ComplianceIntermediate40 min read

CMMC 2.0 Level 2 Readiness

110 practices with evidence collection templates, CUI handling procedures, and contractor-specific implementation guides.

SBK Security Team
Defense Practice
Updated December 2024

Introduction#

CMMC 2.0 is the Department of Defense's framework for ensuring contractors adequately protect Controlled Unclassified Information (CUI).

Detail Level

Level 2 certification will be required for most defense contractors handling CUI. This guide walks through all 110 practices and provides practical implementation guidance.

CMMC 2.0 Structure#

CMMC 2.0 simplified the model to three levels, each with clear requirements and assessment mechanisms.

Assessment Requirements

Level 2 requires third-party assessment by a CMMC Third-Party Assessment Organization (C3PAO). Self-assessment is only permitted for select contracts.

Level 1: Foundational

17 practices for FCI protection. Self-assessment permitted. Required for contracts with Federal Contract Information only.

Level 2: Advanced

110 practices aligned with NIST SP 800-171. Third-party assessment required. Required for CUI handling.

Level 3: Expert

110+ practices including subset of NIST SP 800-172. Government-led assessment. Required for highest-priority programs.

Scoping Your CUI Environment#

Proper scoping dramatically reduces compliance burden. Smaller scope means fewer systems to protect and assess.

1

Identify CUI Sources

Review contracts for CUI markings and DFARS clauses. Not all government data is CUI—only information marked as such or meeting CUI registry categories.

2

Map Data Flows

Document where CUI enters, is processed, is stored, and exits your organization. Include all systems, applications, and storage locations.

3

Define Boundaries

Create clear boundaries around CUI-handling systems. Consider enclave strategies to minimize scope by isolating CUI into dedicated environments.

4

Document Scope

Create a formal scope document for assessor review. Include network diagrams, data flow diagrams, and asset inventories.

Practice Families Overview#

The 110 Level 2 practices are organized into 14 families aligned with NIST SP 800-171. Each family addresses a specific security domain.

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Implementation Tip

Don't tackle all 14 families simultaneously. Start with Access Control, Identification & Authