Three Steps to CMMC 2.0 Implementation

ABS Quality Evaluations

Cybersecurity is no longer a catchy buzzword; it's an integral part of your business operations. Cybercrime is not going anywhere any time soon and is expected to continue to rise across all industries. The time to begin your path to CMMC 2.0 compliance is now. Who you choose to assess your organization's compliance is equally as important as which level your organization is required to comply to. When it comes to cybersecurity, if the "worm" in question is your information, you need to stay ahead of the "early bird."

What is the ABS-QE CMMC 2.0 Pathway To Success

There is no one pathway to achieving compliance to CMMC 2.0. Our team of auditors and assessors take this into consideration as we choose not to take a cookie cutter approach when we conduct audits or gap assessments. We choose to partner with our clients and tailor our offerings to their respective and distinct needs. 

With the many variables at play from: the amount of controls, the level of controlled unclassified information (CUI) to the time that it takes to achieve compliance, there is no 'one way' to achieve compliance. Many auditors and certification bodies choose to take a check-the-box approach, providing minimal insight to the client that is being certified. 

From personal account numbers to sensitive information created and processed in industry and the federal government, we all have an ongoing and vested interest in keeping our secrets safe. With that in mind, imagine all of the critical and private information created and used by our government and the consequences of failing to keep that information secure.

To that end, the Cybersecurity Maturity Model Certification (CMMC) program, managed by the Department of Defense (DoD), ensures security contractors in the Defense Industrial Base (DIB) can adequately defend information assets against pitfalls created by information security threats, vulnerabilities and bad actors. In essence, the job of CMMC is simple – protect critical information! While some people use terms like Military Grade Security, the ultimate goal is to protect our assets, prepare for information security continuity during adverse situations or disasters and prevent security breaches and data compromise.

How Should You Get Started? Establish Your CMMC Compliance Timeline. 

As a maturity model, CMMC allows companies to start with the controls they have in place and build more robust programs by adding more controls and processes. Managing your timeline during this ongoing process will be key to your success as you compete for DoD contracts in the future. 

1. Nail down what information you have. Start by determining the appropriate CMMC level. Don’t short-change yourself. You may only need Level 1 compliance now, but two years down the road, you may win a contract requiring Level 2 compliance via a third-party assessment.
2. Stay informed and updated regarding all CMMC program updates.
3. Implement controls IAW with the appropriate assessment guide and NIST Special Publications.
4. Develop adequate documentation as evidence of control implementation.
5. Assess posture (self-assessment or third-party gap/readiness assessment).
6. Create Plan of Action and Milestones (POA&M) for deficiencies.
7. Enter score in Supplier Performance Risk System (SPRS).
8. Contract with a Certified Third-Party Assessor Organization (C3PAO) for a Joint Surveillance Voluntary Assessment Program (JSVAP).
9. Meet all requirements and receive a Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) High certification, which will automatically turn into a 3-year Level 2 CMMC certification.

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