CMMC Certification: How to Prepare for DoD Compliance
The CMMC is a security framework that requires DoD contractors to maintain a uniform set of cybersecurity standards in order to execute and bid on contracts — and, importantly, access DoD systems. The DoD recently created the CMMC certification framework to better enforce security controls laid out in NIST SP-800-171. To fully understand how and why the DoD created CMMC, read our companion What is CMMC post.
Here, we'll cover the five CMMC certification levels, how they're different, and the controls at each level.
What are the Differences Between the CMMC Certification Levels?
There are five CMMC levels, ranging from CMMC Level 1 as a starting point to CMMC Level 5 as the highest level of achievement. The CMMC certification requirements are based on implementing a certain number of specific control measures. Each CMMC level is progressive, meaning that the requirements for all lower levels are included every time you go up by one. The only change is that more actions are introduced.
Number of Added Controls
Total Number of Controls
CMMC Level 1
CMMC Level 2
CMMC Level 3
CMMC Level 4
CMMC Level 5
These controls organize practices and processes across a set of domains, then divide them into the five levels listed above, comprising the formal CMMC level requirements. Although there are 17 domains, each level doesn't necessarily have processes in each. CMMC Level 1 and CMMC Level 2 don't have any practices in several of the domains, and some areas are emphasized far more heavily than others. In fact, 105 out of the 171 total controls appear in only six categories.
What are the CMMC Domains?
Each CMMC domain corresponds to between one and five capabilities. These describe the overall purpose of the CMMC domain and drive the individual controls.
Here are the CMMC domains:
Access Control (AC)
Asset Management (AM)
Audit and Accountability (AU)
Awareness and Training (AT)
Configuration Management (CM)
Identification and Authentication (IA)
Incident Response (IR)
Media Protection (MP)
Personnel Security (PS)
Physical Protection (PE)
Risk Management (RM)
Situational Awareness (SA)
Systems and Communications Protection (SC)
System and Information Integrity (SI)
Although the controls are what you need to be concerned about from a CMMC audit requirements perspective, grasping how they're organized and the role each domain plays is crucial.
How to Prepare for DoD CMMC Compliance
If you want to know how to pass a CMMC audit, the most foundational knowledge you need about CMMC level requirements consists of the specific control mechanisms CMMC assessors will be evaluating. As we noted in the companion article, while there's no official CMMC audit assessment guidance as of August 2020, it's rumored that NIST SP 800-171A serves as an adequate stand-in.
Once you've earned the CMMC level you need to continue to conduct business, only that level will be seen. Any details about specific findings will be unavailable to DoD contract officials or the public.
Preceding each action in the CUI lists below is a code. The first two letters correspond with the domain abbreviation you'll find above. The next number is the CMMC level at which this control mechanism is introduced, and the final number is one assigned by the Office of the Secretary of Defense (OSD) as a unique identifier.
What are the CMMC Levels?
The five CMMC levels form a pyramid from performed to documented. This DoD image is helpful to understand not only how to colloquially consider the CUI practices, but also how to document your compliance with the CMMC level controls.
For instance, Level 1 CMMC controls don't necessarily need to be documented — merely performed. However, it's important to allow the auditor to quickly determine whether the control is in place by examination, interview, or test.
Contractors only need to maintain a CMMC level commensurate to the contracts they're bidding on. All DoD contractors should strive to fully certify to CMMC Level 5, but it's not required.
To pass the audit and certify, you'll need to choose the appropriate number of controls from each of these five CMMC levels.
CMMC Level 1 Controls: Basic Cyber Hygiene
The focus of CMMC Level 1 is on safeguarding federal contract information (FCI). This is the lowest level, and the control mechanisms outlined below are very achievable. These are best practices that should be adopted for a baseline level of security for any company with IT assets. In fact, the CMMC simply refers to this level as Basic Cyber Hygiene.
One of the philosophical foundations of the CMMC is a concept referred to as process maturity or process institutionalization. The control mechanisms for CMMC Level 1 can be performed on an ad hoc basis and might not require documentation, so this is the only level where process maturity isn't assessed.
AC.1.001 Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).
AC.1.002 Limit information system access to the types of transactions and functions that authorized users are permitted to execute.
AC.1.003 Verify and control/limit connections to and use of external information systems.
AC.1.004 Control information posted or processed on publicly accessible information systems.
IA.1.076 Identify information system users, processes acting on behalf of users, or devices.
IA.1.077 Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.
MP.1.118 Sanitize or destroy information system media containing Federal Contract Information before disposal or release for reuse.
