CMMC Certification Requirements

The Cybersecurity Maturity Model Certification (CMMC), released in January 2020 and updated in March 2020, was created to ensure the protection of Controlled Unclassified Information (CUI). However, CMMC also applies to vendors with access to Federal Contract Information (FCI). CMMC was originally created by the Department of Defense (DoD) to ensure that the vendors submitting defense contract proposals had adequate cybersecurity protections. More details about CMMC requirements are discussed below.

What is Controlled Unclassified Information (CUI)?

CUI is information owned or created by the government but is not considered classified. Although CUI is not classified, it is still important to protect the information from unauthorized access, disclosure, alteration, or destruction. 

What is Federal Contract Information (FCI)?

FCI is information created or provided by the Government regarding a contract that provides information on products or services that a vendor delivers or develops to the Government. This information is not intended for public release. 

CMMC Certification

Before the enactment of CMMC, vendors were required to conduct self-audits to assess their compliance with NIST SP 800-171. However, self-assessments are prone to user error and can be deliberately manipulated to produce desired results. As such, under the new CMMC guidelines, the DoD is rejecting the concept of self-assessments. DoD vendors must now undergo a third-party audit to determine the level of CMMC certification they have achieved.

CMMC certification is considered “go or no go,” meaning a vendor must prove that they have met all of the requirements under their level of certification. If they have not met even just one requirement, they cannot be certified at that level. In addition, all answers will require proof that the process has been implemented, and a weighted score will be issued to determine their effectiveness. 

Who Needs to Comply with CMMC?

Any contractor, including subcontractors, that work with or on behalf of the DoD must comply with CMMC requirements. This includes any vendor that works in the DoD supply chain, referred to as ‘Prime Contractors’ and ‘Subprime Contractors.’ 

• Prime Contractors. These are contractors that have the contract with the DoD. They generally have access to Controlled Unclassified Information requiring them to be CMMC certified at, at least, Level 3.
• Subprime Contractors. These are contractors that supply the prime contractors. Weaknesses in a subprime contractor’s cybersecurity can have a direct impact on Prime Contractors which is why they must also comply with CMMC standards, although at a lower level than Prime Contractors.

There is a misconception that vendors that already have contracts with the DoD do not need to comply with CMMC standards. This, however, is misleading. Although a vendor currently under contract with the DoD will not need to become CMMC certified right away, they will need to do so when it comes time to renew their contract. They will also need to earn their CMMC certification if they are looking to win new contracts within the Department of Defense supply chain. A vendor cannot renew or get new contracts if they don’t comply with CMMC.

HIPAA and CMMC

While CMMC does not directly apply to healthcare providers, the recent cybersecurity bill, HR 7898, now requires the Department of Health and Human Services (HHS) to incentivize a covered entity’s or business associate’s cybersecurity best practices. 

For instance, if a healthcare organization experienced a breach and was under investigation by HHS’ Office for Civil Rights (OCR), their ability to prove that they implemented a recognized cybersecurity framework (at least 12 months prior to the breach) would free them from blame. So instead of being subject to fines, they would receive technical assistance from HHS.

Recognized cybersecurity frameworks include:

• Standards, guidelines, best practices, methodologies, procedures, and processes developed under the National Institute of Standards and Technology Act (NIST Act).
• The cybersecurity practices developed under section 405(d) of the Cybersecurity Act of 2015.
• Programs and practices that are developed in, recognized by, or set forth in federal laws other than HIPAA, such as CMMC.

CMMC requirements are more comprehensive and modern in their approach to cybersecurity, and can be implemented by healthcare organizations as an effective way to mitigate their risks and comply with HR 7898.

What Are CMMC Requirements?

CMMC requirements differ based on the level of access to sensitive government information the vendor has. The DoD has broken CMMC requirements into five levels. Level 1 is the lowest level of CMMC certification, while Level 5 is the highest level. Additionally, each level is cumulative. For instance, vendors required to meet Level 5 CMMC certification must meet CMMC requirements for each level below it. 

CMMC requirements are also divided into 17 domains including:

• Access Control
• Asset Management
• Awareness and Training
• Audit and Accountability
• Configuration Management
• Identification and Authentication
• Incident Response
• Maintenance
• Media Protection
• Personnel Security
• System and Information Integrity
• System and Communications Protection
• Situational Awareness
• Security Assessment
• Physical Protection
• Risk Management
• Recovery

CMMC Level 1 (Safeguard Federal Contract Information) 

The lowest level of CMMC certification is CMMC Level 1. This level of certification is required for vendors that do not possess or have access to CUI. These vendors do, however, have access to Federal Contract Information (FCI). These vendors are required to practice ‘Basic Cyber Hygiene.’ Level 1 requires certain processes to be implemented referred to as ‘Performed’ processes.

