In July of 2023, the DoD submitted its plan to the Office of Management and Budget for review, officially kicking off the CMMC rulemaking process. While that does signify another period of uncertain waiting, it also solidifies the fact that DoD has come to a consensus on a final rule and that CMMC compliance will be mandatory in the not-so-distant future.
If you’re a DoD contractor, you’ve likely been bombarded with messages for the past several years from various service providers who want to help you reach compliance. Now, it seems it’s time to start taking those offers seriously if you’re not ready for CMMC assessment yet. This analysis of the CMMC market landscape is intended to help you navigate the numerous technical pieces and strategic paths that could get you to your compliance goals.
The various service offerings within the CMMC marketplace generally fall into the following stages:
- The Prep (Gap Analysis)
- The Work (CMMC Implementation)
- The Moment of Trust (C3PAO Assessment)
- The Maintenance (Managed Compliance)
Gap Analysis services help organizations measure their present level of conformance to NIST 800-171 and the current draft of CMMC 2.0. While almost all CMMC service providers offer some sort of sales-oriented readiness assessment that directly correlates to their service offering, a true CMMC Gap Analysis is best conducted by a Registered Practitioner (RP) or Registered Practitioner Organization (RPO). The RP and RPO credentials are earned through the CMMC Accreditation Body (Cyber-AB).
To search for registered entities in The Cyber-AB’s database, click here.
CMMC RPOs, otherwise known as Cyber-AB RPOs, provide thorough pre-assessment consulting services that address the entire framework. They differ from C3PAOs in that they are not authorized to conduct actual CMMC assessments. The RPO role exists exclusively to provide CMMC guidance and support to OSCs in the DIB. Unless they are also certified as an RPO, a C3PAO cannot offer these services and cannot extend both services (assessment and advisement) to the same company.
Through a Gap Analysis, you may find for example that your organization is lagging in access control, such as having weak or no multifactor authentication. Your firm may not have the proper resources or tools for safe data storage and backup control. Perhaps you meet all technical requirements, but your documentation doesn’t properly portray the evidence.
In short, a Gap Analysis is the first step to reveal the real work that will be required to achieve compliance.
This is where the marketplace can get overwhelming and, if you’re not careful, can quickly drain time and financial resources. The CMMC framework has a lot of moving parts and there are many ways to piece your infrastructure together to ultimately achieve compliance.
Key vendor services compliance-seeking organizations should pay attention to include:
- Data Hosting
- Managed Services (MSP)
- Security Consulting/MSSP
- Security Incident and Event Management (SIEM) and/or Security Operations Center (SOC)
Data hosting is often considered the most vital piece of the CMMC equation because the entire CMMC framework is based on keeping CUI data safe and secure.
With a plethora of hosting solutions available on the market, the key is choosing a provider who specializes in CMMC compliance and is dedicated to serving DoD contractors for the long haul.
When comparing public cloud solutions such as AWS and Azure with private dedicated hardware solutions like Avatara, some factors to consider include security, scalability, and cost.
While big-name public cloud providers have robust security measures in place, the responsibility for configuring and managing these security measures lies partially with the customer. Private dedicated hardware hosting providers such as Avatara tend to offer more customized security measures which can be tailored specifically to CMMC compliance. With dedicated hardware resources and isolated environments, they offer enhanced control over security configurations. This level of control can be appealing to DoD contractors handling sensitive data.
Scalability & Cost
Public cloud providers generally operate on a pay-as-you-go model, where organizations pay for the resources they consume. This can be cost-effective, particularly for businesses with variable workloads. However, costs can increase if resources are not optimized or managed efficiently. Private dedicated hardware hosting providers typically operate on a fixed pricing model based on the dedicated hardware resources provided, offering cost predictability.
A managed service provider (MSP) plays a crucial role in delivering a wide range of services to businesses, encompassing network management, application support, infrastructure maintenance, and security measures. These services are provided through ongoing and consistent support as well as active administration, either on the customers’ premises, within the MSP’s data center (hosting), or in a third-party data center. MSPs often combine their own proprietary services with offerings from other providers, such as when an MSP offers system administration on top of a third-party cloud infrastructure-as-a-service (IaaS) platform. While some MSPs specialize in a specific vendor or technology, focusing primarily on their own core solutions, many also incorporate services from various other providers.
