Cybersecurity Maturity Model Certification (CMMC)
Burlington and other Vermont 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 Vermont
Vermont CMMC Services
Many Vermont 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)
