The Cybersecurity Maturity Model Certification (CMMC) was formally made part of the Defense Federal Acquisition Regulation Supplement (DFARS) in January of 2020 and updated to CMMC 2.0 in November of 2021. The decision sent over 300,000 members of the defense industrial base (DIB), primarily small and midsize businesses (SMBs), into a state of frenzy. Most found themselves drowning in all kinds of unnecessary noise surrounding CMMC and its implications on existing and future government contracts.
The chaos increased when the Interim DFARS Rule (DFARS Case 2019-D041) joined the foray on November 30, 2020. This rule mandates all defense contractors to perform self-assessments of their cybersecurity using the NIST CSF (SP) 800-171 DoD Assessment Methodology to qualify for new defense contracts and renewals of current contracts.
Amid all the deliberation and scrutiny, let’s try understanding the Interim DFARS Rule and its impact on you as a member of the DIB. In this short blog, we will tell you what in the Interim DFARS Rule changed, what it mandates contractors to do and what your next immediate step should be with this latest mandate by the Department of Defense (DoD).
What changed in the Interim DFARS Rule?
This is not the first time the DoD has emphasized the need for defense contractors to follow the 110 cybersecurity controls defined in the National Institute of Standards and Technology (NIST) Special Publication 800-171, generally referred to as “800-171.”
Even prior to the adoption of CMMC, DFARS mandated most defense contractors to merely attest to the fact that they followed all the controls specified in 800-171. However, many non-compliant contractors’ and sporadic government audits led to controlled, unclassified information (CUI) being leaked.
Therefore, in a bid to counter potential security threats, the Interim DFARS Rule requires contractors to complete self-assessments and formally score their 800-171 compliance status based on a specific scoring system developed by the DoD. The post-assessment score must be uploaded to a federal database – the Supplier Performance Risk System (SPRS) — for the contractor to qualify for new contracts and renewals.
The deadline to conduct a self-assessment and upload it to the SPRS database was November 30, 2020 if you intend to accept any DoD-related contracts that include the flow down of contract clause DFARS 252.204-7012 issued after December 1, 2020.
Now that you understand the urgency with which you must approach complying with the Interim DFARS Rule, let’s discuss how the interim rule scoring works.
Self-assessment and the scoring matrix
During the self-assessment, contractors are expected to rate themselves based on the implementation of each of the 110 NIST (SP) 800-171 cybersecurity controls. The CMMC requires DoD contractors to conduct these self-assessments once every three years unless anything necessitates a change. Because contractors are subject to DoD and prime contractor audits at any time, it is critical to maintain the cybersecurity controls and have recent documentation validating that everything has remained secure and compliant.
The assessment scoring begins with a perfect score of 110 for each NIST 800-171 control. Points are then subtracted for the non-implementation of controls. Each control holds a weighted point value ranging from one to five based on its significance.
No credit is given for partially implemented controls, except for multifactor authentication and FIPS-validated encryption. Although NIST does not prioritize security requirements, it declares that some controls bear a higher impact on a network’s security.
Here are three things you must remember with respect to the self-assessment:
- If you do not receive a perfect score of 110 points, you must create a Plan of Action and Milestones (POA&M) document outlining how the deficiencies will be addressed and the failing items remediated. You can update your score when the shortcomings are addressed and remediated.
- As a contractor, you must also develop a System Security Plan (SSP) with details of implemented NIST 800-171 controls such as operational procedures, organizational policies and technical components.
- Neither SSPs nor POA&Ms are uploaded to the federal database but must be available for audit.
- Upon concluding the self-assessment, you must submit your score to the governmental SPRS database within 30 days.
Now that we have established all that you must do, there’s no time to waste. Here’s what you immediately need to do.
Get assessment-ready now!
To qualify for new contracts and renewals while CMMC is being rolled out, you must start gearing up to conduct a thorough and accurate self-assessment and do whatever it takes to fulfill today’s cybersecurity requirements. This way, you will comply with the Interim DFARS Rule and be prepared for every future development with respect to CMMC.
Navigating through the complexities of CMMC can be both complex and overwhelming. That’s why having an experienced partner to shoulder the responsibility will ease the pressure on you. We would love to chip in with our best efforts. Contact us to schedule a compliance assessment or consultation.