CMMC Implications for Subcontractors
- Triumvirate Cyber
- Sep 18, 2024
- 3 min read
Certified organizations are responsible for ensuring their subcontractors comply with relevant CMMC and DFARS requirements. Here’s how CMMC will affect you and your subcontractors.
What are the CMMC Implications for Subcontractors?
CMMC and related DFARS clauses mandate specific requirements for organizations within the DIB–including their subcontractors. One of the many issues these requirements are designed to address is security throughout the supply chain. The following are key aspects of ensuring both your and your subs’ compliance so you can both keep doing what you do best!
Contract Flow-Downs
Certified organizations must flow down CMMC requirements to their subcontractors through contracts and agreements. This means that subcontractors must meet the same cybersecurity standards as their prime contractors. Effective flow-down processes involve clear communication and contract clauses that outline cybersecurity expectations for subs. Primes should work closely with their legal teams to draft contracts that reflect these obligations and protect against potential risks. Clear terms and conditions will help mitigate disputes and ensure a mutual understanding of compliance responsibilities.
Oversight and Accountability
Organizations pursuing and holding CMMC certification will need to implement robust oversight mechanisms to ensure that subcontractors adhere to the required cybersecurity practices. This involves regular audits, assessments, and monitoring of subcontractor compliance. The prime remains accountable for any lapses in subcontractor security, underscoring the need for thorough vetting and ongoing risk management.
Cost and Resource Implications
Achieving and maintaining CMMC compliance can be resource-intensive. Subcontractors will face additional costs associated with implementing required cybersecurity measures, such as upgrading systems, training staff, and conducting assessments. Prime contractors should anticipate these costs and factor them into their overall project budgets.
Additionally, providing support and resources to subcontractors can foster stronger partnerships while enhancing compliance. Identifying cost-sharing approaches to compliance can help both you and your subs meet CMMC requirements at a lower cost than independently implementing required solutions.
Risk Management and Mitigation
One of the most common causes of cybersecurity breaches is third-party incidents which provide an initial foothold into a target organization. Prime contractors should collaborate with subcontractors to identify and address potential risks proactively to protect themselves and their subs. This collaborative approach will help mitigate vulnerabilities and strengthen the overall security posture of the supply chain.
Steps for Certified Organizations
To ensure a smooth transition and successful management of subcontractor compliance in relation to CMMC, certified organizations should consider the following steps:
Develop a Comprehensive Third-Party Risk Management Strategy: Establish a clear plan for communicating CMMC requirements to subcontractors and managing their compliance. This strategy should include training, documentation, and regular reviews.
Engage with Subcontractors Early: Initiate discussions with subcontractors early in the contracting process to address CMMC requirements and ensure they understand their obligations. We know CMMC is coming; make sure your subs know it’s on the horizon too.
Implement Effective Monitoring Practices: Set up systems to monitor subcontractor access to your organization’s systems and data. Enhance these by periodically auditing access and subcontractor compliance with the CMMC requirements.
Provide Support and Resources: Offer guidance and resources to help subcontractors achieve and maintain compliance. CMMC can be a substantial undertaking for small organizations, so talking to your subs about collaborating on CMMC compliance can yield cost-sharing solutions that help you both meet the requirements. This collaboration can foster a stronger cybersecurity culture across the supply chain.
Stay Informed and Adapt: Keep abreast of updates to CMMC requirements and adjust your compliance strategies as needed. For example: NIST SP 800-171 Revision 3 is expected to be adopted as the basis for CMMC at some point in the future.* Revision 3 includes changes to existing requirements and additional requirements, such as third-party and supply chain risk management. Keeping an eye on the horizon will ensure your organization is always prepared for regulatory changes!
*CMMC is currently based on NIST SP 800-171 Rev. 2. Revision 3 was published in May 2024, at which time the DoD issued a class deviation specifying that Rev. 2 will be used for CMMC until further notice.
Conclusion
The implementation of CMMC introduces significant changes for organizations and their subcontractors. By understanding these impacts and proactively managing compliance, certified organizations can promote a secure and resilient supply chain. Triumvirate Cybersecurity is here to support you through this process, offering expert advice and solutions to help you achieve and maintain CMMC compliance.
Contact us for more information on how Triumvirate Cybersecurity can help your organization navigate the complexities of cybersecurity and ensure your success building a secure, CMMC-compliant environment.
