SME, Inc.

  • Home
  • About Us
  • Services
    • Cloud Solutions
    • Compliance Solutions
      • ALTA Best Practices
      • CMMC
      • DFARS
      • HIPAA
      • PCI DSS
      • Security Awareness Training
    • Data Center Services
      • Hosting
      • Monitoring
      • Hands & Eyes
    • Managed Security Services
      • Asset Management
      • Nextwall™ Managed Firewall
      • IDS/IPS
      • Managed Anti-Virus
      • VPN/Remote Access
      • Vulnerability Assessment Services
        • External Vulnerability Assessment
        • Internal Vulnerability Assessment
        • Web Application Testing
    • Technical Support
      • The SME Tech
      • Backups
      • Remote Support
  • Blog
  • Contact Us

September 26, 2024 By Rich Westbrook

32 CFR CMMC Final Rule Clears Review: Now is the Time to Become CMMC Certified

32 CFR CMMC Final Rule Clears Review

The Department of Defense (DoD) has taken a significant step in enhancing the cybersecurity framework for defense contractors with the finalization of the 32 CFR CMMC (Cybersecurity Maturity Model Certification) rule. This long-awaited rule has officially cleared regulatory review and is set to be published shortly, making CMMC compliance a critical requirement for contractors handling Controlled Unclassified Information (CUI).

With the publication of this rule imminent, contractors must act quickly to achieve CMMC certification. Failure to comply with these standards can result in disqualification from future DoD contracts. The time is now to ensure your cybersecurity practices meet these stringent requirements.

What the 32 CFR CMMC Rule Means for DoD Contractors

The CMMC framework is designed to secure the Defense Industrial Base (DIB) by requiring contractors to adhere to specific cybersecurity standards based on the type of information they handle. Under the final rule, contractors dealing with CUI will be expected to achieve a CMMC certification level that aligns with the sensitivity of the information they manage.

To remain competitive in the defense sector, contractors must implement robust cybersecurity controls, pass a third-party audit, and maintain certification over time. The need to become compliant is urgent, and organizations must start preparing now.

Why GCC/GCC High is Essential for CMMC Compliance

Not all collaboration tools are created equal when handling sensitive government data. Microsoft 365 Government Community Cloud (GCC) and GCC High are specifically designed to meet the security and compliance needs of organizations working with the U.S. government. These platforms provide a secure environment for sharing and storing CUI, making them a critical part of any contractor’s CMMC compliance strategy.

  • Microsoft GCC: This environment offers heightened security for handling CUI and ITAR (International Traffic in Arms Regulations) data. It includes features like multi-factor authentication, secure email, and enhanced data loss prevention. For many contractors, GCC provides a robust foundation for meeting lower-level CMMC requirements.
  • Microsoft GCC High: For contractors working on more sensitive DoD projects, GCC High is often a necessity. It offers even greater protection and is designed to comply with DFARS (Defense Federal Acquisition Regulation Supplement) requirements and support ITAR and CJIS (Criminal Justice Information Services) needs. GCC High is especially useful for contractors aiming to achieve higher CMMC certification levels.

Systems Management Enterprises, Inc. Is Ready to Help You Become CMMC Certified

As the final 32 CFR CMMC rule approaches publication, Systems Management Enterprises, Inc. is here to help you navigate the path to compliance. We provide a comprehensive range of CMMC remediation support services to ensure your organization is fully prepared for certification.

Here’s how we can assist:

  1. Comprehensive Gap Analysis: We will assess your current use of file-sharing tools and communication platforms, ensuring they meet CMMC standards and addressing any gaps in security.
  2. GCC/GCC High Implementation: If your organization is handling CUI, we can help you implement the appropriate Microsoft 365 GCC or GCC High environment to meet compliance requirements.
  3. Tailored Remediation Plans: Our experts will develop and implement customized remediation plans, from securing your file-sharing tools to preparing for the CMMC audit.
  4. Ongoing Compliance Support: Achieving certification is just the start. We provide ongoing support to help you maintain compliance, including updates as cybersecurity standards evolve.

Secure Your File Sharing Tools and Achieve CMMC Certification Now

The final 32 CFR CMMC rule is about to take effect, and your organization must be prepared. Systems Management Enterprises, Inc. stands ready to assist you in implementing GCC/GCC High solutions and providing the remediation support you need to become certified.

Contact us today to get started on your path to CMMC compliance!

Filed Under: Uncategorized

August 22, 2024 By Rich Westbrook

Achieving CMMC Compliance with SME’s FedRAMP-Approved Vulnerability Management Solution

Achieving CMMC Compliance with SME’s FedRAMP-Approved Vulnerability Management Solution

As a Department of Defense (DoD) contractor, achieving Cybersecurity Maturity Model Certification (CMMC) compliance is not just a regulatory requirement—it’s a crucial step in safeguarding sensitive government data and ensuring the security of national defense operations. Among the many requirements of CMMC, having a robust Vulnerability Management Program (VMP) in place is essential. This is where Systems Management Enterprises, Inc. (SME) can be your trusted partner.

The Importance of Vulnerability Management in CMMC

CMMC is designed to ensure that DoD contractors have the necessary cybersecurity controls to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). One of the critical areas of focus within CMMC is the identification, management, and remediation of vulnerabilities within a contractor’s IT infrastructure.

A Vulnerability Management Program (VMP) systematically identifies, evaluates, and addresses security weaknesses across your network, systems, and applications. Without a VMP, your organization is at risk of cyberattacks that can lead to data breaches, financial loss, and the loss of valuable contracts.

