In the heart of the digital battleground where privacy and security have become the ultimate prize, the Department of Defense has, quite rightly, raised its drawbridge. But as the dust settles around the Cybersecurity Maturity Model Certification (CMMC), it is not the battlements they’re reinforcing, it’s accountability. And in this author’s opinion, the most crucial change comes with who we allow to shine the light on these iron defenses. 

Understanding CMMC Basics 

The Cybersecurity Maturity Model Certification (CMMC) is, in essence, the Pentagon’s response to an ever-evolving threat landscape. Unlike its predecessor, NIST 800-171, CMMC is a mandatory and thoroughly validated framework that seeks to standardize security practices across all Defense Industrial Base (DIB) organizations. 

CMMC Control Domains 

Originally laid out across five tiers of certification in version 1.0 and evolving to three tiers in version 2.0, CMMC entails a comprehensive mix of controls, ranging from basic hygiene to advanced cyber practices, with increasingly complex and sophisticated safeguards at each level. 

The Evolution from Self-Attestation to C3PAO Audits 

Before CMMC, self-attestation was the norm. Companies could vouch for their own security postures, a process as rigorous as swatting a fly…and all-too-often leading to inaccurate reporting. CMMC changes this in many ways. 

The New Gold Standard: C3PAO Audits 

Under CMMC, organizations will face audits by Certified Third-Party Assessment Organizations (C3PAOs), a process much more robust than similar assessments such as DSS-PCI or HIPAA. The call for accountability and neutrality has never been clearer. 

The Dangers Lurking in Self-Attestation 

Self-attestation is not only outdated but potentially dangerous. Organizations can become islands of systemic risk and, without the watchful eye of an unbiased subject matter expert, this can lead to compromise of not only a business’s IT systems but, indeed, protected national security information. This would inevitably lead not only to the loss of contracts but the exposure of critical vulnerabilities that could have remained hidden or untreated with more attention paid to the details of cybersecurity. 

The Benefits of an Outsourced IT Security Expert 

There is a beauty in accountability and impartiality that outsourced IT security experts can bring to the table. An external viewpoint can often uncover the blind spots that satisfied employees or trusted systems may inadvertently overlook. 

Amplifying Expertise and Staying Updated 

Bringing in outside experts does more than provide fresh eyes; it brings expertise from a chorus of industries and challenges that a well-integrated internal team may never face. These IT auditors are not only immersed in the latest techniques and technologies—they often pioneer them. 

Long-Game Investments That Could Save Millions 

The cost of an IT security expert’s ongoing consultation, investigation, and CMMC alignment actions for compliance, to include C3PAO audits, may initially seem like an unnecessary overhead, but C-level forward thinking will inevitably reveal that these expenses could save organizations significantly in the long run. From avoiding emergency hardware or software integrations to loss of defense contracts, the argument for foresight and preparation becomes easily compelling. 

Staunching the Ineffectiveness of Self-Assessments 

Those in favor of self-assessments may tout the process’s economic benefits, but it is a philosophy that is flawed at the core. An internal assessment is only as valuable as it is honest, and too often, it is colored by convenience or the dangerous refrain of ‘that’s how we’ve always done things’. In the experience of many MSPs performing compliance alignments, inaccurate attestation is not only common but the norm. However, this type of reporting is dangerous, both in securing controlled information but as well can be criminal. Certified CIO’s Chief Information Security Officer Shaun Miller warns of fraudulent compliance statements: 

Do not claim to have implemented security measures unless you genuinely have. False claims will result in legal consequences, including imprisonment and repayment of your government contract multiplied by three. 

The False Claims Act covers this type of activity. 

The Cost of Complacency 

Under the shadow of potential C3PAO audit failures or loss of defense contracts, the initial price of an outside subject matter expert becomes more palatable than the deep financial cost threatened by complacency. Outsourced CMMC alignment is a strategic investment in an organization’s longevity and credibility. 

In the cyber metropolis, the battle is not only fought with innovative technology, but also with a brave new way of thinking. It’s time for the DIB to embrace the change that CMMC heralds — not as yet another offensive in the war for data security but as an opportunity to invite wisdom in through a different (albeit mandatory) door. 

Let the legacy of CMMC be a narrative of collaboration and growth, where every challenge is recognized not as a barrier but as a stepping stone towards a more impenetrable, and trusted, future. If you need a helping hand with CMMC alignment, CERTIFIED CIO has a TEAM OF EXPERTS ready to assist! Contact Us Now!

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