32 CFR Part 170: What It Means for Defense Contractors & How to Prepare
- Triumvirate Cyber
- Dec 10, 2024
- 2 min read
The Department of Defense (DoD) has taken a significant step toward improving cybersecurity in the defense industrial base (DIB) with the finalization of 32 CFR Part 170, which officially establishes the Cybersecurity Maturity Model Certification (CMMC) program.
Published in the Federal Register on October 15, 2024, this rule will take effect in a few short days on December 16, 2024. This marks a critical point for organizations seeking certification (OSCs), as compliance will soon become a key requirement for participating in DoD contracts.
What 32 CFR Part 170 Means for OSCs
32 CFR Part 170 lays the foundation for the CMMC program, officially creating the standardized cybersecurity framework to protect sensitive federal contract information (FCI) and controlled unclassified information (CUI). Key elements include:
Certification Framework: Specifies the CMMC Levels (1 through 3) and the process for certification through CMMC Third-Party Assessment Organizations (C3PAOs).
Compliance and Oversight: Establishes mechanisms for monitoring and addressing noncompliance.
Alignment with Published Standards: CMMC Level 1 requires implementation of the “FAR 15” requirements from Federal Acquisition Regulation (FAR) Clause 52.204-21. Level 2 aligns with NIST SP 800-171 (rev. 2), while Level 3 adds additional controls from NIST SP 800-172.
The Path Toward 48 CFR Part 204
While the 32 CFR rule establishes the CMMC program, the upcoming 48 CFR Part 204 will allow the DoD to mandate CMMC certification in contracts, with phased implementation expected to start in 2025. When enforced, OSCs will need to meet specified maturity levels to be eligible for contract awards. Key implications include:
Mandatory Certification: Contracts will include clear requirements for CMMC certification.
Phase-In Timeline: Organizations will have designated timelines for achieving compliance, with strict deadlines tied to specific contracts.
Greater Accountability: Noncompliance will result in disqualification or contract termination, incentivizing proactive cybersecurity measures.
How OSCs Can Prepare
To remain competitive and avoid the risk of being ineligible for future DoD contracts, OSCs must act quickly to align with the CMMC framework. Steps to consider include:
Understand the Requirements: Determine the level of CMMC certification needed based on your organization’s handling of FCI and CUI.
Perform a Gap Analysis: Compare your current cybersecurity practices with the requirements of the targeted CMMC Level.
Implement Security Controls: Address deficiencies by adopting the controls corresponding to your required CMMC Level.
Engage with Experts: Early coordination with qualified consultants and certified assessors will ensure help your organization is ready for the formal evaluation process.
Looking Ahead
The DoD’s timeline for CMMC implementation reflects its commitment to safeguarding sensitive data and enhancing the overall security posture of the DIB. By acting now, OSCs can protect their eligibility for upcoming contracts and contribute to a more secure defense ecosystem.
If your organization needs assistance navigating CMMC compliance, Triumvirate Cybersecurity is here to help. With our expertise in cybersecurity and regulatory compliance, we can guide you through every step of the process.
About Triumvirate Cybersecurity
Triumvirate Cybersecurity is a CyberAB Registered Practitioner Organization (RPO) providing cybersecurity, regulatory compliance, and strategic planning advisory services for organizations pursuing certification under the CMMC program. Contact us today to learn how we can help ensure your organization is prepared for these critical changes.
