Your CMMC Compliance Checklist: Conquer The Challenges

If you’re a defense contractor, staying compliant with the Cybersecurity Maturity Model Certification (CMMC) is important to continue working with the Department of Defense (DoD). 

CMMC is expected to be finalized by late 2024 and included in contracts by early 2025, so it’s time to start preparing.

To help you prepare, here’s a straightforward introduction to CMMC Level 2 compliance. 

We’ve also put together a handy CMMC compliance checklist that breaks down the requirements so you can see where you stand and what steps you need to take to meet your compliance goals.

What is the CMMC Compliance Checklist?

The CMMC Compliance Checklist is a step by step guide used by organizations, particularly those working with the U.S. Department of Defense (DoD), to ensure they meet the necessary cybersecurity requirements. 

The checklist is designed to help any organization prepare for a CMMC assessment by outlining the key practices that worked for others or the ones the auditors swear by that they need to implement. 

This is because if you’re a contractor or subcontractor who handles CUI or FCI in any way, you must demonstrate compliance with CMMC. You need help from the CMMC compliance checklist that works and helps implement the necessary processes.

Note: CMMC first launched in January 2020 with five levels of certification. Since then, it has evolved. In November 2021, CMMC 2.0 was introduced, bringing some key changes. One of the biggest updates is that the original five levels have been simplified into three. Below, we’ll break down these levels and how they apply to your compliance process.

What are the CMMC Requirements? Understand the Core Elements

Organizations must implement a couple of strong cybersecurity practices that stem from 14 interdependent domains which are the main CMMC checklist requirements. Each CMMC level requires more practice from these domains. 

• Access Control (AC)
• Identification and Authentication (IA)
• Personnel Security (PS)
• System Communications protection (SC)
• Awareness and Training (AT)
• Incident Response (IR)
• Physical Protection (PE)
• System Information integrity (SI)
• Audit and Accountability (AU)
• Maintenance (MA)
• Risk Assessment (RA)
• Configuration Management (CM)
• Media Protection (MP)
• Security Assessment (CA)

Overview of the Levels of CMMC

CMMC level comes with its own set of cybersecurity practices, standards, and processes, all designed by the Department of Defense to protect national security. 

The goal is to ensure that defense contractors and subcontractors handle FCI and CUI securely. The specific requirements for assessments depend on the level of certification needed.

However, the updated CMMC 2.0 model simplifies the previous five-tier system into three levels: Level 1 (Foundational), Level 2 (Advanced), and Level 3 (Expert). This new structure, announced on July 17, 2021, streamlines the certification process while ensuring robust cybersecurity practices. 

The original CMMC version 1.0 had five levels, including two transitional levels (Levels 2 and 4). However, CMMC 2.0 has removed these transition levels, focusing on just three. Here’s a breakdown of what these levels entail:

Level 1: Foundational

CMMC 2. 0’s Level 1 is called “Foundational.” This level is strictly for organizations that deal with FCI. It is almost identical to Level 1 from the previous version of CMMC 1. This one discusses the version for protecting FCI by protecting the contractor information systems and ensuring that the Contractor only has authorized access to the data.

Level 1 is the quintessential building block of cybersecurity. It establishes the basic cyber hygiene practices that every defense contractor needs. You can’t move on to higher levels without first getting these fundamentals right.

CMMC is currently divided into 3 levels; each is progressive and implies passing through the previous level. Thus, it could be stressed that Level 1 should be mastered first to achieve higher levels.

Who needs Level 1? 

If you are a contractor who deals with FCI and works with the DoD, you need a CMMC level 1 checklist. This applies to the prime contractor as well as the subcontractors. Whether it is about keeping the armed forces’ information safe or achieving the DoD goals. From there, you can enter into the other levels of the CMMC certification process.

How do you get Level 1 certification?

• Read and understand the Level 1 requirements: Read about the general cybersecurity practices that should be employed for CMMC Level 1.
• Outsource if necessary: If your organization cannot conduct whichever security protocol in-house, seek help from third parties offering security services.
• Maintain vigilance: It is necessary to stay compliant and remain regularly alert to your network and data security after passing Level 1 certification. Level 2: Expert

Level 2: Advanced

Four key controls are in the maintenance domain of the Advanced level of the CMMC level 2 checklist. These controls focus on protecting critical data and services when a computer system fails. They also provide guidelines on securing systems during malfunctions or unexpected incidents. 