Required processes for CMMC Level 1 are as follows.

Access Controls.

• Limit information access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).
• Limit information system access to the types of transactions and functions that authorized users are permitted to execute.
• Verify and control/limit connections to and use of external information systems.
• Control information posted or processed on publicly accessible information systems.

Identification and Authentication

• Identify information system users, processes acting on behalf of users, or devices.
• Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.

Media Production

• Sanitize or destroy information system media containing Federal Contract Information before disposal or release for reuse.

Physical Protection

• Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.
• Escort visitors and monitor visitor activity.
• Maintain audit logs of physical access.
• Control and manage physical access devices.

System and Communications Protection

• Monitor, control, and protect organizational communications (i.e. information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of the information systems.
• Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.

System and Information Integrity

• Identify, report, and correct information and information system flaws in a timely manner.
• Provide protection from malicious code at appropriate locations within organizational information systems.
• Update malicious code protection mechanisms when new releases are available.
• Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed.

CMMC Level 2 (Serve as transition step in cybersecurity maturity progression to protect CUI)

This level of certification requires vendors to have written (documented) policies and procedures for the implementation of CMMC requirements. By documenting a framework, vendors create a repeatable process for ensuring the security of information. The DoD refers to this as a ‘Documented’ process for ‘Intermediate Cyber Hygiene’ practices. As a transitional stage, some of the required practices reference CUI protections. 

As security processes are cumulative, CMMC Level 2 certification requires all of the same security processes as Level 1, with additional requirements.

Additional required processes for CMMC Level 2 are as follows.

Access Controls

• Provide privacy and security notices consistent with applicable CUI rules.
• Limit use of portable storage devices on external systems.
• Employ the principle of least privilege, including for specific security functions and privileged accounts.
• Use non-privileged accounts or roles when accessing nonsecurity functions.
• Limit unsuccessful logon attempts.
• Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity.
• Authorize wireless access prior to allowing such connections.
• Monitor and control remote access sessions.
• Route remote access via managed access control points.
• Control the flow of CUI in accordance with approved authorizations.

Audit and Accountability

• Ensure that the action of individual system users can be uniquely traced to those users so they can be held accountable for their actions.
• Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity.
• Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.
• Review audit logs.

Awareness and Training

• Ensure that managers, system administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems.
• Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities.

Configuration Management

• Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.
• Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities.
• Control and monitor user-installed software.
• Establish and enforce security configuration settings for information technology products employed in organizational systems.
• Track, review, approve, or disapprove, and log changes to organizational systems.
• Analyze the security impact of changes prior to implementation.

Identification and Authentication

• Enforce a minimum password complexity and change of characters when new passwords are created.
• Prohibit password reuse for a specified number of generations.
• Allow temporary password use for system logons with an immediate change to a permanent password.
• Store and transmit only cryptographically-protected passwords.
• Obscure feedback of authentication information.

Incident Response

• Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities.
• Detect and report events.
• Analyze and triage events to support event resolution and incident declaration.
• Develop and implement responses to declared incidents according to per-defined procedures.
• Perform root cause analysis on incidents to determine underlying causes.

Maintenance

• Perform maintenance on organizational systems.
• Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance.
• Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete.
• Supervise the maintenance activities of personnel without required access authorization.

Media Protection

• Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.
• Limit access to CUI on system media to authorized users.
• Control the use of removable media on system components.

Personnel Security

• Screen individuals prior to authorizing access to organizational systems containing CUI.
• Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

Recovery

• Regularly perform and test data back-ups.
• Protect the confidentiality of backup CUI at storage locations.

Physical Protection

• Protect and monitor the physical facility and support infrastructure for organizational systems.

Risk Management

• Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI.
• Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.
• Remediate vulnerabilities in accordance with risk assessments.

Security Assessment

• Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.
• Periodically assess the security controls in organizational systems to determine if the controls are effective in the application.
• Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.

System and Communications Protection

• Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.
• Use encrypted sessions for the management of network devices.

System and Information Integrity

• Monitor system security alerts and advisories and take action in response.
• Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks
• Identify unauthorized use of organizational systems.

CMMC Level 3 (Protect CUI)

CMMC Level 3 is the most common certification for vendors in the DoD supply chain, all vendors accessing or storing CUI must be certified at, at least, this level. This level of certification requires vendors to have an established and maintained plan for activity management. This plan should include goals, missions, resourcing, project plans, involvement of relevant stakeholders, and required training. The DoD refers to this as a ‘Managed’ process for ‘Good Cyber Hygiene’ practices. 

As security processes are cumulative, CMMC Level 3 certification requires all of the same security processes as Level 1 and Level 2, with additional requirements.

Additional required processes for CMMC Level 3 are as follows.

Access Control

• Separate the duties of individuals to reduce the risk of malevolent activity without collusion.
• Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.
• Terminate (automatically) user sessions after a defined condition.
• Protect wireless access using authentication and encryption.
• Control connection of mobile devices.
• Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.
• Authorize remote execution of privileged commands and remote access to security-relevant information.
• Encrypt CUI on mobile devices and mobile computing platforms.

Asset Management

• Define procedures for the handling of CUI data.

Audit and Accountability

• Review and update logged events.
• Alert in the event of an audit logging process failure.
• Collect audit information (i.e., logs) into one or more central repositories.
• Protect audit information and audit logging tools from unauthorized access, modification, and deletion.
• Limit management of audit logging functionality to a subset of privileged users.
• Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.
• Provide audit record reduction and report generation to support on-demand analysis and reporting.

Awareness and Training

• Provide security awareness training on recognizing and reporting potential indicators of insider threat.

Configuration Management

• Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.
• Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.
• Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software.

Identification and Authentication

• Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.
• Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts.
• Prevent the reuse of identifiers for a defined period.
• Disable identifiers after a defined period of inactivity.

Incident Response

• Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization.
• Test the organizational incident response capability.

Maintenance

• Ensure equipment removed for off-site maintenance is sanitized of any CUI.
• Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems.

Media Protection

• Mark media with necessary CUI markings and distribution limitations.
• Prohibit the use of portable storage devices when such devices have no identifiable owner.
• Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.
• Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.

Physical Protection

• Enforce safeguarding measures for CUI at alternate work sites.

Recovery

• Regularly perform complete, comprehensive, and resilient data back-ups as organizationally defined.

Risk Management

• Periodically perform risk assessments to identify and prioritize risks according to the defined risk categories, risk sources, and risk measurement criteria.
• Develop and implement risk mitigation plans.
• Manage non-vendor-supported products (i.e., end of life) separately and restrict as necessary to reduce risk.

Security Assessment

• Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.
• Employ a security assessment of enterprise software that has been developed internally, for internal use, and that has been organizationally defined as an area of risk.

Situational Awareness

• Receive and respond to cyber threat intelligence from information sharing forums and sources and communicate to stakeholders.

System and Communications Protection

• Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.
• Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems.
• Separate user functionality from system management functionality.
• Prevent unauthorized and unintended information transfer via shared system resources.
• Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).
• Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection via some other connection to resources in external networks (i.e., split tunneling).
• Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.
• Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.
• Establish and manage cryptographic keys for cryptography employed in organizational systems.
• Control and monitor the use of mobile code.
• Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.
• Protect the authenticity of communications sessions.
• Protect the confidentiality of CUI at rest.
• Implement Domain Name System (DNS) filtering services.
• Implement a policy restricting the publication of CUI on externally owned, publicly accessible websites (i.e., forums, LinkedIn, Facebook, Twitter).

System and Information Integrity

• Employ spam protection mechanisms at information system access entry and exit points.
• Implement email forgery protections.
• Utilize sandboxing to detect or block potentially malicious email.

CMMC Level 4 (Protect CUI and reduce risk of Advanced Persistent Threats (APTs))

This level of certification requires vendors to measure and review practices to determine their effectiveness. They must also implement corrective action plans, should the need arise, and keep upper management apprised to issues or incidents. The DoD refers to this as a ‘Reviewed’ process for ‘Proactive’ practices. 

As security processes are cumulative, CMMC Level 4 certification requires all of the same security processes as Level 1, Level 2, and Level 3, with additional requirements.

Additional required processes for CMMC Level 4 are as follows.

Access Control

• Control information flows between security domains on connected systems.
• Periodically review and update CUI program access permissions.
• Restrict remote network access based on organizationally defined risk factors such as time of day, location of access, physical location, network connection state, and measured properties of the current user and role.

