In the world of technology, an external service provider means many things to many people. It could mean a Managed Service Provider, a Security Vendor, or a Print Vendor. You may also utilize external vendors for application development or staffing your internal IT team. The definition takes many shapes and sizes. How Your External Provider Impacts Your CMMC Compliance is crucial to understand, as these providers play a significant role in maintaining your organization’s security standards.
Within the US Department of Defense and the recently finalized Cybersecurity Maturity Model Certification (CMMC), the external service provider (ESP) has a much more defined definition. Companies that outsource part or all of their IT services need to familiarize themselves with this definition.
If your organization contracts with the Department of Defense (DoD), Defense Industrial Base (DIB) prime contractors, or their sub-contractors of DIBs, the external service provider will play a more important role in your compliance journey.
The illustration below represents how we got here.
Understanding the Updated CMMC Compliance
According to the newly updated CMMC framework, effective from December 16, 2024, your organization may be required to meet one of three assessment levels.
The levels are:
- Level 1: Basic safeguarding of Federal Contract Information (FCI) through self-assessment.
- Level 2: Protection of Controlled Unclassified Information (CUI) with either third-party or self-assessment
- Level 3: Enhanced protection against advanced persistent threats, requiring a Defense Industrial Base Cybersecurity Assessment Center-led assessment.
Although we see most contractors being required to meet Level 2, all levels will require participation from your external service provider.
The Role of Your External Service Provider
- Your external service provider and your organization must have a very well-defined responsibility matrix defining which organization is responsible for each CMMC control.
- The relationship between your organization and the ESP must be detailed in your System Security Plan (SSP)
- The Security requirements for CMMC must be documented for ESP in the SSP.
- YOUR ESP EITHER HAS TO BE CMMC CERTIFIED THEMSELVES OR PARTICIPATE IN THE AUDIT WITH YOU.
Compliance Readiness
Most organizations will need help beyond their ESP’s to get them ready for CMMC compliance. Consider using a consulting firm that will help you and your ESP’s be prepared for CMMC compliance. Most consulting organizations offer the following services to help you prepare.
- Expertise and Guidance
- Simplifying Compliance: CMMC consultants can help you understand and implement the updated CMMC requirements.
- Custom Solutions: They offer solutions tailored to your specific needs and compliance goals.
- Security Controls Implementation
- Technical Controls: They set up essential controls like multi-factor authentication, encryption, and continuous monitoring.
- Policy Development: They help create and enforce cybersecurity policies that meet CMMC standards.
- Audit Preparation and Support
- Pre-Audit Assessments: They identify and address any compliance gaps before an official audit.
- Documentation and Reporting: They help prepare the necessary documentation and reports for the audit.
CMMC Final Rule Drops: Is Your Business Ready?
With the final rule now published and the program set to take effect on December 16, 2024, companies must determine their required CMMC level, identify critical assets, implement the necessary technology, and prepare for an assessment. As contracts start rolling out in mid-2025, ensuring your organization is compliant and ready to bid is crucial. How your external provider impacts your CMMC compliance is also a key consideration, as the right provider can significantly influence your readiness and overall compliance.
