TGC SERVICES PHASED APPROCH TO COMPLIANCE. 

In a rapidly evolving digital landscape, the security of sensitive information has never been more critical. For organizations engaging with the Department of Defense (DoD) and entrusted with Controlled Unclassified Information (CUI), compliance with the Cybersecurity Maturity Model Certification (CMMC) is not just a requirement; it’s a fundamental commitment to national security. 

As we embark on the journey of CMMC compliance, it’s essential to understand that the path is multifaceted, demanding a strategic and comprehensive approach. At TGC Services, we recognize that achieving CMMC compliance is not a one-size-fits-all endeavor. It requires a tailored methodology that aligns with your organization’s unique needs and obligations. 

In this article, we’ll explore TGC Services CMMC compliance approach and methodology, highlighting the principles that guide our efforts, the steps we take to support our clients, and the assurance that comes with our dedication to securing the defense supply chain. 

OUR CORE PRINCIPLES 

At TGC Services, our CMMC compliance approach is underpinned by a set of core principles: 

1. Tailored Solutions: We understand that every organization is different, and their security requirements vary. Our approach begins with a deep understanding of your specific needs, allowing us to tailor solutions that align with your business objectives and compliance obligations. 

2. Proactive Security: Cyber threats are ever-present, and being reactive is not an option. Our methodology focuses on proactive security measures, ensuring that you’re well-prepared to defend against emerging threats. 

3. Collaborative Partnership: We view our clients as partners in the pursuit of CMMC compliance. We work alongside you, providing guidance, training, and support to empower your organization to navigate the complexities of the CMMC framework. 

4. Continuous Improvement: Achieving CMMC compliance is not a one-time accomplishment; it’s an ongoing commitment. Our approach includes measures for continuous improvement to adapt to evolving threats and regulations. 

OUR COMPLIANCE APPROACH AND METHODOLOGY 

Our CMMC compliance methodology follows a structured and strategic 5-Phase approach. This abbreviated overview outlines our comprehensive process, with detailed outlines of each phase to follow: 

PHASE 1: DISCOVERY 

In this initial phase, we gain a deep understanding of your organization’s current state. We identify Controlled Unclassified Information (CUI) and determine the required CMMC level as mandated by your Department of Defense (DoD) contracts. 

PHASE 2: INITIAL COMPLIANCE ACTION ITEMS 

Building on the insights from the discovery phase, we take essential initial compliance actions. These serve as foundational steps in aligning your organization with CMMC requirements. 

PHASE 3: LEVEL 1 CONTROLS – BASIC SAFEGUARDING 

This phase focuses on Level 1 Controls, which represent fundamental security measures designed to protect Federal Contract Information (FCI). These controls provide a basic defense against common cyber threats, as specified by FAR 52.204-21. 

PHASE 4: LEVEL 2 CONTROLS – PROTECTION OF CUI PER DFARS 

In Phase 4, we shift our attention to Level 2 Controls, as defined by the Defense Federal Acquisition Regulation Supplement (DFARS). These controls introduce more advanced security measures to safeguard Controlled Unclassified Information (CUI). 

PHASE 5: TRAINING AND CMMC AUDIT READINESS PREPARATION 

Phase 5 emphasizes the importance of preparing your organization to be both compliant and audit-ready as the CMMC compliance deadline approaches. We provide the necessary training and readiness measures, ensuring your organization is well-prepared for the final audit. 

CONCLUSION 

In conclusion, TGC Services’ approach to CMMC compliance is underpinned by a commitment to security, collaboration, and continuous improvement. We recognize the complexities of navigating the CMMC framework and the significance of safeguarding sensitive information. Our goal is not merely to assist organizations in meeting contractual obligations but also to bolster the defense supply chain’s integrity and contribute to national security. Join us on this journey through our comprehensive approach and methodology, and together, we’ll navigate the path to a secure and compliant future. Detailed outlines of each phase will follow, providing a deeper understanding of our process. 

PHASE 1: DISCOVERY 

IDENTIFY CONTROLLED UNCLASSIFIED INFORMATION (CUI) 

Determine the types of Controlled Unclassified Information (CUI) that your organization handles. This includes data such as financial records, technical drawings, specifications, and any other information that must be safeguarded in accordance with NIST 800-171 and CMMC. 

UNDERSTAND NIST SP 800-171 REQUIREMENTS 

Study and comprehend the NIST Special Publication 800-171 standards and controls. These controls define the security measures that organizations need to implement to protect CUI effectively. 

