Alphabet Soup: CMMC, DFARS, CFR, and More!
- Triumvirate Cyber
- Sep 24, 2024
- 3 min read
The CMMC program is a prime example of how complex and nuanced the federal regulatory environment can be. If you're a contractor working with the Department of Defense (DoD), you've probably encountered acronyms like CMMC, DFARS, and CFR. But what do they all mean, and how do they fit together?
Let’s break down the alphabet soup of regulations and frameworks underpinning the CMMC program, helping you understand the foundational requirements and how they shape the compliance environment.
What is CMMC?
If you're reading this, you likely already know, but it's always best to start from the beginning. The Cybersecurity Maturity Model Certification (CMMC) is the DoD’s framework to ensure contractors meet specific cybersecurity standards to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). CMMC is designed to be a unifying standard for implementing cybersecurity across the defense industrial base (DIB) and ensure that contractors can safeguard sensitive data from growing cyber threats.
The CMMC framework is organized into three maturity levels, from basic cyber hygiene to advanced cybersecurity practices. The higher your level of certification, the more stringent the cybersecurity requirements become, which in turn qualifies you for contracts handling increasingly sensitive data. If you need a starting point on the certification levels, see our CMMC TL;DR post.
But CMMC doesn’t operate in a vacuum. It is built on a foundation of established rules, policies, and frameworks that the government has been using for decades.
DFARS: The Backbone of Cybersecurity Requirements
The Defense Federal Acquisition Regulation Supplement (DFARS) is a set of regulations that supplements the Federal Acquisition Regulation (FAR) and specifically governs procurement for the DoD. Within DFARS, cybersecurity standards have been mandated for years, with the most significant clause being DFARS 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting.”
This DFARS clause requires contractors to implement security controls as defined by NIST SP 800-171, a set of 110 cybersecurity controls that are essential for protecting CUI.* Contractors must demonstrate compliance with these controls, report any cybersecurity incidents to the DoD, and ensure their subcontractors also meet the necessary security requirements.
*The CMMC program is based on NIST SP 800-171 Revision 2, per a class deviation issued by the DoD, despite Revision 3 being released in May 2024.
CMMC vs. DFARS: How do they relate?
CMMC builds upon DFARS 252.204-7012 and NIST SP 800-171 by incorporating additional cybersecurity practices and processes that are organized into different maturity levels. While DFARS mandates the implementation of NIST SP 800-171, CMMC goes a step further by introducing third-party assessments to ensure contractors meet the necessary security standards based on their maturity level.
Understanding CFR: The Federal Rulebook
The Code of Federal Regulations (CFR) is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the federal government. When we talk about the regulations governing defense contracting and cybersecurity, two titles of the CFR are particularly relevant:
Title 32 CFR governs national defense, including regulations issued by the DoD. This title provides the regulatory authority for many defense-related programs, including cybersecurity.
Title 48 CFR is the FAR, which governs all federal acquisitions and contracts. Title 48 includes DFARS as well as other agency-specific supplements to the FAR, which are essential to understanding the legal landscape of federal contracting.
The Bigger Picture: NIST, FIPS, and More
While CMMC, DFARS, and the CFR provide the regulatory structure, other standards and frameworks also play critical roles. The National Institute of Standards and Technology (NIST) develops cybersecurity frameworks like NIST SP 800-171 and NIST SP 800-53, which serve as the technical backbone for CMMC.
Additionally, Federal Information Processing Standards (FIPS) like FIPS 140, which outlines security requirements for cryptographic modules, also influence CMMC requirements. These standards help guide contractors on how to secure systems and information in line with federal expectations.
Why Should Contractors Care?
Complying with CMMC, DFARS, or any of the underlying regulations isn’t just about satisfying legal requirements — it’s about protecting sensitive national security information from cyberattacks, which are becoming increasingly sophisticated and frequent.
By understanding the relationships between CMMC, DFARS, and the broader regulatory framework, contractors can better navigate the complex compliance environment and position themselves for long-term success in the federal marketplace.
Wrapping Up the Alphabet Soup
Navigating the alphabet soup of CMMC, DFARS, NIST, and CFR may seem daunting, but with the right knowledge and preparation, contractors can meet and exceed the necessary cybersecurity standards.
At Triumvirate Cybersecurity, we help organizations demystify these regulations and implement robust cybersecurity practices to achieve and maintain compliance. Whether you're at the beginning of your CMMC journey or seeking to elevate your cybersecurity posture, our team of experts is here to guide you through the process.