Who needs Level 2? 

If you are planning to bid on DoD contracts involving CUI, CTI, or ITAR/export-controlled data, the company must be CMMC Level 2 certified. 

This level is tailored towards organizations that deal with much more sensitive data and must show more commitment to security. The competition and compliance with DoD requirements make Level 2 imperative.

How to get Level 2 certification?

• To get started, you should have a basic understanding of the requirements in CMMC Level 2. Carefully analyze your company’s current state of affairs and identify areas of your security that require work.
• Unless you do a thorough gap analysis, pinpointing areas your security measures have left uncovered regarding Level 2 compliance becomes difficult.
• Use technical solutions, such as implementing access control, encrypting data, and enhancing network security, to minimize the weaknesses found. Develop organizational policies for cybersecurity practices and implement protocols for incidents.
• Ensure your team understands all these new security features so no one can breach the security laid down.
• In case of necessity, cybersecurity consultants or third-party assessor organizations (C3PAOs) should assist in guiding through this process and providing support in the correct implementation of controls and in the recognition of compliance.

Level 3: Expert

The third and highest level of CMMC 2.0 is the “Expert” level. This level is designed for organizations that handle high-priority CUI, which is crucial to national security. Here, the focus is on reducing the risk of Advanced Persistent Threats (APTs).

What sets Level 3 apart from the other levels is the requirement to review and assess your security controls continuously. 

Who needs Level 3? 

DoD contractors and subcontractors that manage critical CUI must meet the CMMC level 3 checklist.

How do you get Level 3 certification?

• Risk assessment: Evaluate your systems and security. A C3PAO can help identify gaps and provide a plan.
• Cybersecurity policy: Ensure you have a strong cybersecurity and disaster recovery policy that meets CMMC Level 3 standards.
• Secure remote work: Protect all devices handling sensitive data. Use multi-factor authentication and update security measures.
• Use AI and Machine Learning: Implement AI tools for 24/7 threat detection and response.

CMMC Compliance Checklist: Step-by-Step Guide to Achieving Compliance

As a defense contractor, achieving and maintaining CMMC compliance is vital for securing contracts with the DoD. Whether you’re a small business or a large corporation, the CMMC compliance checklist we’ve curated for you provides the information and resources needed to achieve compliance. 

We’ve talked with our internal compliance experts at Sprinto, and they’ve shared the steps they absolutely rely on—and they work. As you move through the certification process, just follow these steps to stay on track.

Step 1: Determine which is your CMMC Level

CMMC levels are tied to the sensitivity of the information you handle. As mentioned earlier, different CMMC standards apply to different levels, so it’s crucial to understand which level is relevant for your role.

Your specific CMMC level will be determined by the requirements outlined in the contract you’re bidding on or any existing contracts you have. At the very least, you’ll need to meet Level 1 of CMMC, which can be achieved through self-attestation.

Step 2: Identify the information that needs protection

Start by identifying the types of information you need to protect, such as FCI, CUI, and CDI, as part of your DoD contract. It’s not just about the information itself—you’ll also need to figure out how it’s processed, stored, and transmitted. 

This is important because the CMMC auditor will closely examine how you’re managing and safeguarding this information.

Step 3: What controls do you need to implement?

For CMMC compliance, one of the first things you’ll need to focus on is implementing the right controls. The goal is to establish “good cyber hygiene,” which means putting in place a combination of technical and management controls to safeguard sensitive information.

Here are some key controls you’ll want to consider:

• Access Control 
• Identification and Authentication 
• Personnel Security 
• System Communications protection 
• Awareness and Training 
• Incident Response 
• Physical Protection

Step 4: Prepare for the assessment

When preparing for your CMMC assessment, the first step is thoroughly evaluating your organization’s security controls and practices. Now, here’s what the procedure looks like:

• Start by evaluating your organization’s security controls and practices using your System Security Plan (SSP). 
• This assessment can be done by internal staff or external consultants, with the DoD’s Self-Assessment Guide offering support for Level 1 or Level 2 certification.
• After completing the assessment, document the findings in a (SAR) Security Assessment Report, including any deficiencies and recommendations for improvement. 
• Update your Plan of Action and Milestones (POA&M) based on the SAR. This helps track your progress toward CMMC compliance and prioritize necessary improvements.
• Complete the Defense Federal Acquisition Regulation Supplement (DFARS) Compliance Checklist, which outlines specific cybersecurity requirements for DoD contractors. 
• Upload your SAR, SSP, and POA&M to the (SPRS) Supplier Performance Risk System. This shows your commitment to CMMC compliance. Also, submit your results to SPRS to provide the DoD insight into your security posture and progress.

