CMMC Level 2: The Most Common Obstacles
Looking to become CMMC Level 2 compliant? We’ve got you covered! This article will dive into tips for avoiding common compliance obstacles.
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“Our company wants to become CMMC Level 2 Compliant”
Fantastic! However, achieving CMMC Level 2 compliance is no small feat. It comes with a myriad of challenges, including:
Implementing and documenting 110 security requirements - a major leap from the 17 requirements at Level 1;
Interpreting complex requirements—especially when handling Controlled Unclassified Information (CUI);
Expense - particularly for smaller businesses that often lack the in-house expertise to manage CMMC, forcing them to rely on expensive third-party services;
Implementing technical requirements - including access controls, encryption, and segmentation, to name a few;
Flowing down requirements and ensuring the supply chain meets their CMMC requirements too; and,
Staying on top of constantly evolving CMMC requirements and adapting to new DoD requirements.
Since Level 2 may require a third-party assessment, businesses must identify and fix any gaps before they kick off with a CMMC Third Party Assessor Organization (C3PAO).
“So how would I even start?”
Let's break down each of these challenges and some tips for tackling them.
1. Implementation
CMMC Level 2 is a big step up from Level 1, aligning closely with NIST SP 800-171 revision 2 and requiring organizations to implement and document 110 security requirements—compared to just 17 at Level 1. This can be overwhelming, and many companies struggle to interpret the technical requirements and turn them into effective security policies, especially when it comes to handling Controlled Unclassified Information (CUI).
Hive Systems CMMC Compliance Tip: The CMMC Level 2 Assessment Guide is one of the best resources for identifying each of the requirements, what they mean, and the types of questions you should be asking as you implement them. As an authorized C3PAO, Hive Systems not only understands the requirements, but knows what assessors will be looking for - and can help make sure you’re setting yourself up for success. Contact us today to get started on understanding and implementing your CMMC requirements!
2. Resource Constraints (Time, Budget, and Expertise)
Compliance comes with a hefty price tag, requiring investment in tools, processes, and the right people. For small businesses, this can be especially tough since they often don’t have in-house cybersecurity experts. Instead, they have to rely on external consultants or managed security service providers (MSSPs), which might be convenient but can also get pretty expensive.
Hive Systems CMMC Compliance Tip: It’s all about staying proactive! To boost cybersecurity for small businesses, focus on a few key things: use strong passwords, set up multi-factor authentication, keep software updated, back up your data regularly, train employees on security best practices, and stay alert to phishing scams and malware.
3. Proper Documentation & Policies
CMMC Level 2 isn’t just about having the right security measures in place—it also requires thorough documentation of policies, procedures, and proof that everything is being implemented correctly. CMMC Level 2 also requires a thorough System Security Plan (SSP), outlining how each of your controls are implemented, what your CUI data flows are, and whether you are using external service providers. A lot of companies end up failing their assessments, not because they have poor security, but because their documentation is incomplete or doesn’t meet the requirements.
Hive Systems CMMC Compliance Tip: We offer a wide variety of free resources and templates for your use, including a complete SSP template! Download our SSP today to start building out your CMMC documentation.
4. Technically Daunting
Passing a CMMC Level 2 assessment comes with a lot of technical challenges. The biggest priority is properly identifying, classifying, and protecting CUI. Companies also need to enforce multi-factor authentication (MFA) for privileged and remote access, ensure least privilege access (which can be tricky operationally), and implement strong encryption without making systems unusable. On top of that, organizations must develop and regularly test incident response plans, plus keep employees trained on security threats like phishing and social engineering. It’s a lot to juggle, but all of it is essential for compliance.
Hive Systems CMMC Compliance Tip: When it comes to CMMC, there are many ways to meet the security requirements in a way that is the best fit for your organization- it doesn’t always mean implementing expensive tools. Check out our free CMMC Self-Assessment Tool to help understand what requirements you need to meet, and to ensure full coverage of the security requirements for your environment.
5. Supply Chain Compliance
Contractors need to ensure that any subcontractors or vendors handling CUI are also meeting CMMC Level 2 requirements. Keeping an entire supply chain compliant can be a huge challenge, and managing all the moving parts can quickly become overwhelming.
Hive Systems CMMC Compliance Tip: To manage supply chain cybersecurity effectively, organizations need to take a well-rounded approach. This means doing risk assessments, working closely with partners, setting up security controls, monitoring security continuously, writing CMMC compliance into contracts, and training employees on security best practices. It’s also important to think about diversifying suppliers and having contingency plans in place just in case.
6. Evolving Regulations & DoD Expectations
CMMC is constantly evolving, and DoD requirements can shift over time. Keeping up with the latest guidance and adjusting to changes can be a challenge, but it’s crucial for staying compliant.
Hive Systems CMMC Compliance Tip: We are proud to be a part of the CMMC ecosystem and offer a wide variety of free resources for any updates or changes to DoD requirements. If you are new to CMMC, or just looking for the latest news, the best place to start is our CMMC Resource Center!
7. Readiness for Assessments
Unlike Level 1, where companies can do a simple self-assessment, CMMC Level 2 typically requires a third-party assessment by an authorized C3PAO. That means businesses need to be fully prepared before the official assessment—doing readiness checks, identifying any gaps, and fixing issues ahead of time to avoid surprises.
Hive Systems CMMC Compliance Tip: You’re in luck! No matter where you are in your CMMC compliance journey, Hive Systems is here to help. Whether you’re ready for your CMMC Level 2 assessment and need a C3PAO, or need help getting ready through our readiness and implementation services, Hive Systems is positioned to help you succeed.
How do we know all of this? We’re a C3PAO!
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