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The CMMC 2.0 Level 2 Assessment Guide includes the same controls and determination statements as NIST 800-171A. It is simply a certification program wrapped around the requirements of meeting NIST 800-171A. CMMC 2.0 Level 2 is not a specification in and of itself. The requirements of DFARS 252.204-7019, 7020, and 7021 apply regardless of whether expressly stated in the contract or not.įor sake of this article, we will focus on CMMC 2.0 Level 2 which is required for any contractor or subcontractor handling CUI. Therefore, contractors are required to have their scores recorded in SPRS in order to be eligible for DoD contracts containing the DFARS 252.204-7012 clause. Although CMMC 2.0 is still under development, the Interim Rule released in September 2020 is in effect now. It streamlined the program down to three levels (1, 2, and 3). In November 2021, The DoD announced CMMC 2.0. Finally, it states that, if asked, contractors are required to provide proof of compliance with those controls met as indicated on their uploaded SPRS score. Contractors are required to upload their score into the SPRS tool. In a nutshell, these new clauses defined the Supplier Performance Risk System (SPRS) and required contractors to score themselves on a self-assessment basis using a defined scoring system.

In September 2020, the DoD issued an Interim Rule consisting of three new DFARS 252.204 ( 7019, 7020, 7021) clauses. However, the controls were based on the requirements of the original DFARS 252.204-7012 clause that contractors should have already implemented back in 2016. Many contractors complained that it would be very difficult to certify on such a new program without significant burden and expense.

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Full compliance would be required by 2025 to be eligible for DoD contracts. There was no allowance for Plans of Action and Milestones (PoAMs) for controls that had not been fully met. It was a strict program which required full compliance with all 110 NIST 800-171 controls. There were five different levels of certification depending on the controls met. The first version of the CMMC program was overly complex and confusing. CMMC Version 1.0 was released in late 2019. In response, The DOD developed a certification program that would become known as the Cybersecurity Model Certification (CMMC). In 2019, the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) performed audits against a number of contractors and discovered that none were fully compliant, and most were woefully deficient.

NIST 800-171A articulated the 110 Controls and the underlying determination statements that need to be met to be complaint with the DFARS 252.204-7012 clause. The program was based on a self-assessment process that contractors would conduct using the NIST 800-171A Assessment Guide. This clause, when included in a DoD contract, required the contractor (and their subcontractors) to develop a System Security Plan (SSP) based on the NIST 800-171 set of controls regarding the handling of Controlled Unclassified Information (CUI). We'll start in October 2016 when the DoD issued the DFARS 252.204-7012 or the 'Safeguarding Covered Defense Information and Cyber Incident Reporting' clause. Bear with me as there is an alphanumeric bowl of soup coming.

That is until now.įirst a little history on CMMC. The goalposts have moved a few times and the messaging has been unclear from the Department of Defense. There has been a lot of hand wringing and gnashing of teeth regarding the relatively new model. Monorchism surgery.For the past three years Department of Defense contractors and the MSPs that serve them have been facing the inevitable need to meet Cybersecurity Maturity Model Certification (CMMC) requirements.