The recently released CMMC program requires a third-party audit, and contractors are wondering how they should prepare for something they have never done before. If you find yourself in this position, take the following steps to get your company on the right track and make sure you are properly prepared.
The first step for preparing for your CMMC audit is simply getting started immediately. The newest version is likely more intense than any cybersecurity program you’ve been subjected to before, so you are likely going to have a lot of work to do. That means procrastination is the worst possible thing to do. After all, building a mature cybersecurity system that can earn certification is something that takes time.
Determine the Controlled Unclassified Information Environment (AKA Scoping)
Once you’ve got the ball rolling, the first step to passing this federal audit is determining which systems and assets are in scope. That means anything that comes into contact with your Controlled Unclassified Information, either directly or indirectly. These assets create your CUI environment. Scoping out your CUI environment ahead of time, whether you figure it out on your own or with the help of another professional, will save you time and money.
Conduct a Readiness Assessment
The CMMC builds upon previous cybersecurity requirements in DFARS 252.204-7012 and NIST 800-171. Therefore, you will likely have most of the necessary controls in place already. However, even when this is true, you need to identify where you stand before your audit.
You should conduct a readiness assessment to help you determine where your systems’ weaknesses are and how you could improve them. This assessment should largely focus on ensuring all processes and systems meet cybersecurity standards and how your CUI is protected.
Identify the Steps for Remediation
Now that you know what needs improvement, you can identify the potential risks and what steps you need to take to remediate the deficiencies you identified. Additionally, you can identify the costs associated with each remediation, which can help you prioritize different things. Finally, keep in mind that if your cybersecurity system falls drastically short of the mark, you’ll have higher expenses trying to get it up to snuff. This has become a new cost of contracting with the Department of Defense.
Create a Compliance Roadmap
After establishing what steps are necessary, you need to create a roadmap that will take you from your current state to compliance. Your roadmap should basically be an ordered list of the steps you will take in the right priority, which is based on cost and necessity. While the exact details of your plan will be up to you, the one thing you need to remember is that time is of the essence.
Monitor Your Progress
Once you pass your audit, you must remember that you must continue working. Never let your compliance lapse between audits because no one is looking. Aside from forcing you to start all over with your preparations for the next audit, you could lose your contract with the Department of Defense if you experience a breach. In other words, it can be easy to loosen your cybersecurity posture. You can avoid this by continuing to monitor your processes to ensure you never deviate from a compliant state.
The most recent changes to the CMMC certification have everyone scrambling. Now, all contractors working with the Department of Defense will need to undergo an audit to ensure their cybersecurity systems are certified. Fortunately, taking the proper steps to prepare can help this process go much smoother. Following these steps will help you understand what areas need work and get you started fixing these problems. This will help you pass your audit with ease.