Understanding the Cybersecurity Maturity Model Certification (CMMC) Framework

Introduction to CMMC

The Cybersecurity Maturity Model Certification (CMMC) framework is a standard developed by the Department of Defense (DoD) to evaluate the security capabilities of federal contractors. Specifically, CMMC aims to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) handled by these contractors. With the DoD estimating that contractors manage up to 70% of CUI or FCI, ensuring robust security measures is crucial for national security.

What are CUI and FCI?

Controlled Unclassified Information (CUI) refers to unclassified information that requires security controls to prevent unauthorized dissemination. Although CUI does not typically contain proprietary information or intellectual property, it is vital for the operation of government agencies. Hackers often target CUI to gain insights into defense capabilities or other sensitive data.

Federal Contract Information (FCI) is similar to CUI but covers a broader range of documents not intended for public release. These documents are part of a contractual relationship between a provider and a government agency.

Certification Levels for CMMC

CMMC derives its requirements from existing federal security documents, including NIST 800-171 and 48 CFR 52.204-1. The framework breaks down areas of concern into domains, capabilities, practices, and processes:

Domains: Broad categories covering large impact areas, such as Access Control and Audit and Accountability. There are 17 domains in total.
Capabilities: Each domain has a set of capabilities that a contractor must accomplish, such as establishing system access requirements or conducting security awareness activities.
Practices and Processes: Each capability comprises specific practices and processes that must be in place to protect CUI and FCI.

The CMMC certification is divided into three levels, each corresponding to the number of domains and capabilities a contractor must demonstrate:

Level 1: Implementation of basic cybersecurity controls from NIST Special Publication 800-171 (15 controls in total).
Level 2: The base minimum for handling CUI, requiring the implementation of all 110 controls.
Level 3: Encompasses 134 controls from both NIST SP 800-171 and NIST SP 800-172, with more stringent auditing requirements for advanced threats like Advanced Persistent Threats (APTs).

What is a C3PAO?

Similar to FedRAMP, CMMC requires a Third-Party Assessment Organization (C3PAO) to handle assessments and audits for providers. The assessment process is designed to give the government a clear picture of a provider’s security capabilities. Key terms related to C3PAOs include:

3PAO: An organization certified to audit providers for CMMC compliance.
Certified Professional (CP): A security professional who participates in CMMC assessments, usually as part of a team under an experienced assessor.
Certified Assessor (CA): Conducts and manages assessments and supervises CPs. Both CAs and CPs are part of C3PAO businesses.

Synergies Between CMMC and FedRAMP

FedRAMP certification and CMMC are both part of the federal compliance landscape. While they utilize several NIST documents as the basis for their compliance demands, they do not map onto each other directly. FedRAMP regulates government cloud providers by ranking their security requirements as Low, Medium, and High, determined by the type of data handled.

The DoD has indicated plans to offer reciprocity between CMMC and FedRAMP, allowing cloud providers undergoing rigorous audits in one framework to have a path to working with agencies in both defense and non-defense communities. For example, a cloud provider handling CUI would require a Moderate ranking in FedRAMP, which corresponds to Level 3 in CMMC.

Conclusion

CMMC is an emerging framework that will become essential for IT companies and cloud providers intending to work with agencies under the DoD. It could open doors for companies looking to expand their potential pool of government agencies within the DoD. With potential synergies with FedRAMP, many cloud providers will be able to serve agencies across various levels of government.

For more information about CMMC, FedRAMP, or working with a 3PAO or C3PAO, you can visit the official DoD CMMC website.