The CMMC Final Rule Has Been Released—What’s Next?

Information Technologies | David Steele | Wednesday, December 25, 2024

The Cybersecurity Maturity Model Certification ( CMMC ) is a key initiative by the Department of Defense (DoD) designed to combat the growing frequency and sophistication of cyberattacks. Its primary goal is to strengthen the protection of Controlled Unclassified Information (CUI). As an integral component of the broader cybersecurity ecosystem, CMMC is set to become one of the most comprehensive and ambitious cybersecurity compliance frameworks ever implemented.

Even for companies outside the DoD ecosystem, CMMC serves as an excellent framework for establishing strong security policies and implementing effective cyber hygiene practices. 

This article delves into the key components of CMMC , examines the latest version and its implications, highlights critical areas to monitor, and provides a step-by-step guide to achieving certification. It also explains why CMMC compliance is not just a necessity for DoD contractors but a strategic advantage for any organization seeking robust cybersecurity and a competitive edge in today’s digital landscape.

Cyber Mindset

A common misconception in cybersecurity is the belief that cyber insurance can replace the need for robust IT security policies. Phrases such as "Why do I need an IT security policy? I have cyber insurance" highlight this misunderstanding. While cyber insurance is a valuable component of a broader risk management strategy, it should never be considered a substitute for PRO-Active IT security measures.

A common misconception is assuming your IT provider is entirely managing all cybersecurity concerns. While this belief may feel convenient, it often creates a false sense of security. At its core, this mindset reflects a deeper issue—a lack of understanding or appreciation for how essential technology is to a business's success and resilience. Regularly meeting with your IT vendor to discuss security, budgets, and the alignment of IT strategies with business goals can significantly enhance the value of your IT investments, driving greater returns and long-term growth.

Just as companies ensure the reliability of delivery trucks or well-maintained production machinery, businesses must prioritize the security and reliability of their IT infrastructure. Neglecting strong security policies exposes a business to significant risks, including operational disruptions, reputational damage, and severe financial losses. Cybersecurity isn't just an expense; it's an essential investment in your organization's stability and future.

Furthermore, poor cyber hygiene can have far-reaching consequences. A cyber incident could leave a business facing monumental challenges, from compromised operations to the possibility of a cyber insurance policy falling short when it's needed most. In today's digital landscape, adopting a PRO-Active and thorough approach to cybersecurity is not optional but necessary.

What is the CMMC Ecosystem?

CMMC , or the Cybersecurity Maturity Model Certification , was first introduced in 2020 to enhance the cybersecurity standards of organizations in the defense industrial base (DIB) sector. Originally designed as a five-level framework, it aimed to protect controlled unclassified information (CUI) within the supply chain from cyber threats. However, following feedback from industry stakeholders, the framework has undergone revisions, with the latest version, CMMC 2.0, streamlining the model into three levels and simplifying requirements. The goal remains the same: to strengthen cybersecurity practices and safeguard sensitive information from malicious actors.

diagram explaining levels of the cmmc model

Image source: https://cyberab.org/What-is- CMMC

The cybersecurity landscape is undergoing significant evolution, with major updates expected to shape it through 2025 and beyond. For organizations working with the Department of Defense (DoD), staying up to date on CMMC developments is essential. These changes will directly impact compliance requirements, contract eligibility, and overall operational security. 

Current CMMC Status

The most recent notice or milestone was on December 16, 2024, when the CMMC Final Rule entered into force. In business terms, the provisions and requirements of CMMC of the final rule are now in effect. However, we are still waiting for the impending CMMC Title 48 Proposed Rule to implement CMMC requirements in the Defense Federal Acquisition Regulation Supplement (DFARS). No mandatory CMMC contractual requirements for defense contractors can take effect until the CMMC Title 48 Final Rule is approved and becomes effective. 

With the final rule in effect, businesses can review and update all policies to address any changes or procedures. This also provides the foundation related to certification assessments. In the past, many online organizations offered CMMC certifications, but without a final rule, it was impossible to get valid certification assessments. 

The Cyber AB will commence authorizing eligible C3PAOs to conduct CMMC Level 2 certification assessments. C3PAOs who were previously “pre-authorized” under the former (“ CMMC 1.0”) framework will require formal reauthorization. A Certified Third-Party Assessor Organization (C3PAO) is a company that assesses a company's compliance with the Department of Defense's (DoD) Cybersecurity Maturity Model Certification ( CMMC ) standards. 

How CMMC Certification Connects to Cyber Insurance and Cybersecurity Programs 

CMMC ( Cybersecurity Maturity Model Certification ) plays a crucial role in strengthening your organization's overall security posture, which can directly impact your cyber insurance and cybersecurity programs. 

For cyber insurance, achieving CMMC certification demonstrates that your organization has implemented robust security measures to protect sensitive data. Insurers often view certified organizations as less risky, potentially leading to lower premiums or better coverage options. 

When it comes to cybersecurity programs, CMMC provides a structured framework to assess and improve your defense strategies. By aligning your practices with CMMC standards, you ensure that your organization meets industry-recognized benchmarks, reducing vulnerabilities and enhancing resilience against cyber threats. 

Ultimately, CMMC certification is a valuable asset that boosts your compliance efforts and ability to manage cyber risks effectively.

Intrada's Perspective on CMMC Certification 

At Intrada, we view CMMC Certification and its final rules as the foundation of any company’s cyber awareness and security policy. Not all rules apply universally to every organization, beginning with the comprehensive requirements set forth by the Department of Defense (DoD) who established a robust standard that minimizes the risk of overlooking critical aspects of security. By aligning with the CMMC framework, organizations strengthen their cyber posture and position themselves favorably for cyber insurance and broader compliance needs. 

