CMMC 2.0 Framework: 7 Steps Your Business Should Take to Prepare
In November of 2021, the CMMC dramatically changed. The CMMC 2.0 framework differs substantially from the original CMMC 1.0 requirements, with CMMC 2.0 levels and CMMC 2.0 controls being altered. CMMC 2.0 Level 3 (formerly level 5) requirements have still not been set in stone. So, with that in mind, what should businesses like yours do to prepare for CMMC compliance?
Let’s take a look.
What is CMMC 2.0?
You may be aware that organizations had five years to meet CMMC 1.0 compliance restrictions. CMMC 1.0 was designed to help government contractors achieve better security—and ensure that they did so. To work with different levels of data, government contractors had to achieve different levels of compliance. There were five full levels, with Level 1 compliance being what was needed to work with non-classified information. CMMC 2.0 is a dramatic revamp of the CMMC compliance initiative, cutting down the levels to 3 and modifying each level.
1. Learn More About the CMMC 2.0 Framework
The CMMC 2.0 framework has only recently been released. Many organizations are stumbling to learn more about it, what their requirements will be and what they need to do next. On the whole, Level 1 compliance is easier to achieve and Level 2 (formerly Level 3) compliance is fairly clear. Level 3 (formerly Level 5) compliance requirements may still change. You should determine which level of compliance your organization will need to have and the steps that you would need to take to achieve it.
2. Consult a Professional Partner
CMMC compliance is vital to the way that many companies work. So, it’s in your best interest to consult with a professional partner regarding your CMMC compliance initiatives. The benefits of working with a partner are two-fold. First, the partner will be able to track the ever-changing requirements of the compliance program. Second, the partner will be able to help you move toward these new regulations with minimal disruption, devoting their time to the process so your organization can continue to work unhindered.
3. Complete a System-Wide Audit
You can’t begin to initialize changes if you don’t know where you’re starting from. A system-wide audit is necessary to determine where the gaps in your current security measures and documentation are. A system-wide audit should be conducted by a third party, as it’s too easy for an internal party to overlook certain elements. A comprehensive, system-wide audit isn’t just necessary for CMMC compliance, but can also be part of your overall security and privacy processes.
4. Identify Gaps and Areas of Improvement
Utilizing the known CMMC requirements and your current gaps, try to move toward the CMMC requirements—which can be easier said than done. Once the audit is completed, you should be able to identify areas of improvements and create a game plan. In a large company, this may need to be done in a tiered, iterative system, rather than making all the changes at once.
This is one of the boons of the CMMC system. Companies will have months to make changes to their system, which is why it’s so critical that they start making these changes now. By beginning their CMMC transition today, companies are able to create a smooth, non-disruptive shift in infrastructure.
5. Get Employees On Board
Top-down buy-in will be required from upper management to lower-level staff. The entire company should understand the new CMMC requirements and why they are important; this is necessary for a successful shift. When it comes to security and privacy methods, these methodologies impact the entire company. When the entire company isn’t on-board and understanding, they become disruptive.
Ideally, security and privacy measures should be as non-disruptive as possible if they are to be followed. But new requirements such as the CMMC also come with large volumes of new documentation and processes, precisely the things that employees, supervisors and even management have a tendency to resist if they don’t understand the basis for it.
As you work your CMMC 2.0 framework and CMMC 2.0 controls into the infrastructure of your business, make sure employees understand the “why” of the “what.”
6. Look for Other Areas of Improvement
At its core, the CMMC is intended to improve privacy and security to levels necessary to work with government data. This is understandable; the past few years have included many high-profile (and successful) attacks on government agencies. But the work of privacy and security isn’t done just because an organization is in compliance.
As you audit your organization for CMMC compliance, you should also be considering other areas in which your organization can improve. Consult with your internal IT team and your managed service providers. Look to security methods and philosophies that your organization could use to further shore up its security.
No company has ever regretted being too secure. Companies are undergoing more security attacks than ever before and need to be able to protect themselves. A managed services provider can help you dig deep into your security, systems and technology, to find the best methods of controlling and protecting your data.
7. Be Ready to Pivot
Organizations have until 2025 to ultimately achieve CMMC compliance. Better yet, organizations should be able to go through the CMMC process and improve upon their compliance measures to achieve the level that they want; they will be given time to make changes and adjustments. But organizations also need to remain agile and ready to adjust, as the requirements may change and standards may be misunderstood, given the fast-paced nature of the new regulations.
It’s not likely that there will be tremendous adjustments to Level 3 compliance; it’s more likely that there are just some small details that are yet to be locked down. But companies are going to need to remain agile in the future regardless, as the types of security threats that we’re seeing are changing from year to year.
If your organization is concerned about the new CMMC 2.0 framework, it’s time to contact a professional. At Red River, we can help you work toward the CMMC 2.0 levels you need, figure out the new CMMC 2.0 controls and ultimately establish the level of CMMC 2.0 framework that you need. Contact Red River today to get started.
