CMMC Starts with DFARS

by Justin Peacock

Controlling CUI: DFARS to CMMC

A few years back, the United States Department of Defense (DoD) released a new regulation, a Defense Federal Acquisition Regulation Supplement, or “DFARS” (DFARS clause 252.204-7012), which brought new cybersecurity requirements for contractors and organizations operating with the DoD; aimed to bolster cybersecurity in the Defense Industrial Base (DIB) by setting precise requirements outlined in the National Institute of Standards and Technology’s (NIST) SP 800-171. The requirements protect Controlled Unclassified Information (CUI) flowing from the federal government to private and public contractors from falling prey to cyber threats, and it was a positive step in the effort to strengthen U.S. national security. Although DFARS was introduced in 2016, organizations that are part of the DoD supply chain are focusing on DFARS compliance years later.

In 2019, though, the DoD released the first versions of what became the Cybersecurity Maturity Model Certification (CMMC), set to displace DFARS as the means by which the DoD ensured that its supply chain had adequate security to the extent that it handled CUI.

When the DoD first released version 1.0 of the CMMC and announced that the new Cybersecurity Maturity Model Certification (CMMC) framework would replace the DFARS standard in their effort to assess the cybersecurity posture of the defense industrial base, many organizations were left scrambling to learn how applicable their previous work on NIST SP 800 171 was to the new requirements. Thankfully, the CMMC Accreditation Body (AB) has clarified that aligning with the DFARS standard is paramount to the Cybersecurity Maturity Model Certification from small businesses or prime DoD contractors.

CMMC vs NIST 800 171

The Cybersecurity Maturity Model Certification is slotted to be added to prime DoD contracts in 2020 as a unified standard for “go/no go” decisions at the time of award. It will require organizations in the DoD supply chain to evaluate their maturity level tier and undergo a CMMC audit by an official CMMC auditor. This program as outlined by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSDA&S) will serve as verification ensuring that the defense supplier has adequate cybersecurity practices across basic cyber hygiene, processes, procedures, and policies in place. The Cybersecurity Maturity Model Certification naturally builds on NIST SP 800-171 cybersecurity standards by adding the certification piece. Different levels of the CMMC security requirements, or CMMC levels 1-5, include more advanced practices to reduce cybersecurity risk as more CUI is present or further up the DoD supply chain up to the prime contractors, denoting a higher certification level requirement.

The Future of CUI: CMMC/DFARS

Ultimately, the DoD will require all organizations that process, store, or transmit CUI (members of the DIB) to undergo the CMMC audits and CMMC assessments to validate their cybersecurity practices, performed by independent third-party certified organizations. Aligning with the DFARS/NIST 800 171 standard, which naturally aligns with CMMC requirements outlined in Tier 3 - the Tier that most contractors will be required to comply with - is the best and most effective move for defense industrial base members looking to win contracts associated with the DoD in 2020 and beyond - so says the CMMC AB, Katie Arrington, and the writers of the Cybersecurity Maturity Model Certification among others. The future of CMMC and DFARS lies with NIST.

View the infographic below to learn how CMMC and DFARS overlap. It shows the first steps of how to start with DFARS and how many secure controls are needed to implement and achieve CMMC level 3.