SME’s FedRAMP-Approved Vulnerability Management Solution

SME offers a comprehensive, FedRAMP-approved Vulnerability Management Solution tailored specifically for DoD contractors. The Federal Risk and Authorization Management Program (FedRAMP) is a government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. By leveraging a FedRAMP-approved solution, SME ensures that your Vulnerability Management Program meets the rigorous security requirements mandated by the federal government.

Our solution provides continuous monitoring, automated scanning, and advanced analytics to detect and address vulnerabilities before they can be exploited. This proactive approach not only helps you maintain compliance with CMMC requirements but also significantly reduces the risk of cyberattacks.

How SME Can Help You Achieve CMMC Compliance

Implementing a Vulnerability Management Program that aligns with CMMC can be challenging, especially for organizations without dedicated cybersecurity teams. SME simplifies this process by offering end-to-end support for creating, implementing, and managing your VMP. 

Here’s how we can assist:

1. Assessment and Gap Analysis: We start by conducting a thorough assessment of your current cybersecurity posture and identifying gaps that need to be addressed to meet CMMC requirements.

2. Customized VMP Development: Based on the assessment, we develop a tailored Vulnerability Management Program that meets the specific needs of your organization and aligns with CMMC standards.

3. Implementation and Integration: SME assists with the seamless implementation of the VMP into your existing IT infrastructure, ensuring minimal disruption to your operations.

4. Continuous Monitoring and Reporting: Our solution offers continuous monitoring and real-time reporting to keep you informed of your security status and any emerging threats.

5. Ongoing Support and Optimization: CMMC compliance is an ongoing process, and SME provides continuous support to optimize your VMP, adapt to new threats, and ensure long-term compliance.

Confidently Meet CMMC Requirements with SME

Achieving CMMC compliance is a critical milestone for DoD contractors, and having a robust Vulnerability Management Program is a key component of that journey. With SME’s FedRAMP-approved Vulnerability Management Solution, you can confidently meet CMMC requirements, protect your organization from cyber threats, and secure your position as a trusted DoD contractor.

To learn more about how SME can help you achieve CMMC compliance, contact us today.

Filed Under: Uncategorized

December 11, 2023 By Rich Westbrook

CMMC Rulemaking Updates For End-Of-Year 2023 and Q1 2024

Are You A DoD Contractor With Questions About The Final Rulemaking Process And Implementation Of CMMC 2.0?  

If you answered yes to that question, you’re not alone. 

CMMC 2.0 has been a long time in the making. And while we’re not in the final stage of implementation yet, we’re getting closer by the day.

With timelines for certification stretching into Q1 2025, the time to prepare is now.

In this post, we’ll provide clarification for DoD contractors in these four critical areas:

  • What should you expect to happen this year?
  • What can we expect in early calendar year 2024? 
  • When should you expect CMMC language to start appearing in your contracts? 
  • When should you start your certification process? 

So let’s get started with the basics.

What Should You Expect To Happen This Year?

The good news is the Office of Information and Regulatory Affairs (OIRA) has concluded its review of the CMMC 2 Program, as reported on their official website:     

Courtesy of OIRA

So with the mandatory regulatory review process by OIRA complete, we expect to see the CMMC 2.0 Rule published in the Federal Register sometime before the end of CY 2023. 

Again, that’s great news, but there is still some ambiguity about exactly how the Rule will be published. It could show up as an “Interim Final Rule” or a “Proposed Rule.” 

That designation is important and will have a major impact on when CMMC 2.0 could become effective.

More on that later.

What Can We Expect In Early Calendar Year 2024? 

There are two paths we can expect for CMMC 2.0 in 2024. Those paths depend on how the Rule is published, i.e. as a Proposed Rule or an Interim Final Rule. We found a great explanation of the difference between the two at the Federal Register: 

Interim Final Rule: When an agency finds that it has good cause to issue a final rule without first publishing a proposed rule, it often characterizes the rule as an “interim final rule,” or “interim rule.” This type of rule becomes effective immediately upon publication. In most cases, the agency stipulates that it will alter the rule if warranted by public comments. If the agency decides not to make changes to the interim rule, it generally will publish a brief final rule in the Federal Register confirming that decision.

If the Rule is published as an Interim Final Rule, CMMC will most likely go into effect in Q1 2024, since public comments do not have to be reviewed and addressed before publication of the Final Rule. 

This time frame would provide for a 60 day public comment period after being published in the Federal Register by OIRA in December 2023 with no extensions.

If it’s published as a Proposed Rule, which many experts believe is the more likely scenario, there will be an approximately 12-month public comment review and analysis period before the final CMMC 2.0 Rule takes effect. That takes us into Q1 2025. 

It’s also important to note that DoD will not be making any public comments or official announcements, webinars, etc., until after the final rulemaking process is finished and all public comment and review periods are complete.

Courtesy of DoD CIO

We’re not going to speculate on which scenario is more likely. Instead, we’re going to provide you with actionable information on when and how to prepare for either scenario.

We’ve covered a lot of ground, so let’s wrap it all up.

When Should You Expect CMMC Language To Start Appearing In Your Contracts? 

This one is a binary answer. It looks like either Q1 2024 or Q1 2025. 

If the CMMC 2.0 Rule is published as an Interim Final Rule this December (2023), you’re looking at CMMC 2.0 compliance language and requirements potentially showing up in your contracts in Q1 2024. If it’s published as a Proposed Rule, you’re looking at Q1 2025. 

What does that mean for you as a DoD contractor or subcontractor?

Since NIST 800-171 is the wellspring of the 110 CMMC Level 2.0 certification requirements, we’ll use that standard as your preparedness benchmark to determine your certification timelines. 

When Should You Start Your Certification Process? 

We agree with the DoD CIO:

The Department encourages contractors to continue to enhance their cybersecurity posture during the interim period while the rulemaking is underway.

