What Do CMMC Compliance Services Provide? How Can You Choose the Right Provider?

Quick Answer: A CMMC provider helps defense contractors achieve and maintain compliance through gap analysis, remediation planning, SSP development, POA&M management and ongoing monitoring, so you can bid on DoD contracts with confidence.

Government contracts tend to be highly lucrative, making competition fierce. The phased implementation of the Cybersecurity Maturity Model Certification 2.0 (CMMC) by the U.S. Department of Defense has become a prerequisite for bidding on defense projects. While not every government contract requires CMMC certification quite yet, cybersecurity readiness may be the deciding factor.

There’s no reason to lose a Defense Dept. bid to a competitor when CMMC compliance services are available. At Red River, we provide comprehensive CMMC consulting services that prepare military contractors and supply chain enterprises. These are ways a CMMC provider can help tip the scales in your favor right now.

Key CMMC Compliance Services

The Defense Dept. allows companies two compliance tracts. Outfits that fall under Level 1 and some Level 2 guidelines can self-attest to meeting the standards. After following the rigorous testing protocols, the result must be filed with the federal government. Conducting an in-house examination is no cake walk. It typically prompts business leaders to enlist the support of a Registered Provider Organization (RPO) or a Certified Third-Party Assessment Organization (C3PAO). That’s largely because failing a test leaves you on the outside of the industry.

By that same token, many Level 2 and all Level 3 corporations must undergo an audit by a neutral C3PAO. Preparing for that stringent assessment necessitates bringing in an RPO to perform the following CMMC compliance services.

Gap Analysis

A gap analysis is a commonly used strategy that compares the current state of an operation’s systems efficiency and cyber-hygiene to where it needs to be to maximize its potential. In the context of CMMC compliance, a digital network must adhere to the mandated security and data protection requirements for controlled unclassified information (CUI).

Evidence is collected through methods such as penetration testing and a full review of cybersecurity policy and best practices is conducted. These and other elements, are weighed against the real-life implementation by personnel. Gaps between policy and practice, as well as cyber-hygiene shortfalls, are identified and compiled in a report. The final report serves as a roadmap to craft a remediation plan.

Remediation Planning

Remediation planning involves addressing the cybersecurity shortcomings identified in the gap analysis report. Typically, a CMMC consulting firm works with the leadership team to develop a plan to meet the Defense Department mandate. The process includes updating firewalls, integrating multi-factor authentication, ensuring encrypted CUI transfers, rewriting policies, training staff members and meeting the NIST SP 800-171 and NIST SP 800-172 thresholds. Depending on the efforts required to pass a CMMC compliance audit, creating and implementing a remediation plan can sometimes take upwards of 12 months.

System Security Plan (SSP)

Considered a living, evolving CMMC compliance document, an SSP outlines how an organization goes about protecting its CUI. Following more than 110 NIST controls and enhancements, it adds definition to every aspect of data protection. Items found in a valid SSP identify how CUI is stored, handled, transferred and the designated personnel who enjoy access. A well thought out SSP highlights the flow of digital information and critical assets.

It’s important to have a CMMC provider conduct regular reviews and update the SSP. Nation-state hackers and other advanced persistent threats continue to develop new and innovative schemes to steal America’s military defense secrets. An experienced CMMC consulting firm stays abreast of emerging threats, relays them to industry leaders and assists with appropriate cybersecurity augmentation.

Plan of Action & Milestones (POA&M)

One of the benefits of working with an experienced CMMC provider is avoiding having to deal with a POA&M altogether. Plan of Action & Milestones are official documents that show an organization has missed the mark. If approved by the Department of Defense, an enterprise has a maximum of 180 days to cure its cybersecurity deficiencies.

The plan of action provides details regarding how the non-compliant issues will be addressed. It’s also imperative to understand that high-level security measures, designed to insulate CUI, are normally excluded from a POA&M grace period.

If a vulnerability even cracks the door to a data breach by an advanced persistent threat actor, the federal government will likely reject a POA&M. If you didn’t generate a sufficient score on a CMMC audit or have a handful of outstanding, low-level issues to tidy up, reach out for CMMC compliance services immediately.

Ongoing Monitoring

Threat actors relentlessly target military contractors and organizations that work in the supply chain. Rogue nations and sophisticated hacking gangs view American operations as high-value targets. Whether they want to sell national security secrets on the black market or look for ways to undermine our country, the cyberattacks never stop. That’s why CMMC compliance services must include ongoing monitoring, such as the following.

• Security Assessments: Networks must be periodically audited to ensure systems and access control integrity.
• Threat Detection: The use of Security Information and Event Management (SIEM) tools, AI, machine learning and real-time detection alerts truncates the time hackers have to pilfer off CUI and sensitive materials.
• Threat Hunting: A proactive CMMC provider doesn’t subscribe to the respond-to-attacks model. In keeping with the Defense Department’s mandate, cybersecurity professionals flip the script by targeting online criminals.
• Vulnerability Remediation: The data culled from effective systems monitoring helps cybersecurity professionals identify and close security gaps on a regular basis.

Decision-makers need to be cognizant of the fact that America’s adversaries and garden-variety criminals can launch an attack from anywhere on the planet. Their hours of business are not 9 to 5. Ongoing monitoring keeps digital assets such as CUI safe, allowing company leaders to sleep restfully at night.

