What Is Cmmc, Know About Its Domains & Checkpoints

By Author: Rishu Ranjan
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CMMC stands for Cybersecurity Maturity Model Certification and it applies to contractors and subcontractors of the US Department of Defense. It was published in 2020 and for the next five years, the CMMC is scheduled to be implemented gradually. Bidding on DoD contracts will be governed by CMMC requirements. Defense contracts will require contractors and subcontractors to comply with the CMMC requirement.
As RFPs continue to be issued by the DoD, CMMC compliance levels are likely to appear more and more. Another US federal department will adopt CMMC in the future as a best-practice standard for contractors in cyber security. Compliance should be a priority for organizations. With a detailed breakdown of each of the 17 domains of CMMC compliance, this checklist can be used to prepare contractors for CMMC compliance.

Checkpoint 1: Identify FCIs and CUIs
Understanding the types of government data your business may handle is the first step. CMMC compliance requirements will vary based on the type of data being processed. Your organization and your systems will need to meet a variety of security controls ...
... based on this.
The two most common types of government data contractors will deal with are Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). Government contractors are required to provide FCI to customers as part of their service and product delivery, but this information isn't intended for general public consumption. CMMC Level 1 requirements apply for FCI.
CUI refers to sensitive but non-classified government data. A government agency provides lists of CUIs, which, for example, contain technical data or patent information. CMMC level 3 compliance is required for CUI. Compliance with CMMC compliance is high for highly sensitive, classified, and critical data and services.

Checkpoint 2: Conduct a network scoping exercise
You will need to identify the parts of the network that process CUI and FCI data within your organization once you have identified the CUI and FCI data within the organization. Locate the components in the system responsible for storing and processing these data. Document the areas that process CUI or FCI data by drawing a diagram of the network and systems. Additionally, your organization may have a network of subcontractors if it is a prime contractor.
Outlining the boundaries of CMMC compliance relies on scoping the relevant system sections. An organization can limit the scope of compliance assessment by identifying the systems that process CUI. Rather than assessing the entire system, compliance assessment focuses on relevant parts of the network.
In this way, you can keep CUI separate and secure within your systems and minimize the resources required to meet CMMC compliance. The use of control access and partitioning can also help reduce the scope of assessment in some parts of the network.

Checkpoint 3: Find out what level of CMMC you require
CMMC has different levels of compliance based on the level of risk posed by the data that a DIB entity is processing, storing, creating, or managing. These risk levels are categorized by the CMMC. Requests for Proposals (RFPs) from the Department of Defense will outline the required CMMC level.
Compliance with CMMC Level 1 will be required for organizations that handle federal contract data. CUI (Controlled Unclassified Information) will require CMMC Level 3 compliance for organizations that store it or process it. The NIST 800-171 standard, designed to guard nonfederal systems against CUI, includes all the requirements for this level of protection.
CMMC Level 5 requirements must be met by organizations handling extremely sensitive or classified information or data. At the most comprehensive level, CMMC identifies 171 practices that are based on CIS controls and other standards such as NIST 800-171.
NIST 800-172 is a supplement to NIST 800-171, which was published by NIST in 2021. CUI was to be protected by strict security requirements in nonfederal systems. CMMC Level 5 certification requires the understanding of high-level requirements and security controls presented in NIST 800-172.

Checkpoint 4: Perform compliance gap analysis
CMMC assessments are best prepared with a clear understanding of your current compliance level. CMMC certification can be achieved by testing compliance gaps. CMMC security practices are effective at identifying gaps in network and system vulnerability scanning.
By conducting a gap analysis organizations can develop a Plan of Action with Milestones (POAM), which is an important step in planning projects. Defined milestones allow process improvement and reallocate resources. DIB organizations need to formulate and complete a compliance plan to meet compliance standards to be certified and execute DoD contracts. The plan must be completed before the official CMMC compliance assessment by a Certified Third Party Assessment Organization (C3PAO).
Security practices are outlined at every CMMC level, outlining the policies and processes that must be followed to ensure compliance. Gap analyses can be based on these practices. An organization must meet the requirements in each level of CMMC compliance before it can reach a certain level.
• There are 17 security practices in CMMC Level 1
• This brings the total to 72 security practices with CMMC Level 2 by 55 more.
• With 58 new security practices added to CMMC Level 3, the number now stands at 130
• With the addition of 26 new security practices to CMMC Level 4, it now has 156
• There are 171 security practices listed in CMMC Level 5, up 15 from Level 4.