PE.1.131 Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.
PE.1.132 Escort visitors and monitor visitor activity.
PE.1.133 Maintain audit logs of physical access.
PE.1.134 Control and manage physical access devices.
SC.1.175 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.
SC.1.176 Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.
SI.1.210 Identify, report, and correct information and information system flaws in a timely manner.
SI.1.211 Provide protection from malicious code at appropriate locations within organizational information systems.
SI.1.212 Update malicious code protection mechanisms when new releases are available.
SI.1.213 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 Controls: Intermediate Cyber Hygiene
CMMC Level 2 is the first stage for institutionalized security practices, so a contractor's security culture is evaluated as a part of a CMMC audit. The control mechanisms added at this level should all be documented to demonstrate that they're being performed in a consistent, repeatable fashion. Although logs are a critical part of documentation, CMMC auditor requirements will also look for written policies and procedures.
This is also viewed as a transitional step within the cybersecurity maturity progression, so a number of the control mechanisms added at this level focus on protecting Controlled Unclassified Information (CUI).
AC.2.005 Provide privacy and security notices consistent with applicable CUI rules.
AC.2.006 Limit use of portable storage devices on external systems.
AC.2.007 Employ the principle of least privilege, including for specific security functions and privileged accounts.
AC.2.008 Use non-privileged accounts or roles when accessing nonsecurity functions.
AC.2.009 Limit unsuccessful logon attempts.
AC.2.010 Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity.
AC.2.011 Authorize wireless access prior to allowing such connections.
AC.2.013 Monitor and control remote access sessions.
AC.2.015 Route remote access via managed access control points.
AC.2.016 Control the flow of CUI in accordance with approved authorizations.
AU.2.041 Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions.
AU.2.042 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.
AU.2.043 Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate timestamps for audit records.
AU.2.044 Review audit logs.
AT.2.056 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.
AT.2.057 Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities.
CM.2.061 Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.
CM.2.062 Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities.
CM.2.063 Control and monitor user-installed software.
CM.2.064 Establish and enforce security configuration settings for information technology products employed in organizational systems.
CM.2.065 Track, review, approve, or disapprove, and log changes to organizational systems.
CM.2.066 Analyze the security impact of changes prior to implementation.
IA.2.078 Enforce a minimum password complexity and change of characters when new passwords are created.
IA.2.079 Prohibit password reuse for a specified number of generations.
IA.2.080 Allow temporary password use for system logons with an immediate change to a permanent password.
IA.2.081 Store and transmit only cryptographically-protected passwords.
IA.2.082 Obscure feedback of authentication information.
IR.2.092 Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities.
IR.2.093 Detect and report events.
IR.2.094 Analyze and triage events to support event resolution and incident declaration.
IR.2.096 Develop and implement responses to declared incidents according to pre-defined procedures.
IR.2.097 Perform root cause analysis on incidents to determine underlying causes.
MA.2.111 Perform maintenance on organizational systems.
MA.2.112 Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance.
MA.2.113 Require multi-factor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete.
MA.2.114 Supervise the maintenance activities of personnel without required access authorization.
MP.2.119 Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.
MP.2.120 Limit access to CUI on system media to authorized users.
MP.2.121 Control the use of removable media on system components.
PS.2.127 Screen individuals prior to authorizing access to organizational systems containing CUI.
PS.2.128 Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.
PE.2.135 Protect and monitor the physical facility and support infrastructure for organizational systems.
RE.2.137 Regularly perform and test data back-ups.
RE.2.138 Protect the confidentiality of backup CUI at storage locations.
RM.2.141 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.
RM.2.142 Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.
RM.2.143 Remediate vulnerabilities in accordance with risk assessments.
CA.2.157 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.
CA.2.158 Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.
CA.2.159 Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.
SC.2.178 Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.
SC.2.179 Use encrypted sessions for the management of network devices.
SI.2.214 Monitor system security alerts and advisories and take action in response.
SI.2.216 Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks.
SI.2.217 Identify unauthorized use of organizational systems.
CMMC Level 3 Controls: Good Cyber Hygiene
In addition to the policies and procedures that characterized CMMC Level 2, contractors at CMMC Level 3 are expected to develop plans that further establish their process institutionalization. This could include such high-level concepts as missions, goals, project plans, resourcing, required training, and involvement of relevant stakeholders
Where CMMC Level 1 safeguarded federal CUI and CMMC Level 2 was a transitional step to higher security levels, CMMC Level 3 is where CUI is expected to be firmly protected with no chance of a breach. Cybersecurity is taken very seriously at this stage and ad hoc processes no longer have a place.