Now let’s look at some timelines for Levels 1,2, and 3 certifications.

We’re estimating that it will take roughly 2-4 months for an average Level 1 assessment and implementation, where certification by a C3PAO is not required.

We expect that timeframe to be 10-20 months for a CMMC 2.0 Level 2 assessment, implementation, and certification process.

A CMMC 2.0 Level 2 assessment, implementation, and certification process looks like a 12 – 18 month minimum process.

These timelines place an immediate start time on your certification process, even given the best-case scenario of CMMC 2.0 getting published as a Proposed Rule.

As always, your CMMC 2.0 certification timeframe will depend on your organization’s state of cybersecurity readiness and technical capabilities.

If you haven’t started preparing for CMMC 2.0 yet, don’t panic, we’re here to help.    

Actions You Need To Take (And When) To Prepare For The Official CMMC 2.0 Rollout

Let’s start designing your compliance action plan together. And today is the time to get the process started. 

At SME, we have a team of experts with all the extensive experience, CMMC 2.0 knowledge, and certifications that it takes to keep up with today’s incredibly fast-paced world of cybersecurity.

CMMC 2.0 implementation and certification timelines are starting to stretch into Q1 2025. So let’s get prepared today.    

Get in touch with our team at (703) 378-4110 to schedule Your Cybersecurity Assessment Today! 

Filed Under: Uncategorized

October 25, 2023 By Rich Westbrook

CMMC 2.0 Compliant Enclaves In GCC And GCC High For CUI | Just The Facts

We’re all waiting for the final, official word to come down regarding CMMC but the writing is clearly on the wall. CMMC 2.0 is a reality and will become a requirement for DoD contractors. 

The only question is exactly when it will start showing up in contract language.Based on that inevitable scenario, our DoD contractor clients are asking us for guidance on when and what actions to take to prepare for CMMC 2.0 implementation. So please feel free to reach out to our team directly with any questions you might have.

CMMC 2 Compliant Enclaves In GCC And GCC High For CUI

We’ve also been getting a high volume of inquiries surrounding CMMC 2.0 compliance in the context of the Azure Government Community Cloud (GCC). So, we decided to provide some specific information on Controlled Unclassified Information (CUI) Enclaves in Azure Gov, GCC, and GCC High.

Here’s what you’ll learn in this post:

  • What Are CUI Enclaves in the Azure Cloud?
  • What’s the Difference between GCC and GCC High?
  • What Does It All Mean For DoD Contractors?
  • Where Can You Go For Actionable Information?

So let’s get started with some government cloud basics.

What Are CUI Enclaves in the Azure Cloud?

According to NIST, an enclave is “a set of system resources that operate in the same security domain and that share the protection of a single, common, continuous security perimeter.”

That’s an excellent summary. In the cloud, deploying your compute, storage, network, and application resources within a specific security domain means you enjoy the benefits of the certifications that the cloud services provider, including Azure, AWS, etc., has with DoD in that pool of resources. 

That includes CMMC 2.0 compliance certifications. 

Let’s break that down into bite-size chunks.

What Does It All Mean For Small And Medium-Size DoD Contractors?

There’s no one-size-fits-all solution for every contractor’s applications and electronic CUI.

But as we pointed out in a previous post:

Generally speaking, cloud solutions can be an excellent path to reach CMMC 2.0 maturity. The Azure cloud, for example, offers secure, scalable, compliant solutions. 

Specifically, the Azure Cloud Platforms in Azure Gov, Government Community Cloud (GCC), and GCC High have certain features and functionality designed to meet specific CMMC 2.0 requirements.

Which environment is the best place to build your information enclave? For DoD contractors, GCC and GCC High are typically the most effective solutions for a number of reasons.  

Let’s find out what the most optimal, cost-effective solution is for your business together.

Schedule A Call With Your Dedicated CMMC 2.0 Team Today

Regardless of where you are with your current CMMC 2.0 cybersecurity preparedness, don’t be intimidated by looming CMMC compliance requirements. 

Our team has the extensive experience you need to build the right CUI enclave in Azure Gov, GCC, or GCC High. Building the right enclave can make your CMMC compliance journey simple and cost-effective.

An optimized CUI enclave can typically meet 70-80% of the technical controls required for CMMC compliance.

Are you ready to meet your new team of cybersecurity experts? We’re ready to roll up our sleeves and partner with you to plan and navigate your CMMC 2.0 certification every step of the way, from start to finish. 

Call us at 703-782-9140 to schedule Your Free Cybersecurity Assessment Today! 

Filed Under: Uncategorized

August 17, 2023 By Rich Westbrook

CMMC Is In Final Approval

CMMC Is In Final Approval

The CMMC framework has officially been submitted for its 90-day review.

After being formally announced in September 2020, the Cybersecurity Maturity Model Certification framework is now coming to fruition.

Submission of the CMMC program by the DoD, to the OMB’s Office of Information and Regulatory Affairs (OIRA), was reported on by Defense Scoop in a July 25 article:

DOD sent its CMMC framework to OMB’s Office of Information and Regulatory Affairs, which will take the next 90 days or less to review the rule…

While the submission signifies yet another period of uncertain waiting for the DOD contracting community to see what happens in what’s already been a yearslong journey, it does solidify the fact that DOD has come to a consensus on a final rule and that CMMC is coming in the not-so-distant future.

So what does it all mean for small and medium businesses in the defense industrial base?

We’ll provide you with answers in this post. Here’s what you can expect to learn:

  • A Quick Review Of CMMC 2.0
  • What’s Next In 2023 And What To Expect In 2024
  • The Recent Announcement And What It Means For Our Clients
  • Actions You Need To Take (And When) To Prepare For The CMMC 2.0 Rollout 
  • What You Need To Do Next 

So let’s start at the beginning.

