Are you a DoD supplier/contractor or a Defense Industrial Base (DIB) member? You must have heard of the Cybersecurity Maturity Model Certification (CMMC) Framework by now. This framework is aligned with DoD’s information security requirements for DIB partners. CMMC is designed to enforce the protection of CUI information the Department shares with its contractors and subcontractors. To determine their maturity status, for CMMC Level 2 or 3, contractors must undergo a C3PAO certification assessment. Achieving compliance with this framework is not only challenging but also complex.
However, OSCs have several tricks up their sleeves to make the process a little bit less daunting and cheaper. One of these tricks is limiting the CMMC assessment scope, and cybersecurity companies like Cleared Systems can significantly help.
What Is a CMMC Compliance Scope?
A CMMC scope defines the boundaries around which assets must meet the compliance requirements or will be assessed and those out-of-scope. OSCs are required to submit their assessment scope to the C3PAO assessment team in the Planning and Preparation phase of the CMMC Assessment Process (CAP). Scoping determines the boundaries where CUI and FCI are stored, processed, and transmitted within the DoD contractor’s environment.
Unless scoping is done accurately, the OSC’s entire network and business functions may be in scope for a CMMC assessment. This may result in prohibitively expensive costs to protect the entire OSC’s IT environment. However, you must ensure that all assets that store, process, or transmit CUI are included in the assessment scope to avert a likely violation scenario.
Why Does Limiting Assessment Scope Matter?
As mentioned above, achieving and maintaining CMMC compliance in a broad scope is prohibitively expensive. So, why is limiting the compliance scope essential?
- It reduces complexity: By narrowing the scope to specific systems and processes handling FCI or CUI, OSCs can make their compliance efforts. This streamlined approach helps focus resources and reduces the burden of managing extensive security controls across unnecessary areas.
- Lowers costs: Limiting the CMMC assessment scope means fewer systems and processes must be assessed, secured, and maintained. Thus, expenses related to audits, documentation, and ongoing security measures are reduced.
- It enhances security: A focused, limited scope allows OSCs to implement and monitor security controls more effectively. This results in better protection of CUI since efforts are concentrated on high-risk areas rather than being spread thin.
- It improves audit readiness: A well-defined assessment scope ensures OSCs are better prepared for upcoming CMMC assessments. The assessment team can more easily evaluate compliance within a limited scope, which makes the certification process smoother and more efficient.
- Limited scope facilitates scalability: OSCs can start with a limited scope, achieve compliance, then gradually expand their efforts as needed. Such a phased approach allows for better management of resources and continuous improvement of cybersecurity practices.
Ways of Limiting a CMMC Assessment Scope
Cleared Systems takes two main approaches to reducing a CMMC assessment scope: encryption or establishing CUI enclaves. Either can help an OSC achieve the benefits above.
Limiting CMMC Assessment Scope Using Encryption
Message and network encryption are key in determining what is in scope out of the scope of a CMMC assessment. For instance, if you send or receive CUI via email, that information is routed from one network to another. Since emails are normally unencrypted, if the message is logged in a file in the routing process, it might be viewed by an unauthorized party.
The simple fact that it is unencrypted places the entire email system in scope. Unfortunately, that is a non-compliant solution. If encrypted by the sender and decrypted at the receiver, only the cyphertext is transmitted. Even if it fell on the wrong hand, the message would be inaccessible unless the party had the decryption protocols and keys. Since cyphertext is not CUI, the assessment scope is limited to the encryption module and the endpoint. This analogy works anywhere CUI is transmitted.
OSCs can considerably limit assessment scopes by encrypting data using compliant modules and secure communications such as SSL and TLS. Encryption ensures the confidentiality of CUI whenever transmitted or stored. Experts at Cleared Systems understand the CMMC requirements on encryption (SC.L2-3.13.11) and have helped many OSC’s scoping efforts using this approach. All their encryption modules are FIPS Validated. They can also institute measures like digital signatures to ensure non-repudiation of CUI.
Limiting Assessment Scope Using CMMC Enclaves
Another way to reduce the scope of an assessment is by establishing a CMMC enclave. But what is an enclave? The CyberAB’s CMMC Assessment Process (CAP) defines an enclave as “a set of system resources that operate with the same security domain and share the protection of a single, common, and continuous security perimeter. A segmentation of an organization’s network or data intended to ‘wall off’ that network or database from all other networks or systems.” Enclaves are created by separating different kinds of data, such as CUI, from an organization’s internal data into different systems or subsystems, otherwise called “Data Segmentation.”
Setting up an FCI or CUI enclave considerably reduces an OSC’s Assessment Scope. It limits the CMMC assessment to the assets in the enclave, be it CUI, Specialized, Contractor Risk Managed, or Security Protection. The CUI or FCI is moved into the enclave, leaving your internal data wherever it is. Unlike standalone systems or fully isolated networks, enclaves can still interact with other outside systems.