AC.3.017 Separate the duties of individuals to reduce the risk of malevolent activity without collusion.
AC.3.018 Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.
AC.3.019 Terminate (automatically) user sessions after a defined condition.
AC.3.012 Protect wireless access using authentication and encryption.
AC.3.020 Control connection of mobile devices.
AC.3.014 Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.
AC.3.021 Authorize remote execution of privileged commands and remote access to security-relevant information.
AC.3.022 Encrypt CUI on mobile devices and mobile computing platforms.
AM.3.036 Define procedures for the handling of CUI data.
AU.3.045 Review and update logged events.
AU.3.046 Alert in the event of an audit logging process failure.
AU.3.048 Collect audit information (e.g., logs) into one or more central repositories.
AU.3.049 Protect audit information and audit logging tools from unauthorized access, modification, and deletion.
AU.3.050 Limit management of audit logging functionality to a subset of privileged users.
AU.3.051 Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.
AU.3.052 Provide audit record reduction and report generation to support on-demand analysis and reporting.
AT.3.058 Provide security awareness training on recognizing and reporting potential indicators of insider threat.
CM.3.067 Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.
CM.3.068 Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.
CM.3.069 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.
IA.3.083 Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.
IA.3.084 Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts.
IA.3.085 Prevent the reuse of identifiers for a defined period.
IA.3.086 Disable identifiers after a defined period of inactivity.
IR.3.098 Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization.
IR.3.099 Test the organizational incident response capability.
MA.3.115 Ensure equipment removed for off-site maintenance is sanitized of any CUI.
MA.3.116 Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems.
MP.3.122 Mark media with necessary CUI markings and distribution limitations.
MP.3.123 Prohibit the use of portable storage devices when such devices have no identifiable owner.
MP.3.124 Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.
MP.3.125 Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.
PE.3.136 Enforce safeguarding measures for CUI at alternate work sites.
RE.3.139 Regularly perform complete, comprehensive, and resilient data back-ups as organizationally defined.
RM.3.144 Periodically perform risk assessments to identify and prioritize risks according to the defined risk categories, risk sources, and risk measurement criteria.
RM.3.146 Develop and implement risk mitigation plans.
RM.3.147 Manage non-vendor-supported products (e.g., end of life) separately and restrict as necessary to reduce risk.
CA.3.161 Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.
CA.3.162 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.
SA.3.169 Receive and respond to cyber threat intelligence from information sharing forums and sources and communicate to stakeholders.
SC.3.177 Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.
SC.3.180 Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems.
SC.3.181 Separate user functionality from system management functionality.
SC.3.182 Prevent unauthorized and unintended information transfer via shared system resources.
SC.3.183 Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).
SC.3.184 Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection to resources in external networks (i.e., split tunneling).
SC.3.185 Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.
SC.3.186 Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.
SC.3.187 Establish and manage cryptographic keys for cryptography employed in organizational systems.
SC.3.188 Control and monitor the use of mobile code.
SC.3.189 Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.
SC.3.190 Protect the authenticity of communications sessions.
SC.3.191 Protect the confidentiality of CUI at rest.
SC.3.192 Implement Domain Name System (DNS) filtering services.
SC.3.193 Implement a policy restricting the publication of CUI on externally owned, publicly accessible websites (e.g., forums, LinkedIn, Facebook, Twitter).
SI.3.218 Employ spam protection mechanisms at information system access entry and exit points.
SI.3.219 Implement email forgery protections.
SI.3.220 Utilize sandboxing to detect or block potentially malicious email.
CMMC Level 4 Controls: Proactive
In addition to protecting CUI, CMMC Level 4 requires that contractors take steps to reduce the risk of Advanced Persistent Threats (APTs). These are defined as adversaries with access to significant resources and sophisticated expertise, allowing them to utilize multiple attack vectors as they attempt to infiltrate your systems. Your cybersecurity posture should be sufficiently advanced to detect, address, and adapt to changing tactics, techniques, and procedures (TTPs) used by well-equipped adversaries.
The next step after adopting plans, policies, and procedures is to incorporate a formal self-audit/review process. CMMC auditors will expect Level 4 contractors to discover deficiencies on their own and take corrective action to resolve the issue.
AC.4.023 Control information flows between security domains on connected systems.
AC.4.025 Periodically review and update CUI program access permissions.
AC.4.032 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.
AM.4.226 Employ a capability to discover and identify systems with specific component attributes (e.g., firmware level, OS type) within your inventory.