A Quick Review Of CMMC 2.0

We did a full review of the history of CMMC 2.0 in a previous blog post. So let’s sum it up for review:

DoD did a 9+ month review of CMMC 1.0 from late 2020 well into 2021, without releasing any meaningful information. There was a fair amount of industry chatter about what was happening with the process, but nothing official.

This quiet period continued well into 2021, and nothing much new happened until November 4. That’s when the official release of CMMC 2.0 was officially announced. 

Activity around CMMC 2.0 picked up significantly after the press release, in the form of DIB discussions, speculation, webinars, etc. The scuttlebutt continued throughout calendar year 2022.

So here we are in mid-2023, and the CMMC framework has officially been submitted to the OMB’s OIRA for a 90-day (or less) review.

Where do we go from here?

What’s Next In 2023 And What To Expect In 2024

The rulemaking process is underway, and we won’t know for sure where CMMC is headed for 90 days or so, as the DoD CIO points out:

But there are essentially two paths CMMC 2.0 can take when it’s published to the Federal Register. It can either be published as a proposed new rule or regulation or as an interim final rule. The first scenario would kick off a lengthy process that could take a year or more.

If it’s published as an interim final rule, which we feel is the more likely scenario, it would take effect as a final rule immediately and begin to roll out over the next 60 days.

We could start to see CMMC requirements in DoD contracts immediately as part of a phased rollout. 

But how will it affect DIB contractors?

The Recent Announcement And What It Means For Our Clients

Courtesy of OIRA

Regardless of what happens, we agree with Defense Scoop from the perspective that “CMMC is coming in the not-so-distant future.”

Preparing for CMMC 2.0 under the NIST 800-171 guidelines is a process that can take 12-18 months. So today is an excellent time to get started with an assessment of your security posture in the context of the CMMC/NIST guidelines.

The federal government is also pushing DoD contractors to the cloud, to take advantage of cybersecurity capabilities at scale and meet the stringent DoD data protection standards in CMMC 2.0.

If your infrastructure is not in the cloud yet, there’s no need to panic. But you will need to start making some technology decisions in the very near future.

So let’s figure out where you are currently with regard to cybersecurity, where you need to go, and what it will take to get there.

Actions You Need To Take (And When) To Prepare For The CMMC 2.0 Rollout

Regardless of where you’re at with your CMMC 2.0 cybersecurity preparedness, don’t be intimidated. We’re here to help.

Let’s start designing your compliance action plan together. And today is a great time to get started.

At SME, we have a team of experts with all the extensive experience, CMMC 2.0 knowledge, and certifications that it takes to keep up with today’s incredibly fast-paced world of cybersecurity.

 We’re laser-focused on information security, so you don’t have to be. 

Hopefully you’re feeling more confident already.

Call us at (703) 782-9140 to schedule Your Free CMMC 2.0 Cybersecurity Assessment Today!

Filed Under: Uncategorized

August 15, 2023 By Rich Westbrook

From Awareness to Action: 5 Steps to Enhance Corporate Cybersecurity

In the modern digital landscape, cybersecurity is more than just an IT issue—it’s a business imperative. With cyber threats evolving at an unprecedented pace, companies must be proactive in protecting their critical data and systems. This guide outlines five crucial steps businesses can take to fortify their cyber defenses.

Step 1: Empowering Through Education on Cyber Threats

Cybersecurity begins with understanding the nature of the threats your organization faces. In a business environment where the threat landscape is constantly evolving, knowledge and awareness are critical. It’s essential for all members of your team, from the most junior to the C-suite executives, to have a solid understanding of what cyber threats look like and how they can impact the company.

The first step to achieving this is implementing regular cybersecurity training for all employees. This training should cover the basics, such as recognizing phishing emails and securing personal devices, but it should also delve into more advanced topics relevant to your industry. Tailoring the content to specific roles or departments can enhance the effectiveness of this education.

Moreover, the training should be an ongoing process and not a one-time event. Cyber threats evolve rapidly, with new types of malware, vulnerabilities, and exploits emerging daily. Hence, training sessions should be held regularly, updating employees about the latest threats and countermeasures. Encourage your team to engage with the materials, asking questions and contributing their own experiences or insights.

Step 2: Rigorous Implementation of Access Controls

The computer security concept of the principle of least privilege (PoLP) advocates for granting users only the minimal access levels necessary for carrying out their specific job roles. This principle is critical in creating an effective access control strategy. By carefully managing who has access to what information, companies can significantly reduce the risk of an internal data breach.

Access controls should be applied not just to physical areas, like server rooms, but also to digital assets such as databases, networks, and files. Setting up granular access controls can help ensure that employees can access only the information they need to do their jobs, preventing unauthorized access to sensitive data.

Furthermore, it is essential to conduct regular audits of these access controls. Over time, due to changes in roles or responsibilities, some employees might accumulate access privileges that they no longer need. These unnecessary privileges can pose a security risk. Regular audits help identify such cases, enabling the company to maintain tight control over who can access its critical resources.

Step 3: Authenticating Users Thoroughly

Authentication is a vital component of a robust cybersecurity framework. It verifies the identities of those seeking access to your systems and data, ensuring that only legitimate users can get in. While the traditional username and password combination is still the most common form of authentication, it’s far from the most secure. Cybercriminals often target weak or stolen credentials to gain unauthorized access to systems.

For a more secure approach, consider implementing multi-factor authentication (MFA). This method requires users to provide two or more verification factors to gain access, making it significantly more challenging for unauthorized individuals to breach your systems. These factors can include something you know (like a password), something you have (such as a mobile device), and something you are (biometric data like fingerprints or facial recognition).