Asset Management

• Employ a capability to discover and identify systems with specific component attributes (i.e., firmware level, OS type) within your inventory.

Audit and Accountability

• Automate analysis of audit logs to identify and act on critical indicators (TTPs) and/or organizationally defined suspicious activity.
• Review audit information for broad activity in addition to per-machine activity. 

Awareness and Training

• Provide awareness training focused on recognizing and responding to threats from social engineering, advanced persistent threat actors, breaches, and suspicious behaviors; update the training at least annually or when there are significant changes to the threat.
• Include practical exercises in awareness training that are aligned with current threat scenarios and provide feedback to individuals involved in the training.

Configuration Management

• Employ application whitelisting and an application vetting process for systems identified by the organization.

Incident Response

• Use knowledge of attacker tactics, techniques, and procedures in incident response planning and execution.
• Establish and maintain a security operations center capability that facilitates a 24/7 response capability.

Risk Management

• Catalog and periodically update threat profiles and adversary TTPs.
• Employ threat intelligence to inform the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, and response and recovery activities.
• Perform scans for unauthorized ports available across perimeter network boundaries over the organization’s internet network boundaries and other organizationally defined boundaries.
• Develop and update as required, a plan for managing supply chain risks associated with the IT supply chain.

Security Assessment

• Create, maintain, and leverage a security strategy and roadmap for organizational cybersecurity improvement.
• Conduct penetration testing periodically, leveraging automated scanning tools and ad hoc tests using human experts.
• Periodically perform red teaming against organizational assets in order to validate defensive capabilities.

Situational Awareness

• Establish and maintain a cyber threat hunting capability to search for indicators of compromise in organizational systems and detect, track, and disrupt threats that evade existing controls.
• Design network and system security capabilities to leverage, integrate, and share indicators of compromise.

System and Communications Protection

• Employ physical and logistical isolation techniques in the system and security architecture and/or where deemed appropriate by the organization.
• Isolate administration of organizationally defined high-value critical network infrastructure components and servers.
• Utilize threat intelligence to proactively block DNS requests from reaching malicious domains.
• Employ mechanisms to analyze executable code and scripts (i.e., sandbox) traversing internet network boundaries or other organizationally defined boundaries.
• Utilize a URL categorization service and implement techniques to enforce URL filtering of websites that are not approved by the organization.

System and Information Integrity

• Use threat indicator information relevant to the information and systems being protected and effective mitigations obtained from external organizations to inform intrusion detection and threat hunting.

CMMC Level 5 (Protect CUI and reduce risk of Advanced Persistent Threats (APTs))

This level of certification requires vendors to optimize and standardize implementation of processes throughout the whole organization. The DoD refers to this as an ‘Optimizing’ process for ‘Advanced/Proactive’ practices. 

As security processes are cumulative, CMMC Level 5 certification requires all of the same security processes as Level 1, Level 2, Level 3, and Level 4, with additional requirements.

Additional required processes for CMMC Level 5 are as follows.

Access Control

• Identify and mitigate risk associated with unidentified wireless access points connected to the network.

Audit and Accountability

• Identify assets not reporting audit logs and assure appropriate organizationally defined systems are logging.

Configuration Management

• Verify the integrity and correctness of security critical or essential software as defined by the organization (i.e., roots of trust, formal verification, or cryptographic signatures).

Incident Response

• In response to cyber incidents, utilize forensic data gathering across impacted systems, ensuring the secure transfer and protection of forensic data.
• Use a combination of manual and automated, real-time responses to anomalous activities that match incident patterns.
• Establish and maintain a cyber incident response team that can investigate an issue physically or virtually at any location within 24 hours.
• Perform unannounced operational exercises to demonstrate technical and procedural responses.

Recovery

• Ensure information processing facilities meet organizationally defined information security continuity, redundancy, and availability requirements.

Risk Management

• Utilize an exception process for non-whitelisted software that includes mitigation techniques.
• Analyze the effectiveness of security solutions at least annually to address anticipated risk to the system and the organization based on current and accumulated threat intelligence.

System and Communications Protection

• Configure monitoring systems to record packets passing through the organization’s internet network boundaries and other organizationally defined boundaries.
• Enforce port and protocol compliance.
• Employ organizationally defined and tailored boundary protections in addition to commercially available solutions.

System and Information Integrity

• Analyze system behavior to detect and mitigate execution of normal system commands and scripts that indicate malicious actions.
• Monitor individuals and system components on an ongoing basis for anomalous or suspicious behavior.