Although building enclaves is highly complex, CMMC compliance experts at Cleared Systems have perfected the art. They can design and develop a highly customized CUI enclave in your wider environment to limit the Assessment Scope. Our implementation leaves you several avenues to access the enclave through an app, over the web interface, or a Remote Desktop Session through encrypted VPNs. The experts comprehensively document all the assets inside the enclave to make the scope validation process by the C3PAO more straightforward.
Leveraging CMMC enclaves, your environment will have a smaller compliance footprint since there are fewer endpoints to assess, protect, and manage. Consequently, your technology costs and implementation time are significantly reduced. Only the employees authorized to handle CUI have access. Hence, you will only have to train and manage those employees in the required compliance protocols, also saving you both money and time. By limiting the assessment scope, enclaves make achieving compliance easier, cheaper, and faster.
Ways of Limiting a CMMC Assessment Scope
Cleared Systems takes two main approaches to reducing a CMMC assessment scope: encryption or establishing CUI enclaves. Either can help an OSC achieve the benefits above.
Limiting CMMC Assessment Scope Using Encryption
Message and network encryption are key in determining what is in scope out of the scope of a CMMC assessment. For instance, if you send or receive CUI via email, that information is routed from one network to another. Since emails are normally unencrypted, if the message is logged in a file in the routing process, it might be viewed by an unauthorized party. The simple fact that it is unencrypted places the entire email system in scope.
Unfortunately, that is a non-compliant solution. If encrypted by the sender and decrypted at the receiver, only the cyphertext is transmitted. Even if it fell on the wrong hand, the message would be inaccessible unless the party had the decryption protocols and keys. Since cyphertext is not CUI, the assessment scope is limited to the encryption module and the endpoint. This analogy works anywhere CUI is transmitted.
OSCs can considerably limit assessment scopes by encrypting data using compliant modules and secure communications such as SSL and TLS. Encryption ensures the confidentiality of CUI whenever transmitted or stored. Experts at Cleared Systems understand the CMMC requirements on encryption (SC.L2-3.13.11) and have helped many OSC’s scoping efforts using this approach. All their encryption modules are FIPS Validated. They can also institute measures like digital signatures to ensure non-repudiation of CUI.
Limiting Assessment Scope Using CMMC Enclaves
Another way to reduce the scope of an assessment is by establishing a CMMC enclave. But what is an enclave? The CyberAB’s CMMC Assessment Process (CAP) defines an enclave as “a set of system resources that operate with the same security domain and share the protection of a single, common, and continuous security perimeter. A segmentation of an organization’s network or data intended to ‘wall off’ that network or database from all other networks or systems.” Enclaves are created by separating different kinds of data, such as CUI, from an organization’s internal data into different systems or subsystems, otherwise called “Data Segmentation.”
Setting up an FCI or CUI enclave considerably reduces an OSC’s Assessment Scope. It limits the CMMC assessment to the assets in the enclave, be it CUI, Specialized, Contractor Risk Managed, or Security Protection. The CUI or FCI is moved into the enclave, leaving your internal data wherever it is. Unlike standalone systems or fully isolated networks, enclaves can still interact with other outside systems.
Although building enclaves is highly complex, CMMC compliance experts at Cleared Systems have perfected the art. They can design and develop a highly customized CUI enclave in your wider environment to limit the Assessment Scope. Our implementation leaves you several avenues to access the enclave through an app, over the web interface, or a Remote Desktop Session through encrypted VPNs. The experts comprehensively document all the assets inside the enclave to make the scope validation process by the C3PAO more straightforward.
Leveraging CMMC enclaves, your environment will have a smaller compliance footprint since there are fewer endpoints to assess, protect, and manage. Consequently, your technology costs and implementation time are significantly reduced. Only the employees authorized to handle CUI have access. Hence, you will only have to train and manage those employees in the required compliance protocols, also saving you both money and time. By limiting the assessment scope, enclaves make achieving compliance easier, cheaper, and faster.
Limit Your Assessment Scope With Cleared Systems
Limiting the CMMC assessment scope is essential for reducing complexity and costs, enhancing security, improving audit readiness, and facilitating scalability. Encryption and establishing CMMC enclaves can significantly narrow your assessment scope, making compliance easier and more cost-effective. Cleared Systems specializes in these approaches, ensuring your organization meets all requirements while optimizing resources.
Ready to simplify your CMMC compliance journey? Partner with Cleared Systems to leverage expert solutions tailored to your needs. Contact us today to learn how we can help you limit your assessment scope and achieve CMMC compliance efficiently.