Should All DoD Contractors be CMMC Certified Under the Revised CMMC 2.0?

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DoD vendors have been left questioning if they would require CMMC accreditation because the Department of Defense overhauled CMMC with the release of CMMC 2.0 on November 4, 2021.

The answer remains yes, but the path to get there is evolving. DoD contractors who are aiming for government contractors must consult CMMC consulting VA Beach firms to fulfill compliance needs.

What exactly is CMMC certification?

CMMC is a single cybersecurity standard for cybersecurity deployment throughout the IB).

CMMC was formed in response to the federal supply chain vendors’ failure to comply with NIST SP 800 171, which mandated contractors operating in government distribution networks to comply by December 31, 2017.

Because vendors could self-attest to NIST SP 800 171 adherence, the DoD established CMMC to boost national sovereignty and the cybersecurity of enterprises participating in federal supply chains. The provision for self-attestation at any grade was removed in the original version of CMMC. With the release of CMMC 2.0, self-attestation is now an option for some firms at certain levels. 

All Contractors Must Be CMMC Certified

NIST 800-171 may have been the initial introduction to compliance for many small businesses operating in government distribution networks. NIST 800-171 was the first compliance obligation to affect prime contractors working directly for the government and suppliers operating for primes or other suppliers.

CMMC, like NIST 800-171, is a flow downwards clause. A corporation working on a federal contract must conform with NIST 800-171 or CMMC (depending on the contract criteria) and guarantee that any subcontractors working for them do.

Companies functioning under a DoD contract must retain their CMMC accreditation for the contract term.

Any firm in the federal supply chain that deals with unclassified government data must be compliant. Examples of typical enterprises include industries, educational institutions, research institutes, consulting firms, and service providers.

Companies that only manufacture Commercial-Off-The-Shelf (COTS) items are exempt from CMMC regulations.

How to Acquire CMMC Certification?

The technique for being certified differs depending on the degree of CMMC cybersecurity required. The primary difference is whether you are safeguarding FCI or CUI.

FCI is information the US government offers under an agreement to produce or provide a service or product to the administration. Still, it is unavailable to the public, such as on web pages.

CUI is information created or possessed by the United States government that a law, rule, or government strategy mandates or allows an agency to manage using safeguarding or distribution restrictions.

3 CMMC Levels of CMMC Certification

In CMMC, there are three levels:

  • Level 1 – Fundamentals
  • Level 2- Advanced 
  • Level 3- Expert 

The initial CMMC architecture featured five levels; however, that has now altered with the release of CMMC 2.0.

The security significance of the data you get when executing a contract determines the CMMC level. Level 2 compliance is more challenging to achieve than Level 1 adherence, while Level 3 compliance is more difficult to accomplish than Level 2.

The agreement you are operating will specify which level you must achieve.

You might operate for main contractors with a higher CMMC standard than you. You may be eligible for a lower CMMC level if the prime only runs down certain information.

When does CMMC certification become necessary?

Entities dealing with unclassified federal information must follow NIST 800-171 or CMMC.

The DoD is steadily shifting away from the NIST 800-171 requirement and toward CMMC. All new DoD agreements will be required to comply with CMMC by October 1, 2025, according to DFARS 252.204-7021. When authorized by the DoD, the CMMC provision can be incorporated in new contracts before October 1, 2025.

The DoD will describe the needed CMMC level in Requests for Information (RFI) and Requests for Proposals (RFP). Before a contract can be awarded, you must be certified.

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