What Is CMMC?
CMMC 2.0 is the DoD's method for requiring organizations in the DoD supply chain to protect FCI, CUI, and/or ITAR to the appropriate level determined.
Here are a few types of data requiring different levels from CMMC Level 1 to CMMC Level 3:
This page is built as an overview of the following:
- CMMC 1.0 To CMMC 2.0
- Who Is Affected By CMMC 2.0?
- The Three Levels of CMMC
- When will CMMC 2.0 appear in contracts?
- How Does The DIB Prepare For CMMC 2.0?
- Microsoft 365 and CMMC 2.0
- CMMC Industry Events
- CMMC 2.0 Timeline
Level 1: 17 Practices and Self Assessment
- Classified as "Basic" by the DoD
- Requires those who handle Federal Contractor Information (FCI) to meet Level 1
- Contractors must self-attest that they have implemented the requirements
Level One consists of 17 basic cybersecurity practices. The requirement states that all federal contractors must implement these safeguard controls.
Level 2: NIST 800-171 and 3rd Party Assessments
One of the most significant changes from CMMC 1.0 Level 3, now CMMC 2.0 Level 2, relates to the fact that the 130 controls in 1.0 Level 3 now move to 110 controls for 2.0 Level 2.
- CMMC 2.0 Level 2 is for those handling:
- Controlled Unclassified Information (CUI) / Controlled Defense Information
- Controlled Technical Information (CTI)
- ITAR or export-controlled data
- What happens to the additional 20 controls from CMMC 1.0 Level 3?
- Answer: The additional 20 controls in CMMC 2.0 are considered to be "CMMC-unique," meaning that they were original to the first version of CMMC.
- The "Delta 20" controls were removed and are no longer required.
- Depending on the type(s) of information that you handle (CUI/CDI/CTI/ITAR) all organizations will have to prepare for:
You can keep reading a Q&A blog some of the details for 1.0 to 2.0 here.
Level 3: NIST 800-172
- A subset of NIST 800-172 (To Be Determined)
- Organizations handling CUI
- Organizations likely handling secret or top-secret information
- Depending on the type(s) of information that you handle (CUI/CDI/CTI/ITAR) all organizations will have to prepare for:
When Will CMMC Appear In Contracts?
"Everything is going to revolve around rulemaking for CMMC 2.0"
-Jacob Horne (Chief Security Evangelist at Summit 7 and industry thought leader).
The Key For Contractors
- The DoD is claiming that costs, burdens, and barriers to entry are significantly reduced as a result of the changes in CMMC 2.0. However, accounting for these savings and reductions is done for the overall CMMC program, not for individual companies.
- The allowance of POAMs, the removal of the "Delta 20" controls, and the removal of process maturity requirements are the basis for significant cost reductions. However, if an OSC's costs and burdens was a result of NIST SP 800-171, then these changes are not as helpful as the government is indicating.
Rulemaking is often triggered by direction from Congress. For example, much of the impetus for the CMMC interim rule was a result of the FY 2020 NDAA. Based on the statement that DoD will pursue rulemaking, here's what we know will be codified for CMMC 2.0 based on the two CFRS. The DoD has stated that they will pursue rulemaking in Title 48 and Title 32 of the Code of Federal Regulations.
What are the two CFRs that drive rulemaking?
- 32 CFR (Code of Federal Regulations)
- 48 CFR (Code of Federal Regulations)
- DFARS 252.204-7021 exists to indicate when CMMC certification is required.
Do You Need Microsoft 365 GCC High For CMMC 2.0?
The short answer: No
The long answer: You likely need to choose GCC High for your overall compliance strategy.
GCC High is not required to meet CMMC 2.0 at any Level. However, Microsoft's official recommendation is for organizations planning or required to meet CMMC 2.0 Level 2 (formerly CMMC 1.0 Level 3) should deploy to Microsoft 365 GCC High. The Commercial and GCC versions of the platform can be configured to meet NIST 800-171, and the vast majority of CMMC's requirements with native security products/capabilities. CMMC 2.0 Level 2, for example, can be met in Commercial and GCC per the standards written to date.
What Is Microsoft 365 GCC High? Start here.
The graphic below represents the Microsoft Platform as it relates to relevant compliance frameworks such as CMMC, DFARS 7012, ITAR regulations.
There are several long-term concerns and considerations to assess, and these are highlighted in this guide to GCC vs GCC High.
CS2: CMMC Industry Days
What Is CS2?
CS2, or The Cloud Security and Compliance Series, is an ongoing informational series for contractors in the Defense Industrial Base looking to meet federal compliance mandates. These hybrid events are specifically curated towards aerospace and defense contractors and those in higher education institutions looking for practical approaches to address security threats, invest in the culture of cybersecurity for their organization, and glean best practices for their cloud investments.
Areas of focus for CS2 events include, but are not limited to
- CMMC 2.0
- NIST 800-171
- The DFARS 70 Series (7012, 7019, 7020)
- ITAR regulations
- Handling CUI and FCI
- And much more
