Navigating the Complexities of CMMC Compliance: A Roadmap for Government Contractors

Integrating robust cybersecurity measures has become an essential aspect of government contracting, especially with the emergence of the Cybersecurity Maturity Model Certification (CMMC). However, for many government contractors, navigating the complexities of CMMC compliance can feel like a daunting and confusing task. With an array of regulations, procedures, and requirements to adhere to, it is crucial for contractors to partner with trusted cybersecurity experts like Deltek and NeoSystems to simplify the compliance process. By working closely with these trusted partners, contractors can gain a clear roadmap that ensures their cybersecurity measures align with CMMC standards, ultimately helping them meet the ever-evolving demands of government contracts.

In a recent informational webinar hosted by NeoSystems and Deltek, Stuart Itkin and I shed light on an innovative approach to secure data and support CMMC compliance. We dive into the complicated waters of cybersecurity compliance for government contractors to help clarify some of the often-confusing details of who is responsible for securing controlled unclassified information (CUI) in the many places that it might exist in your business. I’ll share a few of the highlights from our discussion.

In today's rapidly advancing digital landscape, cybersecurity is a very high priority, particularly for entities entrusted with handling sensitive government contracts. Since 2016, the Department of Defense (DoD) has progressively fortified its cybersecurity requirements for contractors, requiring evidence of implementing National Institute of Standards and Technology (NIST SP 800-171) controls. Despite these efforts, maneuvering through these requirements has proven to be a complex task, paving the way for the introduction of the Cybersecurity Maturity Model Certification (CMMC) enforcement framework. As CMMC looms on the horizon, it is imperative for defense contractors to grasp and prepare for the imminent changes.

CMMC represents a significant shift in how cybersecurity compliance is enforced within the defense industrial base. Unlike previous self-assessment “honor system” models, CMMC introduces certified third-party evaluation and approval as a prerequisite for contract awards. This means that contractors must not only implement but also maintain a specified level of security spanning various aspects of their operations, including in-office systems, external cloud services, and written policies and procedures.

What’s In Scope for CMMC

One of the greatest hurdles in the world of cybersecurity compliance for government contractors has to be the knowledge of what’s expected and how to prepare. Additionally, knowing where protected CUI data resides will determine the scope of the compliance certification. The key areas distill into: IT, People, Facilities, Managed Services and Cloud Services.

Establishing a secure “CMMC Enclave” enables companies to implement the necessary technology and resources to safeguard CUI, focusing exclusively on the part of the organization that manages sensitive data. An Enclave is essentially a segmentation of an organization’s network or data that is intended to ‘wall off’ that network or database from all other networks or systems.

Larger organizations may have lots of people and external service providers, so Enclaving is an effective means of reducing scope, so that your CMMC certification process is smooth and easy. Without reducing the scope of an audit, your entire enterprise is subject to NIST 800-171/CMMC controls and evaluation.

When you need to store/process/handle CUI data in an external system, so you must choose a cloud service provider that meets the requirements of DFARS 252.204-7012, which specifies that your cloud service provider must demonstrate FedRAMP Moderate Equivalent controls and an Incident Response Plan that complies with the requirements of sections (c) through (g).

Follow The Data

The level of cybersecurity compliance required for CUI is determined by who has custody of it, and where it will be stored/processed/handled. Businesses with DoD contracts containing the DFARS 252.204-7012 clause are required to protect Controlled Unclassified Data (CUI) by implementing NIST SP 800-171 controls in all their computer systems. If CUI data will exist in external systems, such as SaaS solutions, those systems must meet the higher standard of security – FedRAMP Moderate equivalence.

If a DoD contractor utilizes an External Service Provider (ESP), other than a Cloud Service Provider (CSP), the ESP must have a CMMC certification level equal to or greater than the certification level the contractor is seeking. The timing of your ESPs certification will affect your own certification timeframe, so it’s essential to take the time to find the right partner to suit your unique needs in plenty of time to ensure you do not miss your window of opportunity.

The Path to Compliance

Achieving CMMC compliance is no small feat. It requires a current and sometimes comprehensive understanding of the program requirements, the level of effort needed for your organization to meet your shared responsibilities, the potential risks of non-compliance, and strategies for mitigating any threats before your audit.

As the timeframe for implementing CMMC draws closer, government contractors are under increasing pressure to prioritize cybersecurity readiness. Ensuring compliance and maintaining eligibility for DoD contracts is a paramount concern. However, with the right strategies and trusted partners, such as NeoSystems and Deltek, contractors can confidently navigate the complexities of all facets of CMMC compliance. This allows for the safeguarding of sensitive data and the securing of future opportunities in the defense sector.

How Deltek Supports Government Contractors with CMMC Requirements

Deltek is dedicated to protecting your data by ensuring our capabilities meet the constantly changing security landscape. We are continuously adjusting our suite of products and services to support your cyber posture by increasing our investment in security, compliance and supporting technologies for our customers – easing and scaling the management of systems for your teams.

When fully implemented, CMMC mandates that all DoD contractors have a CMMC certification. While this mandate may seem distant, government contractors should plan ahead, by making it a top priority to find a Cloud Service Provider (CSP) that offers a solution that will support their CMMC compliance requirements. Investing in a cloud partner and a solution that supports your cybersecurity requirements, including FedRAMP Moderate equivalency, will be essential. Costpoint GCCM has achieved FedRAMP Moderate Ready status, which delivers security controls you will need, and the subject matter expertise you can expect from an industry leader. At Deltek, we are dedicated to being your trusted partner.