Registered Provider Organization (RPO) versus Certified Third-Party Assessment Organization (C3PAO)

Military contractors and outfits that work in the defense industrial base will likely require the CMMC compliance services of both an RPO and C3PAO. The reason organizations often need both is due to the differences each CMMC provider delivers.

What is a CMMC Registered Provider Organization (RPO)?

An RPO earns its accreditation from the Cyber AB, based in Maryland. This non-profit organization serves as the sole accreditation body for cybersecurity firms that provide these CMMC compliance services.

Gaining Cyber AB certification allows an RPO to provide CMMC consulting in preparation for testing. These are ways an RPO helps an enterprise address its cybersecurity weaknesses.

• Create A System Security Plan (SSP)
• A CMMC Registered Provider Organization
• Develop Plans of Action & Milestones (POA&Ms)
• Provide Remediation Solutions
• Implementation of NIST Controls

A CMMC RPO usually conducts pre-assessment audits to gauge whether the network defenses meet the standards established by the mandate. Once an operation appears ready, a formal audit is scheduled with a C3PAO.

What is a C3PAO?

A Certified Third-Party Assessor Organization (C3PAO) can also earn its accreditation from Cyber AB. Its designation goes further than an RPO, giving it the authority to conduct impartial CMMC audits and file the results with the federal government. An authorized C3PAO determines the CMMC level required by the company to store and transmit CUI. Based on the CMMC level, a comprehensive audit is conducted to ensure all of the appropriate protections and controls are in place. These are fine details involved in a CMMC audit.

• Preparation: Analyze and assess documented policies and procedures of the System Security Plan. Verify that these measures have been adopted.
• Performing Assessments: The CMMC assessment process includes conducting interviews and vetting digital security measures. A C3PAO may also verify that the organization possesses adequate physical security.
• CMMC Certification: The C3PAO submits its findings to the Defense Contract Management Agency’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) for final approval.

RPO & C3PAO Limitations

Allowing the same CMMC consulting firm to deliver RPO and C3PAO services would be an inherent conflict of interest. That’s a primary reason why the Defense Dept. precludes a CMMC provider from handling the preparation and official audit. This is not to say that an experienced cybersecurity firm cannot earn both RPO and C3PAO credentials. Industry-leading organizations may offer both of these as-needed CMMC services.

How to Choose a CMMC Provider

When selecting a CMMC provider, it’s essential to verify that the firm enjoys Cyber AB accreditation. You can determine whether they are a credentialed CMMC provider by searching the Cyber AB Marketplace. The platform lists RPOs and C3PAOs.

Other metrics worth considering include years of experience in cybersecurity and length of time serving as a CMMC compliance services provider. As many organizations are well aware, CMMC has gone through a variety of evolutions. The current CMMC 2.0 version has three levels, while the initial mandate had five. Understanding the subtle differences among Level 2 candidates remains an important factor in terms of knowing whether to onboard an RPO and self-attest or schedule a C3PAO. The answers to the following questions will help you make an informed decision.

• Does the cybersecurity firm have a proven track record of CMMC compliance services success?
• Have RPO clients passed audits on the first attempt, did they fail or was a 180-day POA&M required?
• Does the cybersecurity firm provide ongoing monitoring?
• What credentials do its staff members possess?
• Do you see the firm being a seamless fit for your workplace culture?

Don’t hesitate to ask for references and information that allows you to better understand who you will have as a CMMC consulting or auditing resource. After all, gaining certification is required to bid on upcoming government contracts. One misstep could sideline your organization.

Beware of Red Flags

Regardless of how enthusiastic someone is about preparing your system, what they don’t know can hurt your bottom line. That’s why lack of experience and accreditation are non-starters when it comes time to enlist a CMMC consultant. Participating in a government contract provides a significant revenue stream. These rank among the commonly reported red flags in the CMMC compliance services niche.

• Missing Credentials: Not being listed on the Cyber AB website.
• In-Process Claims: Some vendors may get ahead of themselves by assuring clients they are almost certified. That statement indicates a lack of experience, patience and professionalism.
• Conflicts of Interest: If a certified third party says they can operate as your RPO and C3PAO, something is definitely amiss. Such conflicts of interest are not allowed by the Department of Defense.
• Guarantees: Having someone say you will definitely pass the CMMC audit is a false guarantee. The CMMC compliance readiness process and assessment are highly complex. An experienced, fully credentialed CMMC firm gives you the best chance of passing.
• Partial Solutions: The CMMC mandate is an intensely involved and surgically specific program. Outfits that have not yet acquired the knowledge and skills to craft and implement a compliance plan of action often fall short. Being 90 percent in compliance won’t pass muster.

Don’t be taken in by weird requests, such as having access to your CUI files. There’s no legitimate reason for an outsider to see sensitive national security information. A CMMC provider is only there to help protect it.

Contact Red River for CMMC Compliance Services

At Red River, we recognize the challenges involved in becoming CMMC 2.0 compliant and passing an audit. Our experienced team of professionals has earned RPO and C3PAO accreditation from Cyber AB.

We work diligently to craft the determined cybersecurity protocols needed to detect, deter and expel threat actors and meet the standards established by CMMC. The cybersecurity experts at Red River are available to bring your organization into compliance before you miss CMMC deadlines. Contact us today by calling or filling out our online form. Let’s get the process started!