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48 CFR CMMC Proposed Rule
Small DoD Contractors Can Quickly and Cost-effectively Meet CMMC Requirements with Managed Cloud Services

 November 7, 2024 | 8 min read  | Redspin Blog

 

Many organizations working in the Defense Industrial Base (DIB) are scratching their heads, wondering how, especially with small or even one-person IT and security teams, they’ll ever meet the daunting list of 110 Cybersecurity Maturity Model Certification (CMMC) requirements for Level 2 as needed to secure new or existing Department of Defense (DoD) contracts.

 

While some may single-handedly knock out CMMC security requirements for Federal Contract Information (FCI), in many cases, those organizations that store, process, and/or transmit Controlled Unclassified Information (CUI) will need to implement all 110 NIST SP-800-171 controls to renew or have the chance to grow their DoD partnerships and accept awarded contracts.

 

But some small teams don’t know where or how to begin. They can’t find skilled security professionals to supplement existing teams or have the budget/resources to expand them and upgrade the organization’s controls to satisfy their requirements.

 

In many cases, the task of implementing and managing CMMC falls on one person who is already balancing multiple IT and security responsibilities, leaving little time to navigate CMMC’s complexities. While these requirements have been in place for years under DFARS clauses 7012 and 7021, self-attestation is no longer sufficient for CMMC Levels 2 and 3 now that CMMC is mandatory. Organizations must demonstrate compliance with CMMC standards, requiring a formal third-party assessment to prove they meet all necessary controls and have a mature security management lifecycle to protect CUI data.

 

Fortunately, secure, isolated cloud environments—or enclaves—built by CMMC experts, Entra ID services for organization-wide identity management, hardened M365 applications with data encryption for CUI, and Azure Virtual Desktops are available.

 

So, how can small teams tackle CMMC compliance without hiring more people or over-extending their already tight budgets?

 

This is where partnering with experienced cloud-focused External Service Providers (ESPs) can make the most impact.

 

Beyond helping small teams build a roadmap for their CMMC journey, a CMMC experienced team can help small businesses accelerate the path toward CMMC compliance, assisting with choosing the right cloud type and configuration of the needed cloud applications and services. In many cases, at much less cost than building a highly trained and specialized security and compliance team. However, the first step is identifying an organization’s CUI scope and any additional sensitive data types associated with current contract awards, renewals, and future business goals.

 

Organizations must carefully consider which platform best aligns with their compliance needs and security goals to ensure this journey is effective.

 

Cloud platforms from Microsoft have specialized features and infrastructure primarily geared for assisting the DIB with protecting the CUI of government contractors. This is the function of Government Community Cloud,  GCC High in particular. Azure Commercial meets many NIST 800-171 controls but doesn’t fully address CMMC requirements. Leveraging Azure GCC High cloud type with a CMMC or C3PAO cloud expert can accelerate CMMC compliance and ease some pressures for small teams with limited IT resources.

 

The smallest DoD contractors can access the same high-level controls as larger enterprises, an important step in this fast-paced race toward CMMC compliance and protecting our government data. In an Azure GCC High cloud environment, the following is provided:

  • You are ensuring that Data Residency and Sovereignty are met. CMMC has specific data residency requirements about where you can store and process CUI. If you handle International Traffic in Arms Regulations (ITAR) data, you will need to have your cloud services come from Azure GCC High.
  • Meets FedRAMP High and Department of Defense (DoD) Impact Level 5 authorization for services.
  • With M365 in Azure GCC High, email and file management have integrated FIPS 140-2, which validates encryption for data at rest and in transit. It automatically protects CUI using the highest government standards.
  • Built-in DoD SRG (Security Requirements Guide) controls, multi-factor authentication (MFA), audit logging, and monitoring tailored to CUI for businesses to implement.

 

CMMC Managed Cloud Services

However, getting through all 14 domains of CMMC with the proper implementation configuration for an Azure GCC High environment that works for your organization is still daunting. The acceleration of CMMC confidence with the rulemaking now final can be fulfilled with a CMMC-managed ESP.

