Cybersecurity Maturity Model Certification (CMMC)
Honolulu and Hawaii Department of Defense (DoD) contractors and subcontractors will soon be required to comply with the new Cybersecurity Maturity Model Certification (CMMC) 2.0 requirements. The CMMC program is intended to better enforce cybersecurity requirements across the defense industrial base (DIB) to better protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
Three CMMC Maturity Levels (ML)
Once implemented, DoD contract solicitations will indicate the required maturity level for the winning contractor. If a contractor does not have the appropriate certification in the DoD’s Supplier Performance Risk System (SPRS), then the contractor will be ineligible for contract award.
CMMC Level 1 will be added to contracts where FCI only will be received or generated by the contractor. Level 1 will require organizations to annually self-assess and affirm their compliance with the 17 Level 1 practice requirements, which are composed of 59 assessment objectives.
CMMC Level 2 requires a triennial third-party assessment and annual affirmation of compliance with 110 practice requirements, which are composed of 320 assessment objectives. Level 2 also expands the type of information system assets that are in scope for assessment, compared to Level 1.
CMMC Level 3 requires an existing Level 2 certification, and contractors will be assessed by the DoD for compliance against an additional 24 practice requirements. Level 3 also expands the type of information system assets that are in scope for assessment, compared to Level 2.
Readiness Preparation
By most estimates, organizations are likely to require 12-18 months to prepare for a Level 2 assessment. With the CMMC final rule likely taking effect during the first half of 2025, Washington DC DoD contractors who wish to participate on new DoD contracts should start preparing as soon as possible.
Map of Hawaii
Hawaii CMMC Services
Many Hawaii DoD contractors will need assistance performing initial assessments to uncover issues, establish corrective actions, and chart a path toward CMMC readiness.
The CMMC is complex. ML 3 contains 381 discrete cybersecurity requirements spread among 130 practices, and 310 policy/procedure requirements spread among 51 process maturity requirements. The requirements are complex, and our team has almost 20 years of experience providing cybersecurity compliance services across many complex frameworks such as NIST SP 800-171, NIST SP 800-53, HIPAA, and others. As a CMMC Registered Provider Organization (RPO), our team can help DoD prime and subcontractors with the following:
- Readiness Assessments and Gap Analyses Against the CMMC Framework
- Assistance with Remediating Gaps Identified during Readiness Assessment
- Assistance with NIST SIP 800-171 Self-Assessment that is recorded in the Supplier Performance Risk System
- Creating System Security Plans (SSP)
- Creating Plans of Action and Milestones (POA&M)
Hawaii’s defense contractor industry plays a unique and strategically crucial role in the United States’ defense posture, particularly due to the state’s pivotal location in the Pacific. The industry supports a wide range of military operations, from cybersecurity and information technology to logistics, construction, and maintenance of military facilities, reflecting the diverse needs of the numerous military installations spread across the islands, including Pearl Harbor, Hickam Air Force Base, and Schofield Barracks. Hawaii’s defense contractors are integral to the U.S. military’s readiness and operational capabilities in the Asia-Pacific region, providing essential services that facilitate the projection of American power and ensure the security of maritime routes. In 2021, Hawaii saw significant defense spending directed towards local contractors, with Hensel Phelps Construction Co. receiving a notable contract for $212.7 million, underscoring the importance of construction and infrastructure development in supporting the military’s presence. Beyond the immediate contributions to national security, the defense contractor industry in Hawaii also plays a significant economic role, creating jobs, fostering local businesses, and contributing to the islands’ economic diversity. The symbiotic relationship between the military and local contractors not only enhances the state’s strategic importance but also bolsters its economic resilience, making the defense contractor industry a key pillar of Hawaii’s economy and a critical component of the United States’ defense strategy in the Pacific.