AU.4.053 Automate analysis of audit logs to identify and act on critical indicators (TTPs) and/or organizationally defined suspicious activity.
AU.4.054 Review audit information for broad activity in addition to per-machine activity.
AT.4.059 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.
AT.4.060 Include practical exercises in awareness training that are aligned with current threat scenarios and provide feedback to individuals involved in the training.
CM.4.073 Employ application whitelisting and an application vetting process for systems identified by the organization.
IR.4.100 Use knowledge of attacker tactics, techniques, and procedures in incident response planning and execution.
IR.4.101 Establish and maintain a security operations center capability that facilitates a 24/7 response capability.
RM.4.149 Catalog and periodically update threat profiles and adversary TTPs.
RM.4.150 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.
RM.4.151 Perform scans for unauthorized ports available across perimeter network boundaries over the organization’s Internet network boundaries and other organizationally defined boundaries.
RM.4.148 Develop and update as required, a plan for managing supply chain risks associated with the IT supply chain.
CA.4.163 Create, maintain, and leverage a security strategy and roadmap for organizational cybersecurity improvement.
CA.4.164 Conduct penetration testing periodically, leveraging automated scanning tools and ad hoc tests using human experts.
CA.4.227 Periodically perform red teaming against organizational assets in order to validate defensive capabilities.
SA.4.171 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.
SA.4.173 Design network and system security capabilities to leverage, integrate, and share indicators of compromise.
SC.4.197 Employ physical and logical isolation techniques in the system and security architecture and/or where deemed appropriate by the organization.
SC.4.228 Isolate administration of organizationally defined high-value critical network infrastructure components and servers.
SC.4.199 Utilize threat intelligence to proactively block DNS requests from reaching malicious domains.
SC.4.202 Employ mechanisms to analyze executable code and scripts (e.g., sandbox) traversing Internet network boundaries or other organizationally defined boundaries.
SC.4.229 Utilize a URL categorization service and implement techniques to enforce URL filtering of websites that are not approved by the organization.
SI.4.221 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 Controls: Advanced / Progressive
At CMMC Level 5, contractors are expected to have a thoroughly institutionalized cybersecurity culture. Written plans, policies, and procedures should cover every level of information security. Formal and recurring training are cornerstones, as are audits and self-evaluations to discover even the most advanced attempts to infiltrate your systems. CMMC auditors will specifically look for standardized, optimized, and documented approaches across all applicable organization units.
AC.5.024 Identify and mitigate risk associated with unidentified wireless access points connected to the network.
AU.5.055 Identify assets not reporting audit logs and assure appropriate organizationally defined systems are logging.
CM.5.074 Verify the integrity and correctness of security critical or essential software as defined by the organization (e.g., roots of trust, formal verification, or cryptographic signatures).
IR.5.106 In response to cyber incidents, utilize forensic data gathering across impacted systems, ensuring the secure transfer and protection of forensic data.
IR.5.102 Use a combination of manual and automated, real-time responses to anomalous activities that match incident patterns. Model Certification | Version 1.02 17
IR.5.108 Establish and maintain a cyber incident response team that can investigate an issue physically or virtually at any location within 24 hours.
IR.5.110 Perform unannounced operational exercises to demonstrate technical and procedural responses.
RE.5.140 Ensure information processing facilities meet organizationally defined information security continuity, redundancy, and availability requirements.
RM.5.152 Utilize an exception process for non-whitelisted software that includes mitigation techniques.
RM.5.155 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.
SC.5.198 Configure monitoring systems to record packets passing through the organization’s Internet network boundaries and other organizationally defined boundaries.| Version 1.02 22
SC.5.230 Enforce port and protocol compliance.
SC.5.208 Employ organizationally defined and tailored boundary protections in addition to commercially available solutions.
SI.5.222 Analyze system behavior to detect and mitigate execution of normal system commands and scripts that indicate malicious actions.
SI.5.223 Monitor individuals and system components on an ongoing basis for anomalous or suspicious behavior.
How to Pass the CMMC Audit
CMMC certification requirements are detailed and comprehensive, but how they're divided between CMMC levels achieves an appropriate balance. Knowing the philosophy behind the CMMC level requirements should help frame the specific control mechanisms you need to adopt. They'll also provide more insight into what you can expect from CMMC auditor requirements when it's your turn to be evaluated.
If you want to increase your chances of passing a CMMC audit, don't just look at the tasks you must fulfill. Read through the ones at higher CMMC levels to gain a sense of context, and consider adopting more advanced security measures as you're able.