CMMC Program Executive: How Defense Industrial Base Organizations Can Prepare for the CMMC Program


The New CMMC Rule 

The security of each organization that supplies goods or services to the Department of Defense (DoD) is of vital importance to the nation’s cyber resilience. The CMMC Program is a part of a holistic initiative by the DoD and Federal Government to enforce cybersecurity standards for DoD contractors and subcontractors and increase supply chain visibility and resilience overall. FedRAMP has increased the security levels of Cloud Service Providers (CSPs) and Software as a Service (SaaS) companies in the technology supply chain. Within the DoD supply chain, CMMC encourages DIB organizations to raise their cyber maturity and resilience. The Code of Federal Regulations (CFR) Title 32 rule passed its 60-day Congressional review on December 16, 2024, officially launching the new Cybersecurity Maturity Model Certification (CMMC) Program. The last remaining step to operationalizing CMMC is the CFR Title 48 rule, which will allow the Government to implement CMMC requirements into contracts and is estimated to launch this year. Defense Industrial Base (DIB) organizations will begin to see CMMC requirements in their contracts with the DoD and related agencies and must be prepared to demonstrate their compliance with the new regulations.  

In the latest version, DOD contracts will require one of three cyber maturity levels for all prime or subcontractor organizations under a given contract.  During Phase One of the program rollout, DIB organizations will need to provide a self-assessment of their relevant maturity level for the contracts they desire. Then in Phase Two, estimated to begin in 2026, maturity level two contracts will require assessments conducted by a third-party Cyber AB approved C3PAO.  The program will be completely rolled out over four phases.   


Gaining CMMC Compliance 

It will be vital for all organizations to have the relevant level of cyber maturity so that they can continue delivering work, goods and services to the DoD. Whether they are the prime contractor or a subcontractor, defense contractors should expect to see CMMC requirements in their contracts. Prime contractors will pass the maturity level requirements down to subcontractors as a condition of receiving sub-contract work.  

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Since the DoD first announced the CMMC Program, it has been building momentum and communicating the framework of the Program to DIB organizations. While there have been minor changes, the core of the framework has remained consistent over the past four years. DIB organizations that have not begun working on compliance should start immediately so they can deliver a self-assessment in early 2025 or a third-party audit in 2026 if they are a level two contractor. With the limited supply of C3PAOs and CMMC assessors, there will likely be a supply shortage resulting in back logs for scheduling a CMMC assessment. Furthermore, organizations looking to utilize external service providers (ESPs) need to engage with those companies early, as there is a limited supply of available compliant options. Ultimately, gaining CMMC compliance is a critical national security mission. With cyber security and data becoming more paramount to the strength of a nation, protecting the data that resides outside DoD firewalls on contractor networks is imperative. 


Changes to the Contracting World 

CMMC encourages DIB organizations to raise their cyber maturity and resilience. Many DIB customers have begun with self-assessments, engaged with consultants for gap assessments and migrated to Government cloud products. This trend has spread to the civilian side of the Federal Government, as well as to American allies, who have discussed or announced mandatory certification programs modeled on National Institute of Standards and Technology (NIST) standards. But for some small and medium sized businesses, cost is a barrier to gaining CMMC compliance, especially for level two or above. The defense industry has responded to that challenge by innovating and developing more offerings for advisory and consulting services, managed services and purpose-built technology that will help companies accelerate their CMMC journey. This expansion of choice allows for a more ideal fit for each individual company based on its unique environment, considering factors such as in-house talent, available resources and budget.  

It is not just prime contractors that must have the appropriate CMMC certification, but subcontractors as well. They will need the same CMMC maturity level as their prime contractor before storing or processing any Controlled Unclassified Information (CUI) or Federal Contract Information (FCI) as part of a contract delivery. To maintain competitiveness, subcontractors will need to achieve CMMC compliance of their own.  Ultimately, the prime will be responsible for validating the CMMC maturity level of their subcontractors and will need to put in place a process to do so.  

Ultimately, CMMC compliance is a vital contribution to the security of Federal data. Whether an organization is beginning to research CMMC, scoping out the boundaries of their CUI environment, or preparing to remediate the gaps to full compliance, it is a good time to start thinking about CMMC compliance.  


