Under Secretary of Defense Ellen Lord statement on misleading cybersecurity certification information

What is CMMC?

The Cybersecurity Maturity Model Certification (CMMC) program is a new set of cybersecurity standards developed by the Department of Defense (DoD) to protect defense contractors from cyber attacks.
-    Access CMMC 1.02
-    CMMC 1.02 Appendices
-    CMMC Model Briefing from DoD

How will CMMC work?

DoD will require CMMC certification prior to any company/business/contractor winning a DoD contract. DoD delivered CMMC 1.0 standards (later updated to version 1.02) to a new non-profit governing organization, the Accreditation Body (AB). The AB will certify third-party inspectors who will then certify companies/businesses/contractors against the different CMMC standards/levels. Third-party inspectors will provide companies’/businesses’/contractors’ certification levels to the AB for tracking and provision to the DoD. The AB will not make CMMC certification levels publicly available.

For more information on the AB, please visit their website: CMMCAB.org/

How will CMMC impact NDIA’s members?

The new CMMC program will require certification for all contractors doing business or who want to do business with DoD. This group of affected contractors includes companies indirectly doing business with DoD through subcontracts as well as companies that sell commercial products or services to DoD.

When will CMMC be rolled out?

DoD published the initial set of CMMC standards on January 31, 2020. Companies will have the ability to be certified in the coming months while CMMC language will start appearing in Requests for Proposals and Requests for Information as soon as the Summer of 2020. By 2026, all new DoD contracts will require an appropriate level of CMMC certification.

Who will decide the required CMMC level for each contract?

The DoD is currently developing a plan to educate acquisition professionals on how to set the appropriate CMMC levels for each contract.

How will CMMC compliance be different from compliance with NIST SP 800-171 through DFARS 252.204-7012?

CMMC merges several cybersecurity control standards, including NIST SP 800-171, into a single, unified standard. It goes beyond NIST SP 800-171 to include the assessment of organizational cybersecurity practices and processes in addition to the assessment of technical systems and practices. However, CMMC compliance will not imply NIST SP 800-171 compliance. NIST SP 800-171 includes 63 non-federal organization controls that are not covered by CMMC. At this time, contractors will have to continue to comply with DFARS 252.204-7012 requirements.

How will CMMC impact subcontractors?

At a minimum, all subcontractors will be required to carry CMMC Level 1 Certification to continue to participate in DoD contracts. Additionally, a prime contractor may require Level 3 Certification for a contract while subcontractors may require different levels of certification. Prime contractors will work with contracting officers to determine the CMMC levels required for subcontractors. The process to determine subcontractors’ CMMC certification requirements is still evolving.

What is NDIA’s role in CMMC?

NDIA worked closely with the DoD during the development of both CMMC standards and the model for governing the program. NDIA provided comments, recommendations, and critiques throughout that process. NDIA also hosted several opportunities for NDIA members to engage with DoD CMMC leads. Going forward, NDIA will continue to serve as a conduit between NDIA members, DoD, and the governing Accreditation Body, communicating changes to the regulations and processes to NDIA members while translating the impact of these regulations and suggested changes from member companies to DoD and the AB. NDIA will not have an official role within the AB and will not serve as a CMMC third-party inspector.

What questions does NDIA have about CMMC?

Following a March 2020 meeting with Undersecretary of Defense for Acquisition and Sustainment Ellen Lord, NDIA was asked to compile a list of outstanding questions from its membership. The NDIA Cyber Legal Policy Committee (NDIA's group focusing on CMMC) compiled a list of questions that was delivered to the Department of Defense in April 2020. The letter that was sent is viewable here. A follow-on letter was delivered to DOD and the CMMCAB leadership with additional outstanding questions in October, 2020. That letter is available here

Tools for NDIA Members

  • Exostar Certification Assistant - NDIA members receive a $500 discount when signing up for Certification Assistant Standard
    • Exostar Certification Assistant is a web-based tool to help organizations through the process of CMMC readiness and certification.  Perfect for smaller organizations without formal IT and information security teams, as well as larger organizations with more mature capabilities, Certification Assistant explains each CMMC practice and process in understandable, non-technical terms, providing a self-guided, step-by-step approach for assessing CMMC readiness, and for implementing the practices and processes necessary to prepare for CMMC certification success.  Its companion, Exostar PolicyPro simplifies creating policies required under CMMC.  Certification Assistant is available in three versions: Lite (Level 1), Standard (Levels 1-3), and Premium (Level 1-5).

  • ComplyUp CMMC Assessment Platform - NDIA members receive a 10% discount when signing up for CMMC Full Access
    • Need to get through your CMMC assessment fast? Yes, you do.
      Looking for auto-generated audit documentation? Yes, you are.
      Desperate for a robust risk management platform? No, you're not.
      You just want to get through this compliance headache.
       
      We get it, and we've built compliance assessment software that gives you a fighting chance at a price that won't hurt.
      Yeah, we've got lots of fancy features that get the security-types excited, but that's not really what we're about. We just want to help you solve your compliance challenges so you can get back to business as usual.

 

For more information about discounts for NDIA members, contact Membership@NDIA.org.

NDIA Resources on CMMC

Other NDIA Cyber Resources

 

NDIA Contact

Mr. Corbin Evans
Director of Regulatory Policy
Phone: (703) 247-2598
E-mail: cevans@NDIA.org