Step 5: Assessment through C3PAO 

To move forward with CMMC certification, now you’ll need to partner with a certified assessor. This is where the CMMC 3rd Party Assessment Organization (C3PAO) comes in. The process will begin with C3PAO to plan your assessment. Here is where you’ll have to discuss your readiness and agree on a timeline that suits both parties.

The C3PAO will then perform an independent evaluation to verify that you meet the required CMMC 2.0 maturity level (whether that’s Level 1, 2, or 3). Their role is to confirm that you’ve properly implemented the necessary security controls and practices while assessing your overall security setup.

After the assessment, the C3PAO will provide you with a comprehensive report detailing their findings. This report will also be uploaded to the CMMC Enterprise Mission Assurance Support Service (EMASS) system, making it accessible to the DoD.

Step 6: Continuously monitor your CMMC compliance controls

Compliance isn’t a one-time task—you need to keep up with it regularly. You need to make sure your systems align with the latest CMMC standards, which is crucial to staying compliant and secure. That’s where consistent monitoring comes in.

Continuous monitoring is simply an ongoing process of observing, detecting, and responding to security threats and compliance issues in real-time or near real-time within an organization’s IT environment.

When you automate evidence collection and gain real-time visibility into your CMMC compliance status, you can keep track of everything without the added stress. Sprinto makes this easy by providing a centralized compliance platform. 

It helps you maintain a single source of truth, proves your practice maturity, and ensures accurate reporting. With Sprinto, you’re always ready for an audit—no more last-minute scrambles or surprises.

Bhargava, Engineering Lead at Zipy, experienced this firsthand: “Our audit was a cakewalk. There was no instance of non-compliance across Type 1 and Type 2 reviews!”

How to Prepare for a CMMC Assessment?

The preparation for a CMMC assessment will start with choosing a specific level of CMMC to get certified in. More than that, there are a couple of more steps you need to take, and they are:

• Familiarize yourself with the specific CMMC-level requirements relevant to your organization.
• Conduct a gap analysis to identify areas where your current practices fall short of CMMC standards.
• Based on your analysis, develop a remediation plan to address gaps and strengthen your cybersecurity controls.
• Engage with a C3PAO if needed, and work with a certified third-party assessment organization to guide your preparation.
• Train your staff so all employees know the new processes and security measures.
• Organize and document all policies, procedures, and evidence needed for the assessment.
• Schedule an internal review to perform a self-assessment to identify any last-minute issues before the official audit.

Start Preparing For CMMC 2.0, the Smart Way

CMMC compliance has evolved significantly over the past few years. While version 2.0 aims to simplify things, it can still be a tough framework to fully grasp and implement. The smartest way to get ready for CMMC is to follow the six steps mentioned earlier. 

When you meet and maintain compliance guidelines, you not only protect your business and DoD contracts but also secure important data and save time during annual third-party assessments.

Even though the timelines for full implementation (from May 2023 to October 2025) are still uncertain, there’s no reason to delay preparations. Now is the perfect time to streamline your organization’s processes and controls to meet CMMC requirements.

Sprinto is here to help you navigate this journey. Our platform automates cybersecurity compliance with in-app risk assessments and gap analysis. 

But it doesn’t stop there—Sprinto’s real-time continuous monitoring frees up your engineering team’s time to focus on growth, making it an essential tool for your CMMC certification process.

Want to learn more? Let’s hop on a call to discuss how Sprinto can support your compliance needs.

FAQs

How long does a CMMC assessment take?

For Level 1, the certification process typically takes 6-8 months. Levels 2 and 3 can stretch out to 9-12 months. If you want to get a head start, Coalfire Federal offers a CMMC Mock Assessment to help you prepare before the official assessment.

What is the deadline for CMMC compliance? 

The DoD aims to codify CMMC by the end of 2024, with contract implementation expected by Q1 2025. However, it’s important not to wait. CMMC is based on NIST 800-171, which is already a requirement today.

How is CMMC different from NIST? 

While NIST-CSF provides voluntary guidelines for managing cybersecurity risks, CMMC is a mandatory certification for defense contractors working with DoD contracts. CMMC is more rigorous and integrates requirements from various cybersecurity standards.