How Carahsoft Can Help 

Carahsoft is a proud part of the cybersecurity industry and the CMMC ecosystem. Gaining CMMC compliance can be a costly and time-consuming process; Carahsoft can guide your organization through all the available options and help make decisions that are best suited to meet your organization’s unique needs. As a value added reseller that represents over 200 cybersecurity technology vendors, and with over 1000 team members focused on our wide breadth of cyber offerings, Carahsoft can support DIB organizations in addressing every CMMC maturity level and capability domain. Carahsoft can foster connections with service providers, subject matter experts and advisory consultants that can help organizations prepare for or execute a CMMC assessment. By tracking policies and trends that align with customer needs, Carahsoft can pair your organization with the right technology to address your needs, as well as offer news, educational material, events and other resources to make an informed decision for CMMC compliance.  

To learn more about gaining CMMC compliance, visit Carahsoft’s CMMC Compliant Products and Services portfolio 

DevSecOps: Achieving Efficiency and Scale with Automation and Software Factories

In today’s rapidly evolving digital landscape, Government agencies face many challenges in delivering modern, secure software applications to the end-user. DevSecOps is a methodology that combines development, security and operations to create a more streamlined and secure software development process. This concept has emerged as a transformative approach that integrates security practices, automation and software factories into the software development lifecycles from its inception. At the Carahsoft DevSecOps Conference, industry experts and innovators shared their knowledge of emerging tools, effective strategies and methodologies in software engineering through several educational sessions.

Unlocking Efficiency: The Power of Automation and AI/ML

Automation helps developers improve the efficiency and quality of code, reduce risk and combat security vulnerabilities. As a key component of DevSecOps, automation allows developers to simplify many of the tasks involved in software development, such as testing, deployment and monitoring. Once automated, developers can focus on writing high-quality code and addressing security vulnerabilities, rather than spending time on redundant manual tasks.

The use of AI has transformed the way developers work, compared to 20 years ago when code was primarily written from scratch. Today, external libraries — software code written by a third-party source — are used frequently which introduces a new set of risks and benefits. The benefits include making software development faster and more efficient as developers use pre-existing code to build their applications. However, if a third-party library has a security vulnerability, it can be exploited by malicious actors to gain access to sensitive data. If not maintained properly, the third-party library can become outdated and incompatible with other software components.

Carahsoft DevSecOps Conference Blog Embedded Image 2023Software Factories

Software development has become an essential part of today’s business operations, and Government agencies are constantly seeking ways to improve their processes. Recently, the concept of the software factory—a structured approach to software development that emphasizes standardization, automation and collaboration—has gained popularity. It establishes a set of tools, processes and best practices that enable teams to develop software more efficiently and effectively. The goal of a software factory is to create a repeatable and scalable process for software development that can be applied across different projects and teams. By implementing this strategy, agencies can improve the quality, speed and consistency of their software development efforts.

One of those best practices, Continuous Integration and Continuous Deployment, are combined in a single process known as CI/CD. CI is the practice of frequently merging code changes from multiple developers into a shared repository, where automated tests are run to address integration issues early in the development cycle. This ensures the code is always in a releasable state and reduces the risk of conflicts and errors when changes are merged. CD, on the other hand, is the practice of automatically deploying code changes to production as soon as they pass the necessary tests and checks. Thus, enabling teams to release software changes quickly and frequently. By utilizing CI/CD, teams can achieve a continuous flow of code changes from development to production, which is imperative for modern software development.

Elevating DevSecOps: A Blueprint for Integrating Early Software Security Measures

Securing software in a containerized environment presents unique challenges due to the dynamic nature of containers and the distributed nature of container orchestration platforms like Kubernetes. Government agencies must ensure that containers are properly configured and secured, as misconfigurations can lead to vulnerabilities that can be exploited by attackers. Another difficulty is detecting and responding to security incidents in a timely manner, as containers can be spun up and down quickly and may be spread across multiple nodes in a cluster. Securing software early can help agencies reduce risk, lower costs, deliver software faster and improve collaboration between development and security teams.

Another crucial component of DevSecOps—continuous delivery—enables teams to deliver software changes quickly, safely and sustainably. This means that teams can release software changes frequently and with confidence, knowing that the changes have been thoroughly tested and are ready for production. Through a combination of automation, collaboration and feedback loops, continuous delivery helps reduce the time and effort required to release software changes.

Agencies can adopt a DevSecOps approach that integrates security into the software development lifecycle from the beginning. This involves using tools and processes to automate security testing and validation, as well as incorporating security requirements into the development process. For instance, agencies can use tools like vulnerability scanners and security-focused container images to detect and remediate vulnerabilities in containers. They can also use automation to validate security requirements and ensure that containers are properly configured and secured.

Securing software early in the development process can lead to several benefits including:

  • Reduced risk of security incidents: By identifying and addressing security vulnerabilities early in the development process, agencies can minimize the risk of security incidents and data breaches.
  • Lower costs: Fixing security issues later in the development process is much more expensive than addressing them early on. By integrating security into the development process from the beginning, agencies can reduce the cost of fixing security issues and avoid costly rework.
  • Faster time to market: Adopting DevSecOps approach can help agencies to deliver software faster by automating security testing and validation. This decreases the time for manual testing and enables faster release cycles.
  • Improved collaboration: Agencies can strengthen collaboration between development and security teams to ensure requirements are properly understood and incorporated into the development process. This proactive initiative can help foster a culture of security throughout the agency.

The adoption of DevSecOps, along with its fundamental principles, empowers Government agencies to establish a more efficient and secure software development process. This is achieved through the implementation of automation, the adoption of a software factory approach and the early integration of security measures.

 

To learn more about DevSecOps best practices and trending innovations, visit Carahsoft’s DevSecOps vertical solutions portfolio. 

*The information contained in this blog has been written based off the thought-leadership discussions presented by speakers at Carahsoft’s annual DevSecOps Conference.*

How to get StateRAMP Ready Faster with Security Snapshot

Security is of utmost importance to government agencies because they have access to the sensitive information of millions of people. To ensure this information stays private, StateRAMP (State Risk and Authorization Management Program) offers several guidelines to help.

StateRAMP is a nonprofit launched in 2021 and modeled after FedRAMP, a government-wide program that promotes secure cloud usage across the Federal government. State and local governments created StateRAMP to extend this authorization to the relationships between cloud service providers (CSPs) and state and local governments to improve cybersecurity posture. As an independent  nonprofit organization, StateRAMP has created a process for continuous cybersecurity improvement to efficiently and cost-effectively verify the cybersecurity of cloud service providers.

Carahsoft StateRAMP Security Snapshot Blog Embedded Image 2023A main initiative is evaluating the data security capabilities of cloud solution providers that sell to state and local governments. StateRAMP ensures CSPs meet minimum security requirements and helps them obtain verification and achieve certification. These verification statuses were created by StateRAMP and must be certified by a third party. To simplify this certification process, StateRAMP has introduced “Security Snapshot.”

Hurdles to Attaining StateRAMP Verification

StateRAMP has had an Authorized Product List since 2021,updated at the end of every business day. This list is comprised of verified providers who meet the minimum security requirements and provide an independent audit conducted by a Third Party Assessment Organization (3PAO). StateRAMP recognizes three verified statuses:

  1. Ready: The product meets minimum requirements.
  2. Provisional: The product exceeds minimum requirements and has a government sponsor.
  3. Authorized: The product satisfies all requirements and has a government sponsor.

There are 38 cloud service offerings (CSOs), 4 local government agencies, 2 universities and 17 states that are qualified in the above three tiers.

A Simpler Future with Security Snapshot

After StateRAMP’s verification process was introduced, providers encountered several questions. For some CSPs, it wasn’t easy to know if they could achieve a StateRAMP-Ready approval. The fear that CSPs would be left with a public, poor StateRAMP score induced anxiety in starting the approval process. Many agencies were unsure if they were making progress in the right direction. To combat this, StateRAMP released a new solution in early January 2023—the “Security Snapshot.”

Security Snapshot provides detailed information on how companies can get StateRAMP-certified. The snapshot offers a preliminary numerical score that CSPs can share with prospective government clients, which will not appear on the CSP’s record.

This resource acts as an early-stage security maturity assessment tool for cloud products. The intent of the service is to provide a first step toward achieving StateRAMP security status. The criteria are designed to help agencies validate minimum requirements and provide controls and additional benchmarks that would further aid in certification.

The Security Snapshot also helps providers gain quality insight into security postures and third-party cloud solutions such as Software as a Service (SaaS), Infrastructure as a Service (IaaS) and Platform as a Service (PaaS) products. Ultimately, it provides insights for providers and the government branches they serve.

With the introduction of Security Snapshot, CSPs can ease their concerns, knowing they will receive detailed, personalized support to help them qualify for StateRAMP’s verification.

 

For more information on StateRAMP’s security approach, visit our StateRAMP resource hub and watch our Carahsoft briefing at carah.io/StateRAMP.