in their systems and who has access to it, though, since it can be scattered across departments and systems such as emails, cloud services, and devices.
Solutions to make identifying and containing CUI easier include:
- Building a systematic data discovery and classification process for your organization
- Using automated tools with tagging capabilities to scan and classify CUI in real time
- Train employees to recognize and handle CUI as part of your organization’s regular cybersecurity awareness training
- Engage a Registered Practitioner (RP) or Certified CMMC Assessor (CCA) to validate your scoping
Interpreting and Applying the CMMC/NIST Requirements
The requirements in NIST SP 800-171 and CMMC Level 2 controls are dense, technical, and often confusing for organizations without dedicated cybersecurity expertise. They can be especially overwhelming or vague to non-experts.
Solutions to make sense of CMMC and NIST standards include:
- Having a CMMC consulting partner walk through CMMC requirements and translate compliance language into actionable tasks
- Creating simplified checklists and control mappings to turn high-level controls into day-to-day operational practices
- Breaking down NIST controls into project tasks with responsible owners, deadlines, and documentation deliverables to make them more manageable for your organization
Resource Constraints (Budget, Staff, Expertise)
One of the biggest headaches faced by cybersecurity compliance managers, especially in small and mid-sized organizations, is the pressure to do too much with too little. Smaller contractors can find themselves lacking the in-house staff or cybersecurity experience needed to achieve compliance without overwhelming their teams or budgets.
When you’re lacking the financial or human capital to build a full cyber compliance program from scratch, solutions include:
- Prioritizing “high-impact” controls first based on risk and ROI to prioritize the most critical controls first and build momentum without draining resources
- Using phased implementation plans to spread compliance costs and efforts over time instead of all at once
- Outsourcing compliance tasks to third-party cloud or IT vendors, where possible
- Getting continuous compliance support from a managed service provider with CMMC experience
Keeping Up with Evolving Frameworks
The process of CMMC certification has seen a seismic shift with CMMC 2.0, and cyber compliance standards will only continue shifting as cybersecurity best practices and associated government cybersecurity policies continue to mature.
Changes to cyber compliance frameworks can impact your organization’s compliance status. Solutions to help your organization stay current now and tomorrow include:
- Subscribing to industry updates and alerts from DoD, CISA, and accredited CMMC advisory organizations.
- Assigning a compliance lead or team responsible for tracking regulatory changes and updating internal processes accordingly
- Documenting your compliance journey thoroughly so that adjustments can be made incrementally when requirements shift, or to use for a Plan of Action and Milestones (POA&M) if you fail to meet new standards for a DoD contract
Preparing for the Formal Assessment
CMMC certification isn’t about checking NIST controls off a list and handing that list to the DoD—it requires thorough documentation, validated security practices, and evidence that controls are effectively implemented over time, as proven through a rigorous formal assessment by a Certified Third-Party Assessor Organization (C3PAO) registered with and approved by the federal government.
Passing a formal assessment means proving the operational maturity of your cybersecurity controls, not just your technical capabilities. Solutions to prepare for and pass formal CMMC assessments include:
- Building a centralized compliance repository to house all of the documentation, artifacts, policies, and procedures relating to your cyber compliance efforts
- Running internal audits or readiness reviews using the DoD’s official CMMC L2 Assessment Guide to identify and close compliance gaps
- Creating a “compliance calendar” to ensure that key recurring practices, such as access reviews or incident response testing, are performed and logged regularly
Maintaining Compliance After Certification
Compliance management is an ongoing practice. The CMMC framework emphasizes maturity and continued effectiveness in your cybersecurity controls, which means you need to make sure your practices are sustained over time. If you lapse in your compliance practices, you will have trouble winning new contracts or renewing existing contracts.
Solutions to the challenges of maintaining your CMMC certification include:
- Using compliance management software or GRC platforms to automate control tracking, alerts, and evidence collection, and flag deviations from best practices early
- Conduct quarterly or bi-annual internal reviews to confirm that relevant NIST 800-171 controls remain in effect and identify any drift quickly
- Incorporate compliance checks into your change management processes to ensure that any new systems or software platforms you bring into your organization don’t introduce unvetted risks
Achieve CMMC Certification and Stay Certified With Help From Cask
CMMC and NIST compliance is your organization’s way of proving to the government that it can trust you. Whether you’re a small subcontractor with clients in the defense industry or a large contracting firm with multiple DoD partnerships, compliance management can pose significant and ongoing hurdles.
Since 2004, Cask has set high standards for helping businesses meet cyber compliance standards. As CMMC consultants, we provide comprehensive personalized support and extensive expertise to help you strengthen your security posture with NIST standards and pass your formal CMMC assessments. Our CMMC Readiness Program includes Mock Assessments, Pre-Assessments, Gap Analysis, POA&M Remediation, and more to ensure your compliance.
Set your organization up to win federal contracts and save money and time. Reach out to Cask’s expert advisors today to get started: Contact us today to get started.
