Overcoming Common Challenges in NIST/CMMC Self-Assessments

In the increasingly critical landscape of cybersecurity within the Defense Industrial Base (DIB), compliance with NIST (National Institute of Standards and Technology) and CMMC (Cybersecurity Maturity Model Certification) is paramount.  

A crucial step in this process is the self-assessment. This assessment identifies gaps in your company’s cybersecurity posture, enabling timely remediation before the final third-party assessment. Let’s take a moment to explore NIST and CMMC compliance and how DIB companies can effectively navigate the challenges of self-assessments. 

Understanding NIST and CMMC 2.0 Compliance 

Let’s take a quick look at what NIST and CMMC 2.0 actually are.  

NIST SP 800-171 specifies how to protect Controlled Unclassified Information (CUI) in non-federal systems and organizations. The Department of Defense (DoD) requires its contractors to comply with NIST SP 800-171 through contract clauses like DFARS 252.204-7012. 

The Cybersecurity Maturity Model Certification (CMMC) program, announced by the DoD in 2019, builds upon NIST SP 800-171 by adding a certification element to cybersecurity compliance. CMMC 2.0, the current version, includes three levels of certification based on the sensitivity of information handled. CMMC 2.0 is expected to begin appearing in DoD contracts in 2025, following final rule implementation. 

Common CMMC 2.0 and NIST Self-Assessment Challenges 

Here are some of the challenges that companies tend to face when it comes to the self-assessments for CMMC 2.0: 

Challenge 1: Lack of Understanding of Requirements 

Many companies struggle to interpret the complex technical language of NIST SP 800-171 and CMMC requirements. To address this, organizations should start early, conduct thorough research, and seek guidance from third-party cybersecurity consultants. 

Challenge 2: Incomplete Documentation 

Inadequate documentation of policies, procedures, and security controls can hinder CMMC certification. Develop a comprehensive documentation strategy, ensuring all processes are well-documented and regularly updated. 

Challenge 3: Resource Constraints  

Smaller DIB organizations often face resource limitations. Break down the assessment process into manageable tasks, prioritize high-impact areas, leverage automated tools, or outsource key aspects to compliance experts. These steps will make the self-assessment more effective and efficient. 

Challenge 4: Identifying and Mitigating Gaps 

Even with tools in place, it might present a challenge identifying discrepancies between current security practices and NIST/CMMC requirements. Conduct a thorough gap analysis and develop an actionable remediation plan. Consider utilizing third-party tools or professional services. Finding those gaps before you do a third-party assessment will save you money and time. 

Challenge 5: Meeting the Required Security Controls 

Implementing all 110 NIST SP 800-171 controls or achieving CMMC Level 2 maturity can be difficult. Adopt a phased implementation approach, starting with critical controls and expanding as resources permit. 

Challenge 6: Keeping Up with Evolving Standards 

NIST and CMMC 2.0 requirements will continue to evolve and change, and it can be challenging to stay compliant with new updates. Once you move forward, you now have to become an informed CMMC/NIST person, and you can do this by subscribing to official publications and maintaining flexibility in your compliance strategies to adapt to new requirements. 

Best Practices for Conducting Effective NIST/CMMC Self-Assessments 

Here are some steps you can take to improve your chances of having a successful self-assessment: 

1. Perform a Pre-Assessment: Start with a baseline assessment to understand your current level of compliance. You can do multiple pre-assessments until you get as close to complete as possible. It may seem like a lot of time, but it will ultimately save you headaches down the road. 
2. Create a Cross-Functional Team: Involve multiple departments (IT, compliance, HR, etc.) in the self-assessment process to ensure comprehensive coverage. This entire process should not fall on one person and should include anyone who has to interact with CUI at any level. 
3. Focus on Risk Management: Beyond mere compliance, focus on understanding the risks associated with your gaps and how they affect the security of CUI. 
4. Regularly Review and Update: Make self-assessments a continuous process, ensuring that your security measures evolve along with the threats and regulatory updates. Stay ahead of the curve on this and you won’t be caught flat-footed when the DoD adds or changes regulations. 

The Role of Third-Party Assistance in Self-Assessments 

It can be a lot to try to learn this all yourself. Even a company that has some familiarity with this can find the CMMC 2.0 assessment process a challenge. This is why there are third-party consultants out there who can help. It is worth the investment to make it easier to navigate this maze. Third party consultants can provide a fresh perspective or assist with complex areas of the self-assessment. 

CMMC Self-Assessment is a Crucial Step to Certification 

Self-assessments are critical in preparing for audits and ensuring that your organization remains compliant with NIST and CMMC requirements. Doing this crucial step in the CMMC certification process will help you find gaps and figure out where you need help in order to become certified. 

Fortunately, we at Exostar are experts in CMMC compliance. Our CMMC Ready Suite provides you with the tools you need to not only do the self-assessment but also get through the entire process to become certified. Contact us today and we can set up a demo and discuss options for your business.