As part of the authentication process, it’s also essential to have strong password policies in place. These might include requirements for password complexity and length, guidelines for changing passwords regularly, and advice on avoiding common password pitfalls.

Step 4: Monitoring Your Physical Space

While it’s crucial to secure digital spaces, companies must not overlook the importance of physical security. The workspace can often be a weak link in your security chain. Sensitive information is not just stored digitally; it also exists in physical formats such as paperwork, and unauthorized access to these can pose serious security risks.

For this reason, businesses need to ensure robust physical security measures are in place. Surveillance systems, such as CCTV cameras, can monitor premises, deter malicious actors, and provide crucial evidence in the event of a breach. Furthermore, access controls should extend to physical spaces like offices, server rooms, and storage areas to prevent unauthorized access.

Beyond these measures, a culture of security awareness should permeate the company. Employees should understand the importance of locking screens when away from their desks, securely disposing of sensitive documents, and reporting suspicious behavior.

Step 5: Regularly Update Security Protections

Cyber threats are an ever-evolving challenge, with new vulnerabilities emerging regularly. To keep up with this constant change, businesses must regularly update and patch their software and hardware security protections. This includes operating systems, anti-virus software, firewalls, and more.

Timely patch management is crucial, as cybercriminals are known to exploit software vulnerabilities before companies have a chance to fix them. Automatic updates should be enabled wherever possible, and a structured patch management process should be in place to ensure that no device falls behind on critical security updates.

Beyond these updates, companies should also continuously evaluate their overall security strategy, incorporating new technologies and practices as they become available. This might include adopting cutting-edge solutions like AI-based threat detection, encrypted communication, or blockchain technology for secure transactions.

Securing Your Digital Future

In this digital age, the security of your company depends on more than just firewalls and antivirus software; it depends on the collective effort of every individual within the organization.

Remember, cybersecurity isn’t a one-and-done task, but an ongoing effort. It requires constant vigilance and adaptation to stay one step ahead of the threats. Adopting a proactive stance towards cybersecurity can help your organization navigate the digital landscape with confidence and resilience, safeguarding your critical data, your operations, and your reputation.

Building a strong cybersecurity framework is an ongoing effort that requires constant vigilance and adaptation to emerging threats. SME, Inc. offers a comprehensive suite of services and solutions to help your company build a robust cybersecurity plan. By leveraging their expertise, cutting-edge technologies, and proactive approach, SME, Inc. can empower your organization with the necessary tools and knowledge to mitigate risks, protect sensitive information, and maintain a secure environment for your business operations.

Filed Under: Uncategorized

July 19, 2023 By Rich Westbrook

Exploring the Latest Updates to NIST SP 800-171 in Relation to Cybersecurity Maturity Model Certification for Government Contractors

Exploring the Latest Updates to NIST SP 800-171 in Relation to Cybersecurity Maturity Model Certification for Government Contractors

Government contractors play a critical role in supporting various agencies and handling sensitive information. To safeguard this data from cyber threats, the U.S. government has established guidelines and frameworks. One such framework is the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, which outlines requirements for protecting Controlled Unclassified Information (CUI). In addition, the Cybersecurity Maturity Model Certification (CMMC) program has been introduced to assess the cybersecurity maturity of government contractors. 

In this blog post, we will explore the latest updates to NIST SP 800-171 as they relate to CMMC, providing insights into how these changes impact government contractors and their journey towards certification.

Overview of NIST SP 800-171

NIST SP 800-171 focuses on safeguarding CUI in non-federal systems and organizations. It outlines a set of 110 security requirements across 14 control families. These requirements cover various aspects of cybersecurity, including access control, incident response, security awareness, and more. Contractors working with the U.S. government must comply with these requirements to protect CUI.

Introduction to the CMMC Program

The Cybersecurity Maturity Model Certification (CMMC) program builds upon NIST SP 800-171 and introduces a tiered approach to assess the cybersecurity maturity of government contractors. CMMC includes five levels, ranging from basic cyber hygiene practices to advanced and proactive security measures. Contractors must achieve the appropriate CMMC level to bid on contracts, depending on the sensitivity of the information they handle.

Alignment between NIST SP 800-171 and CMMC

The latest updates to NIST SP 800-171 have been made to align with the CMMC program. The revised publication incorporates enhanced security controls and updates from the current version of the NIST Risk Management Framework (RMF). This alignment ensures that contractors who meet the requirements of NIST SP 800-171 will be on the path to achieving CMMC certification.

Impact of the Updates on Government Contractors

The updates to NIST SP 800-171 introduce additional security controls and guidelines that contractors must address to enhance their cybersecurity posture. Some of the notable changes include requirements for multifactor authentication, incident response testing, encryption, and supply chain risk management. Contractors need to evaluate their current practices and implement necessary changes to comply with the updated controls.

Navigating the Certification Process

To achieve CMMC certification, government contractors must undergo a rigorous assessment conducted by authorized Third-Party Assessment Organizations (C3PAOs). These assessments evaluate an organization’s implementation of security controls outlined in NIST SP 800-171 and additional CMMC requirements. Contractors should leverage the guidance provided by NIST and engage with experts to prepare for the certification process.

The evolving cybersecurity landscape demands continuous improvements in protecting sensitive information. The updates to NIST SP 800-171 demonstrate the government’s commitment to strengthening cybersecurity measures for government contractors. By aligning with the CMMC program, these updates provide a clear roadmap for contractors to enhance their cybersecurity maturity. It is essential for government contractors to stay informed about these updates, evaluate their current practices, and invest in the necessary measures to achieve compliance and certification, thereby ensuring the protection of sensitive government information.

