What Does a CMMC Audit Consist Of?

In an effort to combat the surge of advanced persistent threats targeting the U.S., organizations working in the military industrial base are tasked with hardening their cybersecurity.

Known as the Cybersecurity Maturity Model Certification (CMMC), direct Department of Defense (DoD) contractors and a wide variety of subcontractors are required to undergo a third-party audit. Recognizing that well-funded hackers, often backed by rogue regimes, have the skills and tools to piece together information from seemingly indirect military supply chain sources, CMMC compliance will be an ongoing mandate impacting upwards of 300,000 organizations.

From small businesses that deliver goods and materials to military installations to related scientific research laboratories, any organization that stores or transmits potentially sensitive information must comply. The alternative would be losing potentially lucrative federal government contracts. That’s why Red River continues to help companies that work with the U.S. Armed Forces prepare for their upcoming CMMC audit.

What is a CMMC Audit?

A CMMC audit involves assessing an organization’s ability to protect specific data. Depending on the type of digital information an operation stores and transmits, it would need to meet one of the three stringent CMMC levels. These are types of data that call for protection under CMMC.

• Federal Contract Information (FCI): Information found in, or related to, government contracts not suitable for public release.
• Controlled Unclassified Information (CUI): Government information stored or transmitted across the military supply chain landscape.
• Controlled Technical Information (CTI): Technical information that has military or space applications.
• International Traffic in Arms Regulations (ITAR) Data: Digital information related to the import or export of items on the United States Munitions List.

During the assessment process, auditors consider an operation’s risk prevention and cybersecurity posture. The audit determines whether an enterprise meets the applicable cybersecurity standards. Companies that fall into the Level 1 category must meet a minimum of 17 protocols. At Level 2, the ante goes up to more than 110 controls. Level 3 outfits are expected to demonstrate the ability to deter, repel and respond to advanced persistent threats.

What Does a CMMC Audit Entail?

It’s mission-critical to promptly begin the CMMC audit process rather than delay and get caught in a logjam of companies rushing to adhere to the mandate. By onboarding a CMMC Third Party Assessment Organization, aka C3PAO, you can stay ahead of the audit curve. These are the steps a third-party firm takes to help companies prepare for a formal CMMC audit and earn certification.

Pre-Assessment Preparations

Sometimes called a “gap analysis,” the process identifies the cracks in your cybersecurity defenses. A necessary step in meeting the CMMC mandate, pre-assessment preparations are considered fundamental to every business. Even garden variety hackers take advantage of seemingly slim cracks.

The Colonial Pipeline hack in 2021 ranks among the headline-grabbing examples. Cybercriminals reportedly infiltrated the company through a VPN that simply lacked multi-factor authentication protection. As a result, gas station pumps ran dry along the Eastern Seaboard and the company was forced to pay out $5 billion in Bitcoin to regain access to its own system. A thorough assessment would have shined a light on this shortcoming.

Documentation Reviews

Documentation reviews may seem cumbersome when an organization possesses robust cyber hygiene. But they serve an essential role in protecting national security. A C3PAO assesses an operation’s written cybersecurity plan to ensure it can repeat best practices over time. Without a comprehensive cybersecurity plan in place, employee turnover and attrition would likely result in lowered defenses. If your organization doesn’t have a written policy, an experienced cybersecurity firm can help you craft one.

Technical Evaluations

The technical evaluation involved in a CMMC audit reviews what industry insiders sometimes call your “authorization boundary.” Considered the most complex part of the process, the organization’s boundaries are broader than business leaders may realize. For example, allowing remote workers to access or transmit CUI from laptops, smart phones or desktops at home expands the authorization boundaries.

In cases where decision-makers allow employees and key stakeholders to log in from devices without endpoint security, the boundary is effectively limitless. In such cases, multi-factor authentication would likely be a CMMC requirement, as well as prudent business practice. It’s also important to keep in mind that technical evaluations explore wide-reaching elements.

Compliance Scoring

The DoD relies on its CMMC database to make decisions based, in part, on a business’s Supplier Performance Risk System (SPRS) score. This compliance score is submitted following a CMMC audit based on the DoD’s Assessment Methodology. Although outfits that fall into Level 1 cyber hygiene may be able to self-assess using the complex regulations, it would be wiser to enlist the help of a C3PAO. That’s because the DoD uses SPRS scores when deciding which companies receive lucrative contracts.

Criteria Assessed by C3PAO

An accredited CMMC auditor conducts a variety of assessments to determine whether an organization’s defensive posture and culture meet the appropriate regulations. The good news for industry leaders who are proactive about the process is that it does not necessarily have to be a pass-fail audit. A C3PAO can provide the following before the official review.

• Data Check: A preliminary determination can be made to identify the type of sensitive information an operation stores or transmits. This helps align the enterprise with the applicable CMMC level.
• Cyber Hygiene: A general review of the organization’s overall cyber resilience is implemented to better articulate its practices and processes. Understanding the current cybersecurity posture defines its ability to protect data.
• Cybersecurity Culture: Human error leads to the vast majority of data breaches. A C3PAO considers the level of cybersecurity awareness and training employees possess. It’s not unusual for a third-party firm to recommend additional cybersecurity education.

The core of a CMMC audit involves understanding and scoring how successfully an operation integrates cybersecurity measures. Once the defenses and culture are brought into compliance, a C3PAO can certify the organization.

Why CMMC Audits are Important

The importance of CMMC audits cannot be understated. As a matter of national security, they ensure the data circulating among military contractors and supply chain entities is well protected. Business owners who undergo the process also gain peace of mind, knowing their profit-driving venture won’t be upended. No one wants to make headline news or suffer the financial losses and tarnished reputation of the Colonial Pipeline. In that sense, knowing you have CMMC-level defenses is a matter of self-preservation.

Contact Red River to Start the CMMC Audit Process

The cybersecurity experts at Red River help businesses in the military industrial base meet the CMMC requirements. If you are concerned about CMMC deadlines or need clarification on your current cybersecurity defenses, call us today or fill out our online contact form. Let’s get the process started!