How Contractors Can Achieve CMMC 2.0 Compliance

Many contractors are discovering significant gaps that are delaying them from achieving CMMC 2.0 compliance since the Department of Defense (DoD) released its final rule. This can be a critical issue for those that are eager to secure new DoD contracts, or to protect their current ones. Here’s what they — and you — need to know about the latest changes to the Cybersecurity Maturity Model Certification.

Key Changes in CMMC 2.0 Compliance

The biggest change to CMMC is its simplified structure, which consolidates five maturity levels into three:

1. Level 1 – Basic safeguarding for Federal Contract Information (FCI), requiring annual self-assessments.
2. Level 2 – Advanced protection for Controlled Unclassified Information (CUI), aligning with NIST SP 800-171. Assessments may be self-conducted or require third-party validation, depending on the sensitivity of the CUI.
3. Level 3 – Enhanced protection against advanced persistent threats, incorporating NIST SP 800-172 controls and requiring assessments by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
   
   

The DoD has outlined a phased implementation schedule.

• Phase 1 starts in early to mid-2025, when self-assessments for Level 1 and some Level 2 requirements will begin.
• Phase 2 will come six months later, along with third-party assessments for certain Level 2 contractors.
• Phase 3 will officially launch eighteen months after Phase 2, as Level 3 assessments roll out.
• Phase 4 will signify full implementation across all relevant contracts, and is expected by 2026.

Contractors Face Unexpected Challenges

Despite the reduced complexity within CMMC 2.0, contractors are finding themselves less prepared than anticipated. These are some of the common issues that they’re encountering.

Misaligned Perceptions of Readiness

Many contractors already assumed that they were compliant with cybersecurity standards like NIST SP 800-171, but have now discovered significant deficiencies during formal assessments. This is often related to insufficient documentation, inadequate monitoring processes, and reliance on outdated practices.

Uncertainty Around CUI

Controlled Unclassified Information remains a stumbling block for many organizations. Identifying and managing it requires clear policies, which several contractors reportedly lack.

Resource Constraints

Small to medium-sized businesses (SMBs) may struggle to obtain the resources they need to implement advanced cybersecurity measures. These resource gaps can leave contractors vulnerable to data breaches and disqualification from DoD contracts.

Reliance on Incomplete Self-Assessments

While self-assessments are permitted for Level 1 and some Level 2 contractors, they often fail to uncover deeper vulnerabilities. Certified Third-Party Assessment Organizations (C3PAOs) can provide this clarity through CMMC assessments, but most of these organizations are already booked for several months into 2025 — further risking noncompliance for those contractors who have yet to schedule with one.

Shift in Compliance Expectations

The transition from the earlier CMMC model to CMMC 2.0 has introduced new requirements and greater accountability, including the need for annual affirmations of cybersecurity status. This shift demands a higher level of readiness and oversight from contractors.

How You Can Meet CMMC 2.0 Compliance

To bridge these gaps, contractors should take proactive steps to strengthen their cybersecurity posture. If you’re in a similar situation, here are the ways you can start to remedy your compliance.

1. Conduct a Gap Analysis: Identify weaknesses in your current compliance efforts and prioritize them based on DoD requirements.
2. Engage Experts: Work with a Registered Provider Organization (RPO) to verify that your cybersecurity measures align with CMMC 2.0’s standards before you contract with a C3PAO for an assessment.
3. Invest in Employee Training: Equip your workforce with the knowledge to handle sensitive information securely.
4. Implement Robust Controls: Ensure that processes for handling CUI and FCI are comprehensive and auditable.
5. Plan for Continuous Improvement: Establish regular reviews and updates to your cybersecurity practices to maintain compliance over time.

How HealthCare Resolution Services Can Help You

HCRS understands the challenges that contractors face in achieving CMMC 2.0 compliance. As an RPO, we are here to help you simplify this process and safeguard your contract eligibility.

Our services include:

• Comprehensive gap analyses to identify vulnerabilities.
• Expert guidance on NIST SP 800-171 and CMMC 2.0 requirements.
• Support for CUI and FCI identification and management.
• Employee training tailored to your organization’s needs.
• Assistance with documentation and assessment preparation.
  
  

Don’t let noncompliance put your organization at risk for lost contracts and potential fines. Contact us today to learn more.