At Intrada, we strive to strike a balance between security, policy, and procedure while maintaining productivity and managing operational costs. Most businesses benefit from a standardized policy that is carefully created, thoroughly taught, effectively implemented, and consistently monitored. Such a policy serves the dual purpose of protecting the organization while fostering growth and development in today’s digital landscape.

Achieving CMMC certification may seem daunting, even overkill, but organizations can take steps to make the process more manageable.

Firstly, it is essential to thoroughly assess the current cybersecurity posture and identify any gaps that need to be addressed. 

Next, organizations should develop an action plan that outlines specific steps for achieving compliance with each level of CMMC . This may include implementing new security controls, training employees on best practices, and documenting all processes and procedures. 

Finally, ensure you have a comprehensive plan to regularly review your adherence to cybersecurity policies, train your staff on the importance of cybersecurity and awareness, and maintain thorough records. In the event of an incident, these records will serve as evidence that your organization has taken all necessary steps to protect data, users, and network infrastructure.

CMMC Final Rule

According to available information, the U.S. Department of Defense (DoD) published the final Cybersecurity Maturity Model Certification ( CMMC ) 2.0 Program rule on October 15, 2024. 

  • Date published: October 15, 2024
  • Agency: Department of Defense (DoD)
  • Purpose: To establish the CMMC program, which will enforce cybersecurity standards for DoD contractors handling Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
  • Effective date: December 16, 2024

Cyber is Just Another Expense

Technology continues to evolve rapidly, and as one Harvard expert aptly noted, " AI won't replace people; they will be replaced by people who use AI ." At Intrada, we embrace a similar mindset when it comes to cybersecurity. Companies that prioritize and invest in robust security measures protect themselves and safeguard the customers who rely on them. Conversely, organizations that overlook the importance of security expose themselves to significant risks. 

In today's digital world, businesses are increasingly drawn to partners who prioritize security, privacy, and protection—values that have become essential pillars of trust and resilience. Achieving this balance is crucial, and that’s precisely the kind of relationship you should expect from your IT partner.

Intrada is actively working toward becoming a Registered Practitioner Organization ( RPO ). Before undergoing assessment, CMMC must first be properly implemented. At Intrada, we deeply understand the CMMC framework and the needs of those invested in it. We specialize in preparing companies for successful implementation and eventual assessment, which is why Intrada has invested in CMMC Ecosystem. 

Our expertise and CMMC Registered Practitioner (RP) training allow us to effectively support Organizations Seeking Certification (OSC) as part of our contract engagements. This role is distinct from that of a CMMC Third-Party Assessment Organization (C3PAO), which conducts official assessments. 

At Intrada, guiding clients in achieving a strong cybersecurity posture is a critical responsibility of their managing IT provider. However, when it comes to assessments, we advocate for the involvement of an independent third party to ensure the process is executed correctly and validated with impartial confirmation.

How Can Intrada Help?

In conclusion, the Cybersecurity Maturity Model Certification ( CMMC ) is a comprehensive framework designed to help organizations enhance their cybersecurity practices and protect sensitive information. With evolving updates and strict deadlines, there's no better time to assess your policies and preparedness. A proactive approach is essential, and that's where Intrada can support you.

Our Policy and Compliance Services focus on developing robust policies across all technology services to ensure your organization remains secure and compliant. Additionally, we emphasize the importance of employee training, empowering your team to recognize threats and maintain best practices. Together, we can build a stronger, more resilient cybersecurity foundation.

  • Acceptable Use Policies
  • Access Control Policies
  • ADA (Americans with Disabilities Act) Compliance
  • Business Continuity and Disaster Recovery Plans
  • California Consumer Privacy Act ( CCPA ) for Web Applications
  • Change and Configuration Management Policies
  • Cloud Security Compliance Standards
  • Cybersecurity Maturity Model Certification ( CMMC )
  • Data Loss Prevention ( DLP ) Policies
  • Data Protection and Privacy Policies (e.g., GDPR, CCPA )
  • Encryption and Data Handling Guidelines
  • Endpoint Security Standards
  • Incident Response Plans
  • Information Security Management (e.g., ISO 27001)
  • Network Security Policies
  • Password and Authentication Policies
  • PCI DSS ( Payment Card Industry Data Security Standard)
  • Physical Security Policies
  • Risk Management Frameworks (e.g., NIST , COSO)
  • Secure Software Development Lifecycle (SDLC) Policies
  • Security Awareness and Training Programs
  • Threat Intelligence and Vulnerability Management Frameworks
  • Vendor and Third-Party Security Requirements
  • W3C (World Wide Web Consortium) Accessibility Standards
  • Web GDPR Compliance and Privacy Practices
  • WISP (Written Information Security Plan)

Organizations can better protect their company, employees, and clients by developing strong policies and ensuring staff are trained to follow them. Cybersecurity is constantly evolving, and compliance frameworks like CMMC are just the beginning. Success requires understanding, adaptation, and collaboration. Do you have a technology partner who works with you to align your expectations and requirements with your company’s needs? If not, Intrada can help. Contact us today for a consultation. Together, we can build a stronger and more secure future for your organization. Stay safe! 

This document is part of the Cybersecurity Maturity Model Certification ( CMMC ) series produced by Intrada Technologies.

Disclaimer: This content is for informational purposes only and should not be considered legal or professional advice. Please consult a qualified professional before making significant decisions based on this information. Intrada Technologies does not assume liability for any damages resulting from the use of this material without proper consultation with appropriate legal and/or cybersecurity professionals.

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ABOUT THE AUTHOR

David Steele is the co-founder of Intrada Technologies, a full-service web development and network management company launched in 2000.  David is responsible for developing and managing client and vendor relationships with a focus on delivering quality service.  In addition, he provides project management oversight on all security, compliancy, strategy, development and network services.

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