SME will work with your team to achieve compliance with these four straightforward services:

  • NIST 800-171 Compliance Assessment
  • Plan of Action and Milestones (POAM) Development
  • Cybersecurity Policy Development
  • Employee Training and Awareness

Let’s get started with a complimentary consultation to discuss where you are today and where you need to be with your cybersecurity posture. Contact SME today at (703) 378-4110 to discuss the next steps in your action plan.

Filed Under: Uncategorized

June 23, 2023 By Rich Westbrook

CMMC 2.0 And Cybersecurity for DoD Contractors In 2023

DoD contractors are seeking clarification on timelines and actionable solutions to take them down the path to cybersecurity maturity within the CMMC 2.0 program.

That was a mouthful.

And if you’re a small or medium size DoD contractor looking for CMMC 2.0 solutions and guidance, you’re in the right place to get answers.

Here’s what you’ll learn in this post:

  • What Is CMMC 2.0? (Brief Overview)
  • What Are The Timelines For Reaching The Three Maturity Levels?
  • Are Cloud Solutions Viable?
  • Are SPRS Scores Tied To CMMC Maturity? 
  • What Actions Do You Need To Take Today?

Systems Management Enterprises, Inc., is a Virginia-based Information Technology and Security Company offering a portfolio of compliance-tested, cost-effective solutions for small and medium enterprises in the DoD space. 

We are here to help

If you could use some expert assistance navigating the complex world of CMMC compliance and cybersecurity, get in touch with our team today.

Now let’s drill down into CMMC 2.0 and its impact on DoD contractors. We’ll get started with a quick review of the basics.

What Is CMMC 2.0 (Brief Overview)?

In a nutshell, the Cybersecurity Maturity Model Certification is a maturity model that represents a culmination of efforts by the DoD. The intent is to safeguard federal contract information (FCI) and controlled unclassified information (CUI) routinely used and processed by the defense industrial base, or DIB. 

The DIB comprises over 100,00 diverse contractors and subcontractors supplying a broad spectrum of products and services to the DoD. 

The foundational standards codified in CMMC 2 derive from the National Institute of Standards and Technology (NIST) SP 800-171 specification. Here’s how NIST defines the specification:

NIST SP 800-171 is a NIST Special Publication that provides recommended requirements for protecting the confidentiality of controlled unclassified information (CUI).  Defense contractors must implement the recommended requirements contained in NIST SP 800-171 to demonstrate their provision of adequate security to protect the covered defense information included in their defense contracts, as required by DFARS clause 252.204-7012

CMMC 2.0 supersedes CMMC 1.0, which was DoD’s first attempt at a cybersecurity maturity model. CMMC version 2.0 streamlines the original model from five maturity levels to three, and from 171 practices to 110 that more closely align with NIST SP 800-171.

CMMC Model 2
https://dodcio.defense.gov/CMMC/about/

Based on the current state of the CMMC program, we’re getting this next question a lot from our DoD contractor clients. 

What Are The Timelines For Reaching The Three Maturity Levels?

Let’s review the evolution of the CMMC 2.0 cybersecurity model and update you on what you need to do next as a DIB contractor.

DoD did a 9+ month review of CMMC 1.0 from late 2020 well into 2021, without releasing any meaningful information. There was a fair amount of industry chatter about what was happening with the process, but nothing official.

This quiet period continued well into 2021, and nothing much new happened until November 4. That’s when the official release of CMMC 2.0 was officially announced. 

From the DoD press release:

The enhanced “CMMC 2.0” program maintains the program’s original goal of safeguarding sensitive information, while:

Simplifying the CMMC standard and providing additional clarity on cybersecurity regulatory, policy, and contracting requirements;

Focusing the most advanced cybersecurity standards and third-party assessment requirements on companies supporting the highest priority programs; and

Increasing Department oversight of professional and ethical standards in the assessment ecosystem.

Activity around CMMC 2.0 picked up significantly after the press release, in the form of DIB discussions, speculation, webinars, etc. The scuttlebutt continued throughout calendar year 2022.

So here we are in mid-2023. We’re advising our clients that one of the most consistent talking points from DoD over the past 18 months has been that it will officially introduce CMMC 2.0 into the rule-making process for a 2023 rollout.

It appears that the CMMC 2 rulemaking process is imminent.

So what do DIB contractors need to know about CMMC 2.0 in 2023?

Based on our experience, we think it’s likely that we will start seeing CMMC 2.0 requirements in DoD contract language this summer, possibly by late July or August.

This is what DoD officially has to say: 

The publication of materials relating to CMMC 2.0 reflect the Department’s strategic intent with respect to the CMMC program; however, CMMC 2.0 will not be a contractual requirement until the Department completes rulemaking to implement the program. The rulemaking process and timelines can take 9-24 months. CMMC 2.0 will become a contract requirement once rulemaking is completed.

That puts the rulemaking process and timelines at November 2023 at the latest. But it’s important to note that the rulemaking process is largely complete, and many of the initial public comments have been incorporated in CMMC 2.0. 

What’s the bottom line? If it’s released to rulemaking in June with minimal public comments, CMMC 2.0 could potentially take effect immediately.

Contractors are looking for solutions and a path forward for compliance.

Are Cloud Solutions Viable?

Our team is fielding tons of questions about cloud services as potential solutions for CMMC 2.0 certifications.  

Generally speaking, cloud solutions can be an excellent path to reach CMMC 2 maturity. The Azure cloud, for example, offers secure, scalable, compliant solutions. 

Specifically, the Azure Cloud Platforms in Azure Commercial, Government Community Cloud (GCC), and GCC High have certain features and functionality designed to meet specific CMMC 2 requirements. 