The term “MSP” traditionally referred to services that centered around infrastructure or device management. However, its scope has significantly expanded to encompass any form of continuous, regular management, maintenance, and support. As technology and business needs have evolved, MSPs have adapted to provide comprehensive assistance in various aspects of an organization’s operations.
Is your MSP operating within a compliant framework?
It is worth noting that the current version of the CMMC Assessment Process (CAP) suggests that MSPs will be included in the scope of assessment. This means that when choosing an MSP, it is not only essential to find one that is committed to ensuring your long-term compliance but also one that prioritizes their own compliance efforts.
Security consultants and Managed Security Service Providers (MSSP) play critical roles in identifying vulnerabilities within computer systems, networks, and software programs, and devising strategies to fortify them against malicious hackers. While a managed service provider (MSP) offers general network and IT support, a Managed Security Service Provider (MSSP) specializes solely in delivering security services. Their primary responsibilities involve creating a comprehensive plan of action and managing and outsourcing the monitoring of systems and security devices to facilitate that plan.
One of the key distinctions between MSPs and MSSPs lies in their respective “operations centers.” MSPs typically operate a network operations center (NOC) from which they monitor and manage their clients’ networks. On the other hand, MSSPs are equipped with a security operations center (SOC) dedicated to round-the-clock security monitoring and incident response.
MSSPs employ various types of security software to monitor and address different security scenarios. Prominent examples of leading security software applications utilized by MSSPs include advanced malware protection software, application security software, firewall software, endpoint security software, web security software, network security software, email security software, and Internet of Things (IoT) security software. These tools form a vital part of an MSSP’s arsenal in safeguarding organizations against a wide range of threats and vulnerabilities.
A Security Operations Center (SOC) and a Security Incident and Event Management (SIEM) platform are different strategies for monitoring a network environment, and they work together to help corporations prevent data breaches and alert them to potential ongoing cyber-events.
In a data center or large enterprise environment, a SOC is necessary for network security. The SOC is often a physical room within the organization’s office where several employees continually monitor network traffic, alerts, and visualized information that could be used to respond to a potential cyber-incident.
A SIEM is a collection of cybersecurity components used to monitor network traffic and resources. From a user perspective, it’s a centralized dashboard of security information used to display alerts and suspicious network activity to a security analyst.
SOC engineers work directly with a SIEM platform to analyze network traffic and events. The SIEM plays a large role in a SOC employee’s ability to quickly determine if a threat compromises the network and work directly to contain it. An unmonitored network environment could have multiple threats breaching resources, but an intelligent SIEM provides the right information and alert system so that SOC employees can identify them.
Let’s say you’ve conducted a CMMC gap analysis and you’re ready to start the implementation phase. There are a wide variety of services and tools at play that could come together to fill in all the gaps. Now it’s time to make the decision: Do you piecemeal your way into compliance? Or do you choose a more comprehensive approach and move your entire IT infrastructure onto an all-inclusive platform?
- Managing a fragmented infrastructure is time-consuming and inefficient.
- Inconsistent security controls lead to gaps in security and increased vulnerability.
- Integration complexity increases risk of misconfigurations.
- Vendor management is multiplied and finger pointing ensues.
- Potential for duplicated efforts, increased costs, and more administrative burden.
A well-integrated and centrally managed infrastructure can streamline compliance efforts and reduce complexity in meeting CMMC requirements. Avatara’s DoD Platform is the comprehensive solution for small and mid-sized businesses seeking cost-effective CMMC implementation and compliance management.
Our all-inclusive platform is delivered and supported in a per-user, per-month pricing model, including:
- Managed Security
- Written Policies, SSP, and Evidence
- Hosted Desktops
- 24/7 US-based Support
- Unified Communications
- Local Hardware
- Collaboration Tools
- Unlimited Storage
- Secure Mobility