Right Hand Technology Group’s Office Hours Recap: Key Insights from a CMMC Assessor

On September 12th, 2024, Right Hand Technology Group hosted another insightful Office Hours session featuring Matt Gilbert, a CMMC Assessor from Baker Tilly. This session provided clients with valuable information on navigating the Cybersecurity Maturity Model Certification (CMMC) process, including updates, practical tips, and real-world scenarios. Here’s a recap for those who couldn’t attend.

Key Discussion Points and Updates

1.New CMMC Rule Concerns and Proposed Adjustments

Matt Gilbert highlighted the recently proposed CMMC rules that aim to clarify contract requirements for different CMMC levels. However, there is concern about the lack of flexibility these rules provide to contracting officers. Matt discussed how contracts involving both high-risk CUI (Controlled Unclassified Information) and low-risk tasks like janitorial services might end up requiring all subcontractors, even those handling low-risk tasks, to obtain Level 2 certification. He suggested that this could increase the burden on small contractors and limit participation, especially in services unrelated to CUI.

2.Understanding Unique IDs and Contract Boundaries

A new feature mentioned in the proposed rule is the introduction of a Unique Identifier (UID) for certified systems. This UID will be linked to the systems that handle CUI and must be provided during contract bidding. Matt explained that once an organization registers and gets certified, that UID becomes essential for tracking compliance throughout the contract’s lifecycle. However, he noted concerns over what constitutes a “significant” system change, such as moving from one cloud provider to another, and whether such changes would necessitate recertification.

3. Handling Parent and Subsidiary Companies with Shared Systems

When discussing companies with shared IT systems between a parent and subsidiary, Matt explained that if a parent company handles any CUI or security protection data on behalf of the subsidiary, they would be considered an External Service Provider (ESP) and

must be CMMC certified. He warned of potential timing challenges if certifications need to be obtained in sequence, creating a “domino effect” where the parent must be certified before the subsidiary can begin its own certification process.

4. Managing External Service Providers and Outsourced IT

A frequent question in the session was whether outsourced IT providers need to be CMMC certified. Matt clarified that if an IT provider takes possession of CUI or security protection data, they qualify as an ESP and must be certified. However, if the IT provider is simply managing on-premise systems without accessing CUI directly, they may not need certification. He emphasized that each scenario should be carefully scrutinized to ensure compliance.

5. Impact on Small Business Participation

One of the pressing concerns raised was the potential burden the CMMC requirements could place on small businesses. With certification costs possibly exceeding profits for certain contracts, some small businesses may opt out of bidding on DoD contracts altogether. Matt pointed out that this could result in less competition and might favor larger defense contractors. Despite the cost burden, he emphasized the importance of protecting critical information and that proper compensation should be provided for ensuring compliance.

6. Addressing VoIP and Virtual Meetings

When asked about VoIP (Voice over IP) and virtual meetings like those conducted via Teams, Matt noted that discussions involving CUI must be protected with appropriate encryption. He recommended ensuring that VoIP systems are segmented from networks handling CUI and that users follow acceptable use policies (AUPs) to avoid sharing sensitive data over non-secure channels. Additionally, any tools that interact with meetings, such as AI note-takers, should be vetted to ensure they meet compliance standards.

Tips for Ensuring CMMC Success

Start Early with Certifications: If you share systems with a parent or external provider, ensure those parties are certified first to avoid delays.

Regular Affirmations: Even though certifications last three years, consider reassessing annually, especially after major system changes, to avoid unnecessary compliance risks.

Scrutinize ESP Agreements: If using third-party IT services, ensure they meet the definition of an ESP and understand what qualifies them as in-scope for CMMC.

Keep Data Boundaries Clear: If making changes to your information systems, document them thoroughly to defend whether or not they necessitate recertification.

Looking Ahead

As CMMC continues to evolve, it’s important to stay informed about updates and best practices. Right Hand Technology Group is committed to helping organizations navigate this complex landscape.

Join us for our next Office Hours session!

We host these sessions every month to keep you informed and answer your questions directly. Don’t miss the opportunity to gain valuable insights and guidance from industry experts.