DETERMINE CMMC LEVEL REQUIREMENT 

Identify the specific Cybersecurity Maturity Model Certification (CMMC) level that your organization is required to achieve based on your contracts with the Department of Defense (DoD). This level will dictate the security measures you need to implement. 

ASSESS CURRENT SECURITY MEASURES 

Conduct an initial assessment of your organization’s existing security measures and policies to identify any gaps in meeting NIST 800-171 and CMMC requirements. 

APPOINT A CMMC TEAM 

Designate a team within your organization responsible for overseeing and managing the CMMC compliance process. Ensure that team members receive adequate training. 

PHASE 2: INITIAL COMPLIANCE ACTION ITEMS  

The Cybersecurity Maturity Model Certification (CMMC) is a critical framework for organizations working with the Department of Defense (DoD) to protect sensitive information. Achieving CMMC compliance is essential for winning DoD contracts and ensuring the security of controlled unclassified information (CUI). To help you get started on your CMMC compliance journey, here are the seven essential tasks to tackle: 

TRAINING: CONTRACTUAL REQUIREMENTS – IDENTIFYING REQUIREMENTS & ACTIONS TO BE TAKEN 

Understanding the specific CMMC requirements outlined in your DoD contracts is the first step. Identify the contractual obligations related to CMMC compliance and any requested actions you need to take. This may include determining the CMMC level required for your organization and adhering to the following regulations: 

• FAR 52.204-21: Requires suppliers’ compliance at the time of award with a select subset of NIST SP 800-171 “basic safeguarding” Cybersecurity controls for internal systems with “federal contract information.” 

• DFARS 252.204-7008: Compliance with Safeguarding Covered Defense Information Controls. 

• DFARS 252.204-7012: Requires suppliers’ implementation of NIST SP 800-171, including Cybersecurity controls for internal systems with “covered defense information” (CDI). To have implemented NIST SP 800-171 for purposes of this DFARS clause, companies must have performed a self-assessment of their covered systems, completed a System Security Plan (SSP), and, as applicable, a Plan of Actions and Milestones (POAM), and obtained the DIBNET incident reporting medium level of assurance hardware certificate. 

• DFARS 252.204-7019 and DFARS 252.204-7020: Requires the implementation of NIST SP 800-171 in accordance with DFARS 252.204-7020. Prior to award, suppliers must conduct a basic self-assessment of the 110 NIST 800-171 controls for each information system that will handle Covered Defense Information (CDI) and submit resulting scores and documentation to the Department of Defense (DoD) Website “Supplier Performance Rating System (SPRS).” 

SYSTEM SECURITY PLAN (SSP) 

Develop a comprehensive System Security Plan (SSP) that outlines your organization’s security measures, policies, and procedures. The SSP is a critical document that provides a roadmap for implementing security controls and is often required for CMMC assessments. 

PLAN OF ACTION & MILESTONES (POAM) 

Create a Plan of Action & Milestones (POAM) to address any security weaknesses or non-compliance issues identified during your self-assessment or CMMC assessment. A well-documented POAM demonstrates your commitment to rectifying vulnerabilities and achieving compliance. 

SUPPLIER PERFORMANCE RISK SYSTEM (SPRS) 

Register in the Supplier Performance Risk System (SPRS), which is part of the Defense Information System for Security (DISS). SPRS assesses and records supplier performance, including their compliance with CMMC requirements. It’s crucial to maintain a good standing in SPRS to continue doing business with the DoD. 

MEDIUM LEVEL OF ASSURANCE (MLOA) CERTIFICATE 

Obtaining an MLOA certificate is vital for CMMC Level 3 compliance. It serves as evidence that your organization has achieved the necessary security controls and practices to protect CUI. The MLOA certificate demonstrates your commitment to securing sensitive information. 

DIB NET REGISTRATION 

The Defense Industrial Base (DIB) Network registration is necessary for organizations involved in the defense industry. Registering on DIB Net provides you with access to valuable resources and information related to CMMC compliance and DoD contracts. 

TRAINING: CONTROLLED UNCLASSIFIED INFORMATION PROTECTION PROGRAM (CUIPP) 

Ensure that your employees are trained in the Controlled Unclassified Information Protection Program (CUIPP). This program equips your team with the knowledge and skills needed to safeguard CUI and comply with CMMC requirements effectively. 

In summary, achieving CMMC compliance is a complex process, but breaking it down into these seven essential tasks can make it more manageable. Start by understanding your contractual obligations, creating essential documents like the SSP and POAM, and obtaining the necessary certificates. Register on DIB Net and ensure your team is well-trained in CUIPP. By taking these steps, you’ll be well on your way to meeting CMMC compliance requirements and securing your place in the defense supply chain. 

PHASE 3: LEVEL 1 CONTROLS – BASIC SAFEGUARDING 

UNDERSTANDING LEVEL 1 CONTROLS 

At the core, Level 1 Controls represent the foundational security measures that organizations must implement to safeguard FCI. These controls are defined by the FAR 52.204-21 clause and are designed to provide a basic level of protection against common cybersecurity threats. 

The Key Components of the Level 1 Controls encompass a range of essential security practices, including: 

1. Access Control: Managing who has access to systems and data by using user authentication and password policies. 

2. Awareness and Training: Ensuring that employees are aware of their roles and responsibilities regarding information security. 

3. Audit and Accountability: Monitoring and recording security-related events for investigation and analysis. 

4. Configuration Management: Keeping hardware, software, and documentation up to date, secure, and properly configured. 

5. Identification and Authentication: Verifying the identity of users and systems accessing information. 

6. Incident Response: Developing and implementing an incident response plan to address and mitigate security incidents. 

7. Security Assessment and Authorization: Conducting regular assessments and obtaining authorization to operate systems. 

8. System and Communications Protection: Safeguarding communications and data by implementing security controls. 

SIGNIFICANCE OF LEVEL 1 CONTROLS 

Level 1 Controls are not only important for compliance but also for ensuring the security of sensitive government information. They establish a baseline level of protection that is crucial for all organizations doing business with the federal government. 

By adhering to these controls, organizations are not only meeting regulatory requirements but also enhancing their overall cybersecurity posture. In an age where cyber threats are ever-present, implementing these fundamental safeguards is a critical step towards protecting data and ensuring the integrity of the supply chain. 

CONCLUSION 

In Phase 3 of our CMMC compliance journey, we explore Level 1 Controls, or Basic Safeguarding, as mandated by FAR 52.204-21. These controls represent the foundational steps that organizations must take to protect federal contract information (FCI) and controlled unclassified information (CUI). By understanding and implementing these controls, organizations not only meet compliance requirements but also strengthen their cybersecurity defenses, safeguarding the sensitive information entrusted to them. Phase 3 marks a significant milestone in our commitment to cybersecurity excellence, ensuring that our operations align with the highest standards of security and compliance. 

PHASE 4: LEVEL 2 CONTROLS – PROTECTION OF CUI PER DFARS 

As we continue our journey towards achieving compliance with the Cybersecurity Maturity Model Certification (CMMC), we enter Phase 4, where we focus on Level 2 Controls as defined by the Defense Federal Acquisition Regulation Supplement (DFARS). In this phase, the emphasis shifts from foundational security measures to more advanced controls. Let’s explore what Phase 4 entails and the significance of Level 2 Controls. 

UNDERSTANDING LEVEL 2 CONTROLS 

Level 2 Controls are a significant step up in the security requirements that organizations must meet to handle Controlled Unclassified Information (CUI) effectively. These controls are outlined in the Defense Federal Acquisition Regulation Supplement (DFARS) and are critical for organizations engaged in contracts involving the U.S. Department of Defense (DoD). 

THE KEY COMPONENTS OF LEVEL 2 CONTROLS ENCOMPASS A RANGE OF ADVANCED SECURITY PRACTICES, INCLUDING: 

1. Access Control: Strengthening access controls through advanced authentication and authorization mechanisms, such as multi-factor authentication. 

2. Audit and Accountability: Expanding auditing and monitoring capabilities to enhance detection and response to security incidents. 

3. System and Communications Protection: Implementing more robust security measures to safeguard data in transit and at rest. 

4. Security Assessment and Authorization: Conducting in-depth security assessments and obtaining formal authorization to operate (ATO) from the DoD. 

5. Configuration Management: Managing and controlling system configurations to a higher standard, including secure baseline configurations. 

6. Incident Response: Enhancing incident response capabilities and coordination with the DoD for threat intelligence sharing. 

SIGNIFICANCE OF LEVEL 2 CONTROLS 

Level 2 Controls represent a critical evolution in an organization’s cybersecurity posture. They are designed to address the growing complexity and sophistication of cyber threats in the modern digital landscape. These controls not only safeguard sensitive information but also ensure the integrity and availability of critical systems. 

Compliance with Level 2 Controls is a testament to an organization’s commitment to cybersecurity excellence. It signifies the ability to manage, secure, and respond to advanced cyber threats effectively. For organizations engaged in DoD contracts and entrusted with sensitive defense information, Level 2 Controls are a vital part of maintaining the integrity of the defense supply chain. 

CONCLUSION 

In Phase 4 of our CMMC compliance journey, we delve into Level 2 Controls as outlined by DFARS. These controls represent an advanced level of security measures required to handle Controlled Unclassified Information (CUI) effectively. By understanding and implementing these controls, organizations demonstrate their readiness to face the evolving and sophisticated cybersecurity challenges in the defense industry. 

Phase 4 marks a significant milestone in our commitment to cybersecurity excellence, ensuring that our operations are aligned with the highest standards of security and compliance set forth by the U.S. Department of Defense. It is a testament to our dedication to safeguarding critical information, systems, and contributing to the security of our nation. 

PHASE 5: TRAINING AND CMMC AUDIT READINESS PREPARATION 

As we progress further in our journey toward achieving Cybersecurity Maturity Model Certification (CMMC) compliance, we arrive at Phase 5: Training and CMMC Audit Readiness Preparation. This pivotal phase places a strong emphasis on ensuring that your organization is not only compliant but also audit-ready, poised to meet the upcoming CMMC compliance deadline. Let’s explore the key elements of Phase 5 and understand its significance. 

PREPARING FOR CMMC COMPLIANCE DEADLINE 

The CMMC compliance deadline looms on the horizon, and Phase 5 is all about getting your organization ready for the final audit. The objective here is to ensure that you meet the CMMC level required by your contracts with the Department of Defense (DoD). The audit readiness preparation process involves several key components: 

1. Employee Training: It is essential to ensure that your staff is well-versed in CMMC requirements and best practices. This includes understanding the security controls, identifying and reporting incidents, and adhering to the CMMC framework. 

2. CMMC Audit Preparation: Training your team on what to expect during a CMMC audit, including how to interact with auditors, present evidence of compliance, and respond to inquiries effectively. 

3. Review of Compliance Documents: Ensure that all required documents, including your System Security Plan (SSP) and Plan of Action & Milestones (POAM), are up to date and accurately reflect your compliance efforts. 

4. Conduct Mock Audits: Mimic the audit process by having a third-party auditor or an internal team perform a mock audit. This helps identify any potential issues and allows you to address them before the official audit. 

5. Incident Response Drills: Test your incident response procedures to ensure that your team can handle and report security incidents according to CMMC requirements. 

SIGNIFICANCE OF PHASE 5 

Phase 5 holds great importance, as it ensures that your organization is well-prepared for the CMMC audit. Being audit-ready not only facilitates a smoother audit process but also demonstrates your commitment to data security and CMMC compliance. Meeting the CMMC compliance deadline is not just a legal requirement; it is a testament to your dedication to securing controlled unclassified information (CUI) and contributing to national security. 

HOW TGC SERVICES CAN HELP – REQUEST YOUR FREE EVALUATION 

As the CMMC compliance deadline steadily approaches, proactive preparations are essential to ensure a smooth and successful journey. At TGC Services, we are acutely aware of the challenges that organizations encounter as they navigate the intricate landscape of CMMC compliance. This is precisely why we offer complimentary Assessments and Penetration Testing, enabling you to assess your current state of readiness and pinpoint potential vulnerabilities. 

What sets us apart is our affiliation with the esteemed Cyber-AB (Cybersecurity Accreditation Body), underscoring our commitment to excellence in the cybersecurity domain. Many of our Engineers and Technicians proudly hold the distinction of being Cyber-AB Registered Practitioners, which reflects their dedication to staying at the forefront of cybersecurity practices and standards. 

Our TGC Team stands ready to guide you in achieving your CMMC goals. With their expertise, training, and unwavering support, we ensure that your organization is fully prepared for the impending CMMC audit. The importance of taking action now cannot be overstated; waiting until the last moment is a risk that can be avoided. 

Reach out to us today, and allow us to be your trusted partner on the path to a secure and audit-ready future. With our proven capabilities and a team of Cyber-AB Registered Practitioners, we are poised to assist you in not just meeting CMMC compliance but in surpassing it with confidence and resilience.