We can help you navigate cloud solutions in the context of cost, timelines, and viability.

Are SPRS Scores Tied To CMMC Maturity? 

We wanted to clarify a few persistent questions we’re getting from our clients concerning SPRS scores and CMMC 2. 

While these two programs are not officially tied together in any way, there is some overlap. 

DoD has recently issued a final ruling that requires contracting officers to consider supplier risk assessments in the Supplier Performance Risk System (SPRS) when evaluating offers.  

While your SPRS score is independently calculated, it is based on a points system that’s tied to each of the 110 controls in the CMMC program.

So contractors can potentially increase their SPRS score, improve CMMC readiness, and at the same time improve their chances of winning DoD contracts by completing a NIST 800-171 assessment.

Now let’s consider your next steps.

What Action Do You Need To Take Today?

Is the looming CMMC 2.0 program mandate keeping you at night? Are you a DoD contractor with questions about CMMC, SPRS, and cloud solution requirements?

Regardless of where you are in your compliance journey, we’re here to help with cost-effective, small-business-optimized cybersecurity solutions.

Let us handle your information security so you can focus on growing your business. 

Right now, we’re offering a complimentary CMMC 2 cybersecurity compliance assessment with no obligation and no cost to you. 

That’s right, you have everything to gain and nothing to lose.

Call us at 703-378-4110 to schedule Your Free Cybersecurity Assessment Today! 

Filed Under: Uncategorized

May 5, 2023 By Rich Westbrook

What Are The New Best Practices for ALTA Pillar 3 Version 4?

What Are The New Best Practices for ALTA Pillar 3 Version 4?

What are the latest best practices in ALTA Pillar 3 for title companies, their workforces, and their security infrastructures?

That’s a great question. And we’ve been getting it a lot lately from title company owners, executives, and IT teams. 

So we decided to provide you with some definitive answers in this post.

Here’s what you can expect to learn:

  • What Are The Changes to ALTA Pillar 3 In Version 4.0?
  • What Do Title Companies Need To Know About ALTA Best Practice 3?
  • What To Do Next To Prepare For ALTA Pillar 3 Compliance

Let’s get started with the basics.

What Are The Changes to ALTA Pillar 3 In Version 4.0

ALTA announced the release of version 4 of its Best Practices Framework in a letter on January 23, 2023, with an effective date of May 23, 2023, for implementation. Here’s what they had to say about Pillar 3:

Though not reflecting the full extent of the proposed changes, the revisions that have received significant areas of attention include:

Pillar 3 (Privacy and Information Security Programs to protect NPI): Updates to the physical protection of NPI, inclusion of network and cloud security of NPI, further details on coverage of business continuity and disaster recovery plans, further details on the required oversight of service providers and third party systems, use of the ALTA Cybersecurity Incident Response Plan Template as a reference document for the written incident response plan, and requiring processes for addressing breaches or unauthorized access to NPI.

That covers the new requirements of Version 4 at a high level. All of the legacy Pillar 3 requirements from Version 3.0, like annual vulnerability and risk assessments, security awareness training, etc., are also still in place.

Pillar 3 is all about protecting Non-Public Personal Information, aka NPI. 

As a quick refresher, NPI typically includes a first name or initial and a last name combined with—Social Security Number, driver’s license number, state-issued ID number, credit or debit card number, other bank or financial account information.

It’s also important to note that NPI can be maintained and stored in physical and/or digital format. NPI can be contained in customer applications, transaction records, files, and other relevant customer documents and communications. 

Storage for records containing NPI might be maintained physically on-premise, in third-party physical archives, or in rented or leased facilities. Electronic storage might include on-prem computers and servers, remote work computers, mobile devices and laptops, colocated computers, and cloud servers and storage.

The bottom line is all NPI must be maintained according to Pillar 3 requirements. Incidents that led, or might have led, to compromised NPI must also be reported. 

ALTA has provided numerous resources to help title agencies and settlement services companies comply with Title Insurance and Settlement Company Best Practices Version 4. 

But it’s important to note that these resources and documents are intended for large, comprehensive security and IT teams that are beyond the scope of most small and mid-sized companies. 

That’s where we can help.

What Do Title Companies Need To Know About ALTA Best Practice 3?

We’ve summarized the new ALTA Pillar 3 requirements contained in the Best Practices Version 4 framework. This is what it looks like at a high level.

From the ALTA Title Insurance and Settlement Company Best Practices Version 4, the Pillar 3 section starts with the requirement for a WISP, or Written Information Security Plan:

[Pillar] 3. Best Practice: Adopt and maintain a written information security plan (“WISP”) and a written privacy plan to protect NPI as required by local, state, and federal law.

Establish and implement a WISP designed to protect the security and confidentiality of NPI and the security of the Company’s information systems. The WISP should include:

In a nutshell, these are the main NPI security components:

  • Multi-factor user authentication
  • Password management plan that requires unique login names and system

passwords to access systems containing NPI 

  • Timely software updates 
  • Physical security (including background checks)
  • Network and cloud security policies to protect NPI on IT systems and infrastructure
  • Development of guidelines for the appropriate use of information technology

Preparedness and Training

This summarizes the requirements of the Preparedness and Training Section:

  • Establish, and periodically test, a written business continuity and disaster

recovery plan 

  • Establish, and periodically test, a written incident response plan designed to

promptly respond to, and recover from, a cybersecurity incident

  • Periodically review the Company’s security controls and the Company’s WISP and make appropriate changes to address emerging threats and risks to the

Company’s information systems and NPI

  • Establish a training program to guide management and employee compliance with Company’s WISP and awareness of current and developing cybersecurity threats

We also paraphrased the last three major requirements of ALTA Pillar 3 v4:

Comply with applicable federal and state laws pertaining to securely maintaining records containing NPI. 

