Every company begins the CMMC compliance process at a different point: your company may be out of compliance and in need of a NIST 800-171 assessment, score, and associated documents (SSP & POA&M). Perhaps you only require assistance from a CMMC consultant with the implementation of specific control requirements. Alternatively, you may have adopted CMMC standards and require an outside party to conduct a CMMC Pre-Assessment to validate your existing state.

What is CMMC?

The Department of Defense (DOD) is rolling out a new cybersecurity framework standard dubbed the Cybersecurity Maturity Model Certification in an effort to streamline regulations and enhance security for DOD contractors (CMMC). NIST SP 800-171, the Federal Acquisition Standards (FAR) document 52.204-21, and other requirements are included in this new umbrella standard. The two forms of information covered by this new standard are Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) (CUI).

Unlike the previous NIST SP 800-171 criteria, self-assessments will only be approved for a subset of FCI contracts and will need an annual confirmation from a senior corporate official that the company is satisfying requirements.

There will be three CMMC compliance levels under the new CMMC 2.0 Compliance Rules, which are dependent on the information maintained by the contractor (FCI versus CUI) and differ in control and assessment requirements.

The vast bulk of the DoD supply chain will be required to get CMMC Level 1 or 2 certification. See CMMC Certification Levels for a more complete discussion of the three levels and their criteria.

In early 2021, the Department of Defense began issuing contracts that required CMMC certification. By the end of 2025, all contracts will be required to comply with CMMC compliance and certification, according to the initial timeframe. After introducing CMMC 2.0 in November 2021, the Department of Defense decided to put a hold on new contracts until the CMMC 2.0 rulemaking process is finished. This will take between 9 and 24 months. As a result, future DoD contracts might include CMMC 2.0 standards as early as late 2022. Because the road to CMMC compliance will take several months, now is the time to start planning.

The Department of Defense said that it is looking into ways to incentivize and reward contractors that comply with CMMC 2.0 criteria before they become required.