Use This CMMC Compliance Checklist to See if You’re Compliant
The Cybersecurity Maturity Model Certification (CMMC) is a unified standard for implementing cybersecurity across the defense industry supply chain. The CMMC framework was created by the Department of Defense (DoD) to ensure that all contractors and subcontractors who handle Controlled Unclassified Information (CUI) are compliant with specific security requirements.
As a contractor or subcontractor working with the DoD, compliance with CMMC is necessary to bid on and win contracts. This checklist will help you determine if your organization is compliant with the required CMMC level for your specific contract.
Determine Your Required CMMC Level
The first step in determining your compliance is to understand which level of CMMC certification is required for your specific contract. There are five levels of CMMC, each with increasing security requirements. Your organization’s required level will be specified in the Request for Proposal (RFP) or contract. Determine the type of Controlled Unclassified Information or Federal Contract Information you handle. This includes identifying the data and systems involved in the contract.
Review the requirements: Familiarize yourself with the different levels and their associated requirements. The CMMC framework outlines five levels ranging from basic cybersecurity hygiene to advanced practices.
Conduct a Gap Analysis
Once you know your required CMMC level, conduct a thorough gap analysis to determine where your organization currently stands in terms of compliance. This involves comparing your current security practices with the requirements outlined in the CMMC framework. Regularly monitor and review your progress in closing the identified gaps. Track and document your efforts to demonstrate compliance with the CMMC requirements. Conduct internal audits and assessments to ensure ongoing adherence to the desired level of cybersecurity maturity.
Implement Necessary Controls
Based on your gap analysis, identify any gaps or deficiencies and implement the necessary controls to meet the required CMMC level. This may involve implementing new policies, procedures, or technologies. Maintain accurate and up-to-date documentation of your cybersecurity practices, policies, procedures, and compliance efforts. This includes recording incident response activities, risk assessments, training records, and ongoing monitoring activities.
Conduct a Self-Assessment
After implementing necessary controls, conduct a self-assessment to determine if your organization meets the required CMMC level. This is an opportunity to identify any remaining gaps and make necessary adjustments before seeking third-party certification. An example may be Establishing a schedule for conducting periodic self-assessments to monitor and validate your organization’s continued compliance with the CMMC requirements. This will help identify any new gaps or areas that may require further improvement. Another would be keeping detailed records of your self-assessment activities, including the findings, remediation actions taken, and evidence of compliance. These records will support future audits and demonstrate ongoing adherence to the CMMC level achieved.
Obtain Third-Party Certification
The final step in determining compliance with CMMC is obtaining third-party certification. This involves a comprehensive assessment by an accredited assessor who will verify that your organization meets the required CMMC level.
Compliance with CMMC is necessary for any contractor or subcontractor working with the DoD. By following this checklist, you can ensure that your organization is prepared to bid on and win contracts by meeting the required CMMC level. Keep in mind that compliance is an ongoing process, so it’s important to continuously monitor and update your security practices to maintain compliance.