Even if they have an in-house IT staff, most firms are not advised to manage all parts of CMMC preparation structurally. On the one hand, before a CMMC for DoD contractors evaluation or audit, it’s advisable to analyze all of the current measures.
On the other hand, you could overlook a few flaws if you don’t have an expert’s perspective. When you reach the CMMC preparation phase, contact a Registered Provider Organization (RPO) with Registered Practitioners (RPs).
Because they have undergone direct training from the CMMC Accreditation Body (CMMC-AB) and must behave according to an established standard to retain their RPO designation, an RPO knows the criteria as intended. A skilled RP will assess your infrastructure, systems, and controls regarding the appropriate CMMC Level a business is attempting to attain when stepping through a thorough gap analysis.
Enter: Gap Analysis for other related frameworks, such as NIST 800-171, is familiar territory for the CMMC Gap Analysis Compliance teams. They’re incredibly useful when deciding on a broad approach to a cybersecurity strategy and establishing a Plan of Action and Milestones (POA&M).
For example, CMMC Level 3 comprises NIST 800-171’s 110 controls plus an extra 20 for 130 controls. CMMC, unlike a standard NIST 800-171 gap assessment and report, needs maturity and reproducible, reliable evidence for two of the three techniques per control: proof via interview, proof through testing, and proof through observation.
Before completing the CMMC inspection, each control must be a demonstrable element of your organization’s cybersecurity process and approach. A gap analysis is instrumental in documenting controls, primarily conducted by an RP who has had CMMC-AB training.
#1. You don’t have enough documentation.
Process paperwork and management are becoming increasingly critical as IT and compliance gets more complicated.
You could have a great technical implementation, but if you don’t have the rules and procedures to back it up, you’ll struggle to satisfy other CMMC goals, such as completely controlling incident response and configuration management. Controlling and recording future changes to your organization’s cyber ecosystem is also greatly hampered by a lack of documentation for present policies and procedures.
Documentation is beneficial in CMMC preparation, particularly during the Gap Analysis phase. This will very certainly be a significant element of remediation if you don’t currently have enough documentation for all rules and procedures.
During the CMMC Assessment phase, having adequate policies and processes is also critical for reaching CMMC Level 3 and higher. At this stage, each control must be validated using two of the three methods of admissible proof (interview, testing, or observation); documentation will be necessary.
To pass CMMC Level 3, all documentation procedures must be deployed and matured, indicating that they are already an efficient and established element of your organization’s compliance strategy.
#2. Your cybersecurity strategy isn’t integrated into your company’s overall strategy.
If you’re a small business, information security may have always been an afterthought, but it’s one of the most apparent and toughest gaps to overcome. It may not even be mentioned as a separate line item in the budget but somewhat under IT. IT and cybersecurity, unlike other operational and legal expenditures, are frequently overlooked.
Plans of Action and Milestones (POA&M) are no longer an option for passing an audit. CMMC will now demand extra time and effort and additional financing from the Defense Industrial Base. Information security should become an elevated line item in 2021 and beyond, if not because of necessity.
Valuing cybersecurity has several benefits, including enhanced security culture and behavior, increased compliance changes, and a decreased risk of losing DoD contracts or contractual agreements.
#3. You rely on the National Institute of Standards and Technology’s 800-171 standard.
If your firm is already compliant with NIST 800-171, you may be tempted to skip the gap analysis and jump right to CMMC DFARS compliance. However, if you’re going for Level 3 or above, you should spend more time reviewing your controls because there’s more to examine before your CMMC assessment.
Being NIST 800-171 compliant is a good start, but it might not be enough for CMMC compliance.
CMMC Level 3 adds 20 Delta standards and the need for maturity to the 110 controls in NIST 800-171. That means you’ll need clearly-defined rules, processes, plans, budgets, role and responsibility documentation, and evidence that you’ve followed them. This necessitates documentation, upkeep, and tracking capabilities, which are not covered by just following NIST 800-171.