Defense Industry Preparation: Major Interruptions Impacting the Defense Industrial Sector
The Cybersecurity Maturity Model Certification (CMMC) is a significant shift in how Defense Industrial Base (DIB) contractors engage with the Defense Department. The proposed Federal CUI rule, which applies to agencies outside the Department of Defense, is set to further define the expectations for Controlled Unclassified Information (CUI) [1].
Cost Challenges
Achieving and maintaining CMMC compliance requires substantial investment. Contractors need to allocate resources for system mapping, compliance documentation, assessments, and certification fees. These costs are sustained over time, as compliance is an ongoing requirement, not a one-time effort [2]. The biggest challenge for CMMC compliance, according to a recent survey, is cost, with 57% of respondents indicating it as a top preparation challenge [3].
Timeline Confusion
Despite the DoD establishing timelines for CMMC Level 2 and Level 3 assessments, contractors face uncertainty about exact deadlines and phases of compliance enforcement. This creates challenges for planning resource deployment, coordinating internally across cybersecurity, contracts, and program functions, and aligning sub-tier supply chain readiness [2][3].
Defining Controlled Unclassified Information (CUI)
Contractors must identify all CUI that they handle to apply the correct security controls. Due to the broad range of information types and variable interpretations of what constitutes CUI, this definition can be ambiguous. Misidentification risks either under-protection (jeopardizing compliance) or over-extension of controls (increasing cost and complexity) [1][2].
These challenges collectively create a complex compliance landscape. Successful navigation demands coordinated efforts across technical cybersecurity measures, contract management, and strategic business planning to ensure readiness and maintain competitive positioning in the defense supply chain [2][3].
Mitigating Risks and Ensuring Readiness
Inaction on CMMC could expose an organization to serious legal risk under the False Claims Act. Contractors should follow the CMMC L2 Scoping Guide to identify any asset that stores, processes, or transmits CUI. Engaging a CMMC certified professional or assessor, or at least assessing your contracts and clarifying CUI expectations with your contracting officer, can help ensure readiness [1].
The recently proposed 48 Code of Federal Regulations (CFR) Federal CUI rule may require agencies to define expected CUI types more clearly, which could help alleviate some of the confusion [1].
Conclusion
Navigating the complexities of CMMC compliance is a critical task for DIB contractors. By understanding the challenges and taking proactive steps, contractors can position themselves for success and maintain their competitive edge in the defense supply chain.
[1] Thomas Graham, vice president and chief information security officer at Redspin, emphasizes the importance of staying informed and proactive. [2] "Navigating CMMC: A Guide for Defense Contractors," National Law Review, 2021. [3] "2021 CMMC Readiness Report," CMMC-AB, 2021.
- The federal workforce, faced with the challenges of CMMC compliance, must reimagine their strategies to allocate resources efficiently, especially in areas of finance, as significant investments are required for system mapping, compliance documentation, assessments, and certification fees.
- With the ongoing need for CMMC compliance, defense contractors must leverage technology to streamline business operations, ensuring they can align sub-tier supply chain readiness, plan resource deployment, and maintain their competitive positioning in the federal workforce.
