What should DoD contractors know about CMMC and DFARS?

Controlled Unclassified Information (CUI) security is crucial for any contractor working with the USA defense department. It’s highly essential that military contractors must treat the data they process and store responsibly. CUI cybersecurity is addressed in the Defense Federal Acquisition Regulation Supplement (DFARS) and the Cybersecurity Maturity Model Certification (CMMC).

In this blog, we take a closer look into the similarities and differences between DFARS and CMMC and need for CMMC government contracting services.

DFARS

DFARS went into effect in 2017. Contractors for the Department of Defense (DoD) and secondary suppliers to defense contractors must comply with DFARS. Companies must generate the following in order to comply with DFARS:

  • A Security Plan for the System (SSP).
  • Milestones and a Plan of Action (POAM).
  • A CUI Environmental Protection Team is a group of people that are in charge of the environment (CEMT).

Organizations use DFARS to submit the final self-evaluation to the Department of Defense. The Department of Defense maintains the authority to investigate, and several hundred audits are conducted each year.

CMMC

CMMC is a comparatively recent approach for safeguarding CUI. Any vendor or organization doing commerce with the Department of Defense (including primary contractors and their secondary suppliers) must comply with the CMMC criteria and get accreditation. Although CMMC adherence started in 2020, the Department of Defense will continue to incorporate CMMC requirements into new agreements until all organizations are compliant by 2025. It evaluates businesses on the basis of five maturity levels:

Basic Cyber Safety (Level 1)

Seventeen security procedures must be applied at this level.

Intermediate Cyber Security (Level 2)

Documented processes and regulations, as well as 55 extra security practices, are required at this level.

This level of organization has demonstrated strong cyber cleanliness and adopted CUI procedures. There are a total of 58 practices in this category. This is a requirement for every organization that uses or generates CUI.

Proactive (Level 4)

At this level, organizations have established sophisticated cybersecurity practices. There are 26 more practices at this level.

Advanced/Progressive (Level 5)

Companies can fend off sophisticated, persistent attacks at this level (APTs). Throughout the company, security procedures are standardized. There are 15 more practices in this grade.

CMMC compliance is assessed by third-party assessment organizations (3PAOs).

Now, let’s understand CMMC vs. DFARS.

The aim of both DFARs and CMMC is the same: to safeguard CUI. Being DFARS certified will enable you to advance through the CMMC levels of maturity. CMMC relies on DFARs, and the paperwork created while obtaining DFARS compliance is necessary for progressing through the CMMC levels.

The most significant distinction between the 2 is how they are evaluated. While the two have considerable overlap, it is feasible to be DFARS certified without also being CMMC compliant and vice versa. 

Interim Rule of the DFARs

Organizations just had to confirm that they implemented NIST 800-171 rules without presenting any proof or undertaking an examination before using CMMC. It requires organizations to examine and grade their compliance utilizing a grading system devised by the US DoD.