With the goal of protecting federal contract information (FCI) and controlled unclassified information (CUI) within the Department of Defense (DoD) contracting community, Cybersecurity Maturity Model Certification (CMMC) will be a requirement for participation in some DoD request for information (RFIs) and request for proposals (RFPs) in 2020, ultimately expanding to all DoD procurement by fiscal year 2026 (FY2026). CMMC will apply to both prime and subcontractors.
Baker Tilly’s CMMC services are designed to support organizations that are required to obtain their CMMC certification.
Based on current CMMC guidance, we can help your organization think through the level and the scope for your CMMC requirement that stems from the Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7021. This could include evaluating if the commercial item exception applies and/or recommending how to best define your scope, and support your representations that CUI does not exist outside of that boundary. Additionally, we can help you determine when or how to use the enclave concept for separate scope.
As you prepare for CMMC, you also need to comply with the DoD assessment requirements associated with DFARS 252.204-7019 and 7020. Baker Tilly can help you conduct your basic assessment against the National Institute of Standards and Technology (NIST) 800-171 requirements or prepare for a Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) assessment. Lastly, we can provide advice about how to load your scores to the DoD’s Supplier Performance Risk System (SPRS).
Using our extensive understanding of cybersecurity, NIST SP 800-171 and the requirements of the CMMC model, we help map your existing controls to the CMMC model, identify gaps between your controls and the CMMC model and provide recommendations for remediating those control gaps. This can be in a mock assessment or more advisory structure to suit your needs.
If needed, our specialists can work with you to build a plan and close your existing gaps. We can help formalize your processes and controls, and document your compliance.
CMMC will have impacts on your supply chain, bid and proposal and project-specific IT systems. Specifically, DFARS 252.204-7019 through 7020 includes requirements for flowdown and validation of SPRS scores and CMMC levels. Leveraging our expertise and years of experience supporting contractors, we can help you think about and develop strategy to respond to issues such as risk assessment of teaming partners. This will ensure they are ready for CMMC so you can successfully bid, flow down clause management, estimate cost implications and respond to RFP and RFI CMMC requirements.
The DoD indicated they understand contractors will incur incremental costs to establish good cyber hygiene and compliance with new requirements. Our specialists will help you navigate within the appropriate frameworks of cost allowability and allocability.
If you are contemplating entering or expanding your government contracting business, we can help you determine gaps with CMMC (or to achieve a higher level of CMMC) and other DFARS, FAR and CAS requirements, as well as support your implementation of those process. We can also help you think about a strategy to increase your opportunities via GSA schedules or other programs.
As the details of the certification program finalize, Baker Tilly intends to become a certified third-party assessment organization (C3PAO) and, where permitted, we hope to support organizations with their official certification assessments. We are also proud to have Matt Gilbert leading our CMMC services. He is one of the first certified provisional assessors and was a participant in the CMMC AB’s working groups.
Our cybersecurity practice uses a variety of technology tools to streamline our service delivery model and make document sharing and requests seamless. Our specialists are well versed in methods for facilitating video conferences, teleconference calls and live, online document-sharing sessions to perform CMMC readiness services as efficiently as if we were live on-site. You can expect the same quality service, all while minimizing travel expenses and space constraints that can accompany on-site work.
“We are committed to helping government contractors meet all of their compliance requirements from CMMC, to the increasing supply chain risk management obligations under section 889 as well as the whole host of complex regulatory compliance, audit and other government oversight burdens.”Matt Gilbert, CMMC Leader