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CMMC 2.0

CMMC Compliance for Defense
CONTRACTORS AND SUPPLIERS

Your contract names a level. ITS implements the practices behind it, keeps the System Security Plan and the plan of action current, and gets you ready for the assessment route that actually applies to you.

WHERE BIDS ARE LOST

What Trips Suppliers Up Before an Assessment

CMMC failures are rarely about security tooling. They are about scope, evidence and somebody assuming a question had already been answered. This page sits inside our wider IT compliance services, and these are the seven findings we are called in to fix.

The gaps we find most often:

  • Nobody has read the contract clause to find the level
  • Federal Contract Information treated as if it were out of scope
  • An enclave that was never actually separated from the rest of the network
  • A plan of action with items older than the contract
  • Evidence that only exists in one person's head
  • A self-assessment run by the person who built the systems
  • No answer to which assessment route the contract allows
WHY ITS

The Work Between the Clause and the Assessment

Your contract says what you have to meet. It does not say how, who does it, or what proof is supposed to look like. That is the part ITS carries.

Scope Before Spend
We work out what information you actually hold and where it moves, because scope is what decides the cost of everything that comes after it.
Practices That Are Running
Access control, multifactor authentication, logging, patching, training and incident response, implemented and then operated rather than written down and hoped for.
Evidence a Stranger Can Read
The System Security Plan, the plan of action and the records kept current as a by-product of the work, so an assessor reads a file instead of interviewing your staff.

CMMC 2.0 does not invent new security requirements. Level 2 is the 110 practices of NIST SP 800-171, and what CMMC adds is proof: an assessment, on a schedule, by someone other than you.

We are not going to re-answer the questions our own articles already answer well: CMMC and NIST 800-171 compared, what an RP, a CCP and a CCA each do, and how long certification takes.

WHAT CMMC REQUIRES

Six Decisions Your Contract Has Already Made

CMMC 2.0 is a verification program layered on a control set that already existed. These are its own moving parts, in the order they matter to a supplier.

Program structure summarized from the Department of Defense's CMMC documentation and the DFARS clauses ITS cites in its own published CMMC articles.

Level 1, Level 2 or Level 3

The level is set by your contract, not chosen by you. Level 1 covers basic protection of Federal Contract Information, Level 2 is where most suppliers land, and Level 3 applies to the highest priority programs.

Who needs CMMC

The 110 Practices

Level 2 assesses the 110 practices of NIST SP 800-171. There is no separate CMMC control catalogue to learn, which is the good news buried inside the acronym.

See the control set

CUI and FCI Scoping

Which systems hold Controlled Unclassified Information, which hold Federal Contract Information, and which hold neither. Everything downstream, price included, follows from that answer.

System Security Plan and POA&M

A written plan describing how each requirement is met, and a plan of action for the ones that are not met yet. Both are living documents, and an assessor reads them first.

Your SPRS Score

The self-assessment expressed as a number and submitted to the Supplier Performance Risk System. Because you grade yourself, the score is only ever as good as your reading of the requirements.

How to report it

Self-Assessment or a C3PAO

Level 1 is self-assessed. Level 2 is normally assessed by an authorized third party, and only a C3PAO can certify it. ITS operates your controls, which is exactly why ITS cannot be your assessor.

Assessment or audit
HOW TO START

Three Steps to an Assessment You Are Ready For

Scope first, then evidence, then operation. You can stop after any step.

STEP 1

Read the Clause, Scope the Information

We start where the obligation starts, which is your contract: which clause applies, which level it names, and what information it actually covers. Then we map where that information lives and where it moves. Scope decides cost, so this is the step worth slowing down for.

Talk to a Compliance Expert
CLIENT RESULTS

What Clients Say About Working With Us

Two ITS clients on what changed once somebody owned the security work. Neither is a defense supplier, and we are not going to imply otherwise.

ITS led significant, transformational changes at Eastern Plumas Health Care to ensure we weren’t susceptible to attacks. Looking back, prior to that partnership, we had a lot of risks on campus. I’m glad nothing happened, but I’m even more proud that after implementing those systems, we’ve avoided data breaches and HIPAA violations throughout our five-year partnership.

Doug McCoy CEO of Eastern Plumas Health Care (EPHC)
FAQ

What Contractors Ask Us Before Bidding

1. What is CMMC 2.0, and who has to comply?

The Cybersecurity Maturity Model Certification is the Department of Defense's program for verifying that its suppliers protect the information those suppliers hold. It applies through your contract: a clause names a level, and the level sets what you have to meet and who is allowed to assess it. That reaches prime contractors and their subcontractors, at any size, whenever the work involves Federal Contract Information or Controlled Unclassified Information. If you are unsure whether it reaches you, the types of business that need CMMC is the shortest way to find out.

2. Is CMMC the same thing as NIST 800-171?

CMMC 2.0 does not invent new security requirements. Level 2 is the 110 practices of NIST SP 800-171, and what CMMC adds is proof: an assessment, on a schedule, by someone other than you. So the control work and the verification work are two different projects with two different owners, and you need both. The full side by side is CMMC and NIST 800-171 compared, which is where we keep that answer rather than repeating it here.

3. Can ITS certify us for CMMC?

No. Only an authorized CMMC Third Party Assessment Organization, a C3PAO, can certify Level 2, and that organization has to be independent of the people running your controls. ITS runs your controls, which is precisely why ITS cannot also assess them. What ITS does is the rest of it: scope the information, assess the practices against evidence, implement and operate what is missing, keep the System Security Plan and the plan of action current, and be in the room answering questions when the assessor arrives. Anyone offering to certify you and manage you has misread the program.

4. Do we self-assess, or does someone else assess us?

It depends on the level your contract names. Level 1 is a self-assessment. Level 2 is normally assessed by a C3PAO, though some contracts allow a self-assessment instead, and the contract is the only place that answer lives. The practical risk with self-assessment is not dishonesty, it is interpretation: nobody checks how you read a requirement until a prime or the government does. We have written up what a CMMC self-assessment involves, and the difference between an assessment and an audit is worth five minutes before you use either word in a meeting.

5. How long does it take, and what does it cost?

Both answers depend almost entirely on your scope, and we are not going to print a number that would be wrong for most readers. We have covered them properly elsewhere: how long CMMC certification takes and what CMMC compliance costs. The one thing worth saying on this page is that the variable you control is scope, which is why step one below is scoping and not shopping.

6. We are a small subcontractor. Does this reach us?

Usually, and it tends to arrive as a purchase order rather than a letter. A prime that has to meet a level cannot hand its obligations to you and keep the risk, so the requirement flows down the supply chain with the work. Being three tiers down and eleven people does not remove it. What it does change is scope: a small supplier that receives one narrow category of information can often draw a much smaller boundary than it fears, and that is the conversation to have before you sign, not after.

Find Out Which Level Your Contract Actually Names

A scoping call, an honest read on where you stand against the practices that level requires, and a written plan of action. No obligation at the end of it.