Select service providers, contractors, consultants, and third-party systems whose information security policies are consistent with the Company’s WISP, including software tools and resources which may have access to NPI or store records containing NPI as part of their setup or operation. 

Establish a privacy policy explaining how data is collected and used and publish it on Company’s website(s) or provide information directly to Consumers in another useable form.

To sum it all up, there are significant technology and physical security measures required in the latest version of ALTA Pillar 3 for title and settlement services companies. These measures impact your choice of vendors, consultants, service providers, software, hardware, and cloud  solutions.

And the new version of ALTA Best Practices takes effect on May 23, 2023.

We recognize that you’re focused on serving your clients, not on physical and cyber security policies surrounding the collection and maintenance of NPI.

That’s why it’s time to meet your ALTA Title Insurance and Settlement Company Best Practices Version 4 compliance team.

What To Do Next To Prepare For ALTA Pillar 3 Compliance

SME is here to assist title agencies from start to finish in order to successfully meet ALTA Best Practice 3. Here’s what you can expect:

  • Our team will perform a pre-assessment to determine your readiness level 
  • Our team will lay out a comprehensive plan to help you organize your compliance efforts
  • Our team will recommend and implement security products and services as directed by your team
  • Our team will work with you and your team to document and report successful completion of Best Practice 3
  • We’ll be mindful of your budget and timeframe for implementation

Systems Management Enterprises, Inc. is a Virginia-based Information Technology and Security Company offering a variety of purpose-built, cost-effective solutions for your business needs. 

We’ve been in business for over a decade—providing infrastructure services, managed security, compliance solutions, and technical support to small and medium enterprises in the title services space.

At SME, we have the experience, expertise, services, and solutions to help you  maintain a secure, always-available, compliant technology infrastructure. 

Do you have questions? 

We’re here to help. Call us at 703-782-9140 or Schedule Your Free ALTA Best Practice 3 Assessment Today! 

Filed Under: Uncategorized

April 17, 2023 By Rich Westbrook

New Ruling on SPRS Score and NIST 800-171 Assessment

New Ruling on SPRS Score and NIST 800-171 Assessment

The Department of Defense (DoD) recently issued a final ruling that requires contracting officers to consider supplier risk assessments in the Supplier Performance Risk System (SPRS) when evaluating offers. This ruling is an effort to improve the cybersecurity of the defense industrial base (DIB) by encouraging contractors to implement strong cybersecurity measures and effectively manage their supply chains. 

Under the old DFARS 7019 ruling, contractors were required to enter their score into SPRS with the assumption that contracting officers might be checking to confirm the score was in there before the decision was made to award a contract.

Contracting officers are now instructed by the final rule to consider assessments, if available, in determining contractor responsibility through the new solicitation provision called DFARS 252.204-7024, effective March 22, 2023. The new ruling makes checking the score a requirement before awarding a contract.

One of the key ways that contractors can improve their SPRS score, and therefore their chances of winning DoD contracts, is by completing a NIST 800-171 assessment. This assessment is a set of cybersecurity standards developed by the National Institute of Standards and Technology (NIST) that contractors must meet in order to do business with the DoD.

However, completing a NIST 800-171 assessment can be a complex and time-consuming process. That’s where Systems Management Enterprises (SME) comes in. SME is a leading provider of cybersecurity and compliance solutions for government contractors, and they can help contractors navigate the NIST 800-171 assessment process and improve their SPRS score.

SME offers a comprehensive suite of services designed to help contractors meet NIST 800-171 requirements and improve their cybersecurity posture. These services include:

  1. NIST 800-171 Compliance Assessment: SME’s team of cybersecurity experts will conduct a thorough assessment of your organization’s current cybersecurity posture and identify any gaps or vulnerabilities that need to be addressed to meet NIST 800-171 requirements.
  2. Plan of Action and Milestones (POAM) Development: SME will help you develop a comprehensive POAM that outlines the steps you need to take to address any gaps or vulnerabilities identified during the compliance assessment.
  3. Cybersecurity Policy Development: SME can help you develop and implement cybersecurity policies and procedures that meet NIST 800-171 requirements and align with your organization’s overall cybersecurity strategy.
  4. Employee Training and Awareness: SME can provide cybersecurity awareness training to your employees to help them understand their role in protecting sensitive information and preventing cyberattacks.

By partnering with SME, contractors can improve their SPRS score and demonstrate to the DoD that they are taking cybersecurity seriously. SME’s team of cybersecurity experts can help contractors navigate the complex world of cybersecurity compliance and ensure that they are meeting all relevant standards and regulations.

Contractors can improve their chances of winning DoD contracts by completing a NIST 800-171 assessment and improving their SPRS score. SME can help contractors navigate the assessment process and improve their cybersecurity posture, ensuring that they are well-positioned to compete in the DIB. Contact us to today to get started!

Filed Under: Uncategorized

  • 1
  • 2
  • 3
  • …
  • 7
  • Next Page »

Contact Us

    Your Name

    Your Email

    Subject

    Your Message

    Recent Post

    The Department of Defense (DoD) has taken a significant step in enhancing the cybersecurity framework for defense … More »

    What Our Clients Say

    "SME handles all of our internet hosting needs, providing a reliable, high-performance, secure and cost-effective platform for us to host web-based systems for biotech companies. We have been consistently impressed with the responsive, knowledgeable and professional service we receive."

    Simply Making IT Easier!TM
    Local: 703-378-4110
    Toll Free: 855-2-SMEINC
    Email: info [at] smeinc.net

    Copyright © 2024 · Systems Management Enterprises, Inc. · Privacy Policy · Terms of Service