CMMC Survival Guide: What to Expect When You’re Expecting…CMMC Compliance for Manufacturing Company

For small and mid-sized defense contractors, preparing for CMMC compliance for your manufacturing company can feel a lot like preparing for a big life event. Much like expecting parents, you’re about to embark on a journey that requires planning, patience, and a fair amount of learning along the way. 

But don’t worry, you’ve got a guide to help you with it.

In this post, we walk you through what CMMC compliance means for your business and how to get started. For any terms or acronyms that leave you scratching your head, be sure to check out our CMMC Survival Guide: Lost in a Sea of Jargon? for a quick reference.

What Is CMMC?

Think of CMMC as the Department of Defense’s way of making sure its “family” is safe. It’s designed to protect national security by securing the supply chain by ensuring that contractors have proper cybersecurity measures in place. The DoD introduced CMMC to make sure everyone who works with sensitive information follows the same rules.

The goal is to keep classified and unclassified information safe, protecting the broader defense community. If you’re working with any level of sensitive information, big or small, CMMC compliance will likely affect you. The best analogy would be a parent vetting a babysitter to ensure that their child is safe under the sitter’s care. 

What Does CMMC Compliance Mean for Your Manufacturing Company?

Just like any growing family, your business needs to prepare for changes, and CMMC certification is one of them. Here’s what CMMC compliance could mean for you:

• Certification requirements: Depending on the type of work you do, the level of certification required will vary. Whether it’s self-attestation at Level 1 or an external assessment for higher levels, you’ll need to make sure your business is up to par.
• A market differentiator: Just like a shiny new toy that every kid on the block wants, having CMMC certification can make your business attractive. Many businesses will have to meet CMMC requirements, but not all will be able to do so easily. Being certified can set you apart from competitors and give you an edge in the marketplace.

1. Open doors: Much like a well-cared-for child has endless potential, CMMC compliance can open up new opportunities. With certification in hand, your business could qualify for more lucrative DoD-related contracts. If you’re aiming for growth, this is a significant step toward securing more work.

The Certification Process: From Birth to Adulthood

The certification process is like watching a newborn grow: Each level of certification represents a milestone in your compliance journey. There are three levels of compliance that an OSC (Organizations Seeking Compliance) will need to understand so they can ensure that they are ready to move on to the next stage. 

The time it takes to become ready for CMMC can vary widely depending upon things such as scope of compliance, level of compliance, and resources. The process takes companies anywhere from six months to 28 months, so it is important to start now.

• Level 1 self-attestation: This is like the “baby steps” phase. At this stage, you’re getting used to the idea of cybersecurity, ensuring basic practices are in place. For many small manufacturers, Level 1 involves self-attestation, which means you can assess your own security practices without needing an external review. 

You have to crawl before you walk and this is where most begin. But just like a toddler taking their first steps, there are risks. The Defense Counterintelligence and Security Agency (DCSA) or your customer can check in at any time to ensure you meet the requirements.

• Level 2 certification: As your compliance program grows, it becomes more independent, much like a pre-teen. This level requires external assessors (C3PAOs) to evaluate your cybersecurity measures, and with more complex contracts, the stakes are higher (with minor exceptions allowing self-attestation). 

You’ll need to demonstrate that your security practices are sophisticated enough to handle sensitive DoD information. Think of this as parents checking in to make sure the chores are done. In this case, external assessors will review your security measures every three years for Level 2 and Level 3 certifications.

• Level 3 certification: Like a late teen looking to move on to college or start life their life in the “real world,” Level 3 requires significant maturity to be successful. Items such as business resilience and testing of measures through ethical hacking and other security testing activities are required at this level. 

Most small to mid-sized manufacturers are not requested to meet this requirement but it happens in some cases depending upon the sensitivity of the data and criticality of the products and services being offered. 

No matter what the level, an OSC will need to have three critical pieces of information that would be akin to proof of immunizations that help prevent illness and disease. The System Security Plan (SSP), Plan of Action and Milestones (PoAM), and a Supplier Performance Risk System (SPRS) score are required, and you will not comply without them. 

• SSP: The SSP lays out how your company is implementing the required security measures.

• PoAM: This documents your plan to address security gaps. It shows the DoD how you’re working to fix any issues.
• SPRS: SPRS is a DoD tool that evaluates contractor performance and manages cybersecurity risks across the supply chain. Point values are provided for each practice that is considered as met, and a score can be derived. A score of 110 means that you have met all requirements, whereas a -203 means that you meet none of them.

Costs and Challenges: Growing Pains

Let’s face it: Raising a child or growing a compliance program comes with its own set of challenges. CMMC certification isn’t always easy, and there are costs associated with getting it done. Some of the key challenges you may face include:

• Cost of certification: Certification can feel like the cost of diapers and formula: It adds up fast. For small businesses, especially those pursuing higher levels of certification, the costs can be significant.
• Time commitment: Raising a healthy compliance program takes time. From preparing your systems to going through the audit process, be ready to invest time in making sure everything is in place. 
• Potential competitive advantage: Despite the growing pains, getting certified can give you a leg up. Just as kids who learn early on tend to excel, businesses that become CMMC certified early are better positioned to secure valuable contracts.

How to Get Started With CMMC: Your First Steps

Think of this section as the baby registry checklist for CMMC compliance. Here’s what you need to do to prepare for the arrival of your certification:

1. Assess your current security posture: Much like baby-proofing a house, you need to take stock of where you are. Look at your existing security practices and see where there are gaps. This is the time to make sure your “nursery” (infrastructure) is ready.
2. Know which certification level is required: Just as you pick the right stroller or crib, you need to pick or otherwise understand the right level of CMMC that you require. The level depends on the type of contracts you’re aiming for. Make sure you understand which level applies to your business and have conversations with your customers about the requirements.
3. Prepare for your audit: This is where the rubber meets the road. Just like parents prepare for the arrival of a newborn, you need to prepare for the CMMC audit. Gather all the necessary documentation, ensure your processes are up to standard, and get ready for the assessor’s review. This requires practice to avoid surprises.
4. Maintain the program: Now that the hard work is done, you have to make sure that you are keeping up with changes in the environment. Think of this as the golden years of parenthood, where you’ve done the hard work, and now you can enjoy the results, so long as you stay attentive to any changes in the environment that might require adjustments.

Don’t forget to check out our CMMC Survival Guide: Lost in a Sea of Jargon? for a breakdown of key terms you’ll encounter during the process.

Conclusion: Raising a Healthy Compliance Program

CMMC compliance for a manufacturing company is like raising a child, it’s a long-term commitment that requires continuous care and attention. From the early stages of self-attestation to the more complex certifications, every step is a milestone in the growth of your business’s cybersecurity practices.

By obtaining CMMC certification, not only are you securing your current contracts, but you’re also setting yourself up for future success. With a healthy, well-nurtured compliance program, your business will be ready to take on new opportunities in the DoD landscape.As you prepare for this journey, remember that — just as with parenting — CMMC compliance requires patience. But in the end, the rewards are well worth the effort. Are you considering CMMC compliance? Reach out for guidance from our experienced team at TechSolve.