CMMC 2.0 Level 2 Assessment Checklist

Preparing for a CMMC Level 2 assessment requires meticulous planning and execution. In preparation, defense contractors in the DIB should conduct a comprehensive readiness assessment, evaluating their current cybersecurity posture against CMMC requirements. The following recommendations will inform IT, risk, and compliance professionals of their readiness for a C3PAO assessment and ultimately ensuring CMMC 2.0 Level 2 compliance:

1. Take Inventory and Categorize Information

Determine what information qualifies as controlled unclassified information (CUI). Once identified, categorize this information into distinct groups or classifications based on sensitivity, importance, or regulatory requirements. Understanding the type and location of CUI within the organization allows for the development and implementation of tailored security measures, including access controls, encryption standards, data loss prevention techniques, and employee training programs.

2. Conduct a Gap Analysis

Evaluate existing cybersecurity measures and compare them to the standards outlined in NIST SP 800-171, the framework that provides guidelines for protecting controlled unclassified information in non-federal systems. Review current security policies, procedures, and controls to identify how they align with the specific requirements of NIST SP 800-171. Examine aspects such as access control, incident response, configuration management, and risk assessment.

Pinpoint discrepancies in security controls, implementation gaps, and areas where compliance is insufficient. The goal is to create a detailed roadmap for strengthening cybersecurity measures and ensuring compliance with NIST SP 800-171.

3. Implement Required Security Controls

Establish a robust incident response plan to help identify potential threats, respond swiftly to security breaches, and recover from incidents with minimal disruption. Additionally, emplace access control measures to ensure that only authorized personnel can access sensitive systems and data. Use multi-factor authentication (MFA), role-based access controls (RBAC), and regular audits of user access rights. Finally, deploy intrusion detection systems (IDPS), set up automated alerts for suspicious activities, and maintain detailed logs for thorough analysis and reporting.

4. Develop Policies and Procedures

Create a structured framework that addresses security controls, risk management, and data protection strategies relevant to your organization’s operations and compliance obligations in close alignment with CMMC Level 2 requirements. These policies should cover a range of areas, including access control, incident response, data encryption, and security training for employees. It is essential that these policies are meticulously documented, providing clear guidelines and protocols to ensure consistency in implementation and serve as a reference for training purposes. Effective communication is key to embedding these practices within the organizational culture.

5. Invest in Employee Training and Awareness

Conduct regular training sessions and awareness programs for employees, focusing on cybersecurity best practices. Emphasize that everyone plays a critical role in safeguarding CUI. Structure the training programs to cover a variety of important topics, including recognizing phishing attempts, creating strong passwords, and understanding the importance of software updates and patches. Additionally, provide employees a platform to ask questions and discuss scenarios, helping to build a culture of security awareness across the organization.

6. Conduct Internal Audits and Monitoring

Systematically review and evaluate existing security measures and protocols to ensure they are functioning as intended and are up-to-date with the latest security standards. Identify areas where improvements can be made, such as outdated software, misconfigured systems, or gaps in the security policy. Use automated tools and technologies to consistently observe and analyze network activities, system operations, and user behaviors for any anomalies or suspicious activities. This will allow you to swiftly detect potential vulnerabilities or breaches as they occur, minimizing the window of exposure and allowing for a rapid response.

7. Engage with a C3PAO Early

Early collaboration allows defense contractors to tap into a C3PAO’s expertise, offering crucial feedback on areas that need improvement and guidance on best practices. It also allows for a comprehensive understanding of what to expect during the assessment, including the specific criteria and requirements that will be evaluated. The insights gained can help align your processes and documentation with compliance standards, ultimately making the formal assessment process smoother and more efficient.

8. Continuously Update and Improve Cybersecurity Practices

Update technical controls and refine policies, training programs, and incident response strategies to address new threats effectively. Leverage threat intelligence platforms (TIPs) and industry best practices to anticipate potential risks. Engage with cybersecurity experts and consult updated frameworks for valuable insights into emerging threats and optimal defense mechanisms.

Learn More about CMMC Level 2 Assessment

To learn more about CMMC Level 2 assessment and preparing for CMMC compliance, be sure to check out CMMC Level 2 Assessment Guide: A Comprehensive Overview for IT, Risk, and Compliance Professionals in the DIB.

And to learn more about Kiteworks for CMMC compliance, be sure to check out Achieve CMMC Compliance With Complete Protection of CUI and FCI.