The Impact of CMMC Compliance on Small Businesses
CMMC Compliance
The U.S. Department of Defense (DOD) has introduced new proposed rules for the Defense Federal Acquisition Regulation Supplement (DFARS) aimed at enforcing the Cybersecurity Maturity Model Certification (CMMC) program. Starting in 2025, these rules will apply to all DOD contracts.
Self Certify or Third Party Certification
Contractors must either self-certify or get third-party certification before starting any work. The type of certification needed depends on the level of cybersecurity required. This is based on how sensitive the information is in each contract. We expect public feedback on these proposed regulations by October 15, 2024.
Title 32
As of October 2024, the final rule for Title 32 of the Cybersecurity Maturity Model Certification (CMMC) is in its final stages of the regulatory process. The Department of Defense (DoD) has completed the interagency review, and the rule is expected to be published by late October 2024. Once published, there will be a 60-day Congressional review period, after which CMMC assessments will officially begin, likely around December 2024.
Title 48
Title 32 establishes the CMMC framework, outlining cybersecurity requirements for contractors dealing with Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). However, CMMC will not be fully enforced until Title 48 is updated, which will integrate these requirements into Defense Federal Acquisition Regulation Supplement (DFARS) clauses, officially tying compliance to contract awards. This integration is expected to happen in 2025.
Must have Active CMMC Assessment at the Time of Contract Award
If these rules are implemented as proposed, contractors will need to have an active CMMC assessment at the time of contract award and maintain that assessment throughout the contract’s duration. Failure to obtain or sustain the required certification could result in being ineligible for the contract or facing contract termination during the performance period.
What is CMMC Compliance?
Consulting Support for CMMC Compliance
At Core, we offer a modular approach to certification. We break the requirements down into two broad categories: organizational and technical. We provide NIST/CMMC training for your employees, your management, and your IT Team or MSP (if you outsource your IT needs).
We also help you with your guided self-assessment.
We will help you develop your System Security Plan (SSP), Plan of Action and Milestones (POAM), Roadmap, and budget. Core Business Solutions is a NIST/CMMC registered provider organization (RPO). Click to view CBS CMMC Consulting Offering Sheet Link.
What are the Challenges Small Businesses Face with CMMC Compliance?
Small businesses face significant challenges when it comes to complying with the Cybersecurity Maturity Model Certification (CMMC) requirements.
Cost of Compliance
One of the most pressing challenges is the cost associated with certification. Achieving CMMC compliance often requires businesses to invest in new cybersecurity tools, upgrade their existing technology, and ensure that their systems meet the necessary security standards. For small businesses with limited budgets, these costs can be daunting, as they may need to divert funds from other critical areas to cover these expenses.
Resource Limitations
In addition to financial constraints, small businesses may struggle with resource limitations. Many small businesses lack dedicated IT or cybersecurity personnel, making it difficult to navigate the complex requirements of the CMMC.
Without an in-house expert, the process of interpreting and implementing the required controls can be overwhelming, leading to delays and increased risk of non-compliance. Small businesses may also lack the bandwidth to maintain ongoing security monitoring, which is critical for sustaining compliance after certification.
Outdated Technology
Another challenge is the need to upgrade or modernize existing technology. Many small businesses operate on legacy systems that may not be compatible with the cybersecurity standards mandated by CMMC.
Upgrading these systems is not only costly but can also be disruptive to operations, as it may require training staff on new tools, migrating data, and ensuring minimal downtime.
Despite these challenges, small businesses can take several steps to overcome them and achieve CMMC compliance.
Overcoming CMMC Compliance Challenges
Grants and Funding Opportunities
One approach is to seek out government or private sector grants and funding opportunities aimed at helping small businesses improve their cybersecurity posture. There are various programs designed to offset the costs of cybersecurity upgrades and certification, allowing small businesses to pursue compliance without draining their financial resources.
Partnering with a Managed Service Provider
Small businesses can also consider partnering with managed service providers (MSPs) that specialize in cybersecurity. These third-party experts can offer tailored solutions, help implement necessary controls, and provide ongoing monitoring to ensure compliance.
By outsourcing cybersecurity tasks to trusted professionals, small businesses can mitigate resource limitations and avoid the need for an in-house cybersecurity team.
A Phased Approach
Another key strategy is to break down the CMMC requirements into manageable steps. Small businesses can start by conducting a gap analysis to determine where their current cybersecurity practices fall short and then prioritize the most critical areas for improvement.
This phased approach allows businesses to gradually implement the necessary controls without overwhelming their budget or resources. Additionally, investing in cybersecurity training for employees can help reduce vulnerabilities, as human error is often a significant factor in security breaches.
By empowering their teams with the knowledge to identify and prevent threats, small businesses can strengthen their overall security posture while working toward CMMC compliance.
Need help applying cybersecurity practices to your business? Our solutions include hands-on consulting support from industry experts. We don’t leave you to figure out compliance on your own. We walk you through every step of the process.