Checkpoint 5: Make a plan for your project
Documentation and findings should be consolidated in a project plan. CMMC Level compliance is outlined in a clear outline in this document. Establishing milestones along the way will make the process easier to follow. Among the project plan's components are:
• Assessing the scope and boundaries of the system
• Measurement and implementation team
• Compliance with CMMC level requirements
• CMMC compliance gap audit findings
• Resources and timeline estimated
• Clear deadlines for completion of the project

Checkpoint 6: Establish a System Security Plan (SSP)
CMMC compliance at the higher levels requires an SSP (System Security Plan). CUI or other government data is processed and stored as a result of this document. SSPs are required for CMMC Level 2 and above because cybersecurity processes are documented at this point.
Every organization contemplating CMMC compliance should develop or refine an SSP. Keeping it up to date should be considered a regular process.

Checkpoint 7: Make the right resource allocations
Taking a look at cybersecurity resilience and updating it will require a lot of resources. Different areas of the organization will be affected by the requirements. Besides deploying new hardware and software, improvements will also encompass cybersecurity training and policy formulation.
DoD contractors must comply with CMMC for FCI and CUI contracts.
The compliance project should have the appropriate level of resources. Throughout the process, it is likely to require the most resources at first. It takes time, effort, and resources to review and renew controls and system security.
Establish a team of staff with budgets to cover security scans, outsourced advice, or policy and procedure revisions. Assessment of internal resources and expertise is critical for optimizing compliance, as external support and resources may be needed.

Checkpoint 8: Checklist for the CMMC Domain
A range of security practices is included in each of CMMC's 17 domains or areas. The following checklist provides a basic understanding of each domain for organizations.
1. Authentication
• Defining network and system access rules for users.
• Update records of who is authorized to use which systems.
2. Managing assets
• Take inventory of all technology, hardware, and software in the system.
• Record procedures for archiving data and destroying it.
3. Accountability and auditing
• Track user actions and data, including timestamps, in logs.
• Ensure the CUI and assets are logged after every session.
4. Train and Educate
• Train everyone in the organization on cybersecurity.
• Match training to an employee's role and interaction with CUI systems.
5. Managing configurations
• Improve cybersecurity resilience by embedding baseline device configurations.
• Map the devices and systems that handle CUI.
6. Validation and Identification
• Users, devices, and processes are uniquely identified through embedded systems.
• Establish a minimum level of password complexity for user identification.
7. Incidence Response
• Detect and eliminate threats to CUI by creating an incident response plan.
• Train employee response to potentially serious incidents.
8. Upkeep
• Make sure that systems, hardware, and devices are regularly inspected and maintained.
• Document software, hardware, and firmware updates.
9. Protecting media
• Implement a policy for managing and destroying sensitive media.
• Record sensitive data on all media.
10. Security of employees
• CUI access should be screened for all personnel.
• Complete background checks for all new hires.
11. Protection against physical harm
• Maintain a list of building and server access rights.
• Protect sensitive areas of the organization, including servers and hardware.
12. Recovering
• Set up an automated system backup schedule.
• Test backups periodically.
13. Managing risks
• Build a risk management plan and embed it into your business processes.
• Identify vulnerabilities and risks in networks and systems.
14. Assessing security risks
• Identify new vulnerabilities by auditing security measures regularly.
• Adapt security measures as threats emerge.
15. Sense of Situation
• Processes to alert the system to new threats.
• Be aware of external threats related to cybersecurity.
16. Communications and System Protection
• Establish clear boundaries between networks, including cloud-based systems.
• Make sure endpoints are secure.
17. Integrity of information and systems
• Stay up-to-date and patch your network components.
• Update software and hardware regularly.

Final Checkpoint: Obtain Certification
CMMC is not self-assessed, unlike other NIST standards. A C3PAO, an accredited third-party assessor, confirms an organization's CMMC compliance through an audit.
CMMC level compliance is assessed by a third-party evaluation organization. The CMMC Accreditation Body issues a three-year certification once the accreditation is complete. It will be a requirement for contractors to prove compliance with the CMMC before awarding contracts.
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