 

Think of an ESP as an extension of your IT team. Instead of struggling to learn this new environment and map the services needed to align with the policy and procedures required for CMMC organization, a CMMC-managed cloud expert can do this in a fraction of the time it would take others. Instead of struggling to build a secure IT infrastructure on-prem, you can use a cloud pre-configured with CMMC security controls. However, because these environments are CMMC-ready, there are still many misconfigurations, false configurations, and assumptions that a company doing this on its own can run into.  An experienced ESP will protect your organization from these pitfalls.  Ideally, the partner can provide more than just implementation and fulfill many ongoing compliance challenges like active monitoring, change management support, and security log management.

 

CMMC-managed cloud providers help fill these gaps via the shared responsibility model for continuous CMMC compliance. This oversight is invaluable and can assist with what the cloud platform delivers, how an organization’s CUI flows between its systems and users in the cloud, and ensuring that continuous threat detection, logging, and validating changes are authorized and aligned to the regulation. These experts can help you build a sustainable way that your organization can process, transmit, and store CUI as needed for your business — not just to achieve CMMC certification but to streamline continuous protection. While there is a three-year window before another CMMC certification is required, prime contractors can request their subcontractors to show proof of their compliance lifecycle management at any time.

 

CMMC and Cloud Benefits

Many small businesses assume cloud services for CMMC are too expensive and complex. They may think it’s just a solution for larger contractors.

 

In reality, Microsoft GCC High is optimized to make this more affordable than trying to build it yourself or get these benefits from other cloud platforms. It is significantly cheaper than hiring and retaining dedicated IT staff, especially considering salaries, benefits, and ongoing training. The benefit of moving to this model is that it makes it easier to support:

  • Business growth, adding a new user, or ramping up additional storage or computer services.
  • It segments the few users or a business division handling CUI from the broader business focus. With virtual machine access in the cloud, Azure Virtual Desktop (AVD) removes endpoints from CMMC’s scope. This means that even if your employees use personal devices or connect from unsecured networks like public WIFI, the cloud protects that data.
  • Implementing with minimal effort a CMMC enclave at-the-ready for when a business has only intermittent handling of CUI data.

Subcontractor Implications

While CMMC’s rollout had delays, the DoD is now actively working to incorporate CMMC requirements into contracts. This means that both prime and subcontractors may need to demonstrate compliance sooner than expected, starting as early as December 16, 2024, the effective date of the 32 CFR CMMC program.

 

If you’re a subcontractor, there’s also a good chance your prime contractor is starting to include CMMC language in your work agreements. While DoD hasn’t explicitly mandated CMMC certification, primes are already increasing security expectations. You might face more detailed security questionnaires or encounter stricter security requirements in contract language, and as mentioned before, you may be required to prove CMMC readiness.

 

Partnering with Redspin for CMMC in the Cloud

Now that the rulemaking is final, waiting any longer could leave you scrambling to refine how your organization looks at CMMC compliance and potentially risk losing DoD contracts from others who prepared earlier. With expert providers, managed cloud services can accelerate an organization’s readiness for their CMMC certification and ensure they have everything in place to renew their contracts and bid on additional ones to grow their business.

 

Redspin, the first C3PAO and the first to successfully pass CMMC C3PAO recertification can accelerate your CMMC certification journey with cloud-managed services and ongoing compliance management.

 

Redspin focuses on helping you scope the best means to protect your data and make CMMC easy to achieve and maintain, leveraging Azure GCC High cloud services with the configurations and licensing that align with your data level protection needs. Our managed program addresses the security requirements but also extends to assist with policy and procedures development, 24/7 security monitoring, and consultants to help with CMMC security training. Redspin is dedicated to providing cloud services to help grow CMMC confidence throughout the Defense Industrial Base.

 

 

Partnering with Redspin

Redspin, the first Authorized (and first to be recertified) CMMC Third Party Assessment Organization (C3PAO,) offers specialized services to guide contractors through CMMC assessments and compliance, ensuring they remain eligible for DoD contracts. Services include:

By partnering with Redspin, contractors can confidently navigate the CMMC journey and maintain compliance with DoD requirements.

 

Stay tuned for more updates as we continue to follow and dissect the implications of CMMC’s final rulemaking. In the meantime, should you have any questions or need assistance with CMMC, Redspin is here to help. Please join our upcoming CMMC Connect session, contact us at info@redspin.com or fill out the form below to chat. 

 

 

Book a meeting to get CMMC ready with Redspin: