The Department of Defense (DoD) recently finalized the 32 CFR Final Rule, which significantly alters the compliance landscape for Managed Service Providers (MSPs) operating within the Defense Industrial Base (DIB). This rule is particularly relevant for MSPs that work with contractors in the defense sector and must now navigate a new set of compliance and security assessment requirements.
In this article, we will explore the key takeaways from our recent conversation on the impact of the 32 CFR final rule, particularly focusing on the implications for MSPs, the role of consultants, and the need for comprehensive gap assessments.
Takeaways:
– MSPs must be assessed rather than certified under the new 32 CFR ruling.
– Consultants are key to preparing MSPs for successful assessments.
– Gap assessments help identify readiness for compliance and reduce risk.
– Inheritance allows MSPs to leverage existing certifications, streamlining their assessments.
– Transparency, proactive communication, and efficient preparation are critical for successful assessments.
Key Changes in the 32 CFR Final Rule
The 32 CFR ruling greatly affects how MSPs engage with the Cybersecurity Maturity Model Certification (CMMC). One of the major shifts is that MSPs will no longer be required to be certified to a certain level, but rather, they must undergo assessments with their clients’ seeking assessments. At first, it seemed positive that requirement was not forced upon MSPs assisting their clients, but now their processes and controls will be in scope of EVERY client assessment.
So, hear what we’re saying, it’s still a big deal to have your stuff together.
1. Shift from Certification to Assessment
Traditionally, MSPs in the defense sector were required to obtain a certification equal to or higher than their client’s, indicating they met certain security standards equal to their client seeking assessment. Under the new rule, however, MSPs must now be assessed under their OSA’s assessment scope rather than being certified at a particular level. This means that MSPs must demonstrate their security posture and practices through a comprehensive assessment process, ensuring they meet the necessary CMMC standards for their role.
Why this matters: The change from certification to assessment ensures a more dynamic approach to compliance. It focuses on ongoing monitoring and assessment of practices, rather than a one-time certification. This change emphasizes the importance of MSPs in the DIB space and how critical their connection is to their clients.
2. Inheritance: Leveraging Existing Certifications
Another important concept introduced by the 32 CFR Final Rule is the idea of inheritance in assessments. This allows businesses to leverage the security certifications of their MSP, reducing the burden, time, and potentially even cost of an assessment. Essentially, if an MSP has already passed an assessment and received a certification, OSA can inherit certain controls from those partners, streamlining their own assessment process.
Why this matters: Inheritance can significantly reduce the time and cost associated with compliance. MSPs should work closely with their clients and partners to understand how inheritance works and ensure they are taking full advantage of it to simplify the OSA’s assessments.
3. MSP Assessment Preparation
As MSPs adjust to these new requirements, it becomes clear that preparation is key. Consultants, especially those experienced in CMMC compliance like a C3PAO or Certified CMMC Assessor, will play a critical role in guiding MSPs through the assessment preparation process. They can help MSPs identify areas of weakness in their security frameworks, ensure they understand the assessment criteria, and assist in addressing any gaps before the formal assessment takes place.
The thing to remember is: If a C3PAO gives you consulting, that same C3PAO is not allowed, by law, to do your assessment. You must find another C3PAO to do the certification assessment.
Why this matters: Having the right consultants involved early on can save MSPs significant time and resources in the long run. They help streamline the compliance process, ensuring that MSPs are ready for the assessment and minimizing the risk of non-compliance.
The Importance of Gap Assessments
Gap assessments are becoming an essential tool for both MSPs and contractors in the DIB sector. These assessments help organizations identify any compliance gaps before undergoing the formal CMMC assessment. By conducting a gap assessment, MSPs can pinpoint weaknesses in their cybersecurity practices and address them proactively, rather than risking non-compliance or failing the formal assessment.
Why this matters: Gap assessments not only help MSPs prepare for the assessment itself, but they also provide an opportunity to improve overall security practices. Regular gap assessments are a proactive way to stay ahead of evolving cybersecurity requirements and reduce the likelihood of security incidents that could harm both the MSP and their clients.
Proactive Steps for MSPs
To ensure they are fully prepared for the 32 CFR assessments, MSPs should take several key steps:
– Be proactive: Understand your clients’ needs and security requirements and take steps to address any potential vulnerabilities before they become compliance issues.
– Engage consultants: Work with experienced consultants who can help you understand the nuances of the new assessment requirements and ensure you’re fully prepared.
– Conduct regular gap assessments: This will help you stay on top of your compliance status and identify areas for improvement.
– Ensure transparency: Open and honest communication with clients, partners, and assessors will help streamline the assessment process and build trust.
– Leverage inheritance: Take advantage of existing certifications and security practices from partners to streamline your own assessments.
The Bottom Line: MSPs Must Prioritize Compliance and Security
The 32 CFR Final Rule represents a significant shift in the way MSPs must approach cybersecurity compliance in the defense sector. It places a greater emphasis on continuous assessment rather than static certification, which requires MSPs to be more proactive in maintaining high standards of security. By embracing the new assessment process, conducting gap assessments, and leveraging partnerships for inheritance, MSPs can stay ahead of the curve and ensure they meet the stringent requirements of the CMMC system for their clients.
Ultimately, MSPs must take a proactive, transparent, and committed approach to cybersecurity in order to succeed under the new regulations. As the DoD continues to evolve its cybersecurity standards, MSPs must remain agile and prepared to adjust to any future changes. By doing so, they can position themselves as trusted partners in the defense industry, ensuring they are ready to meet the demands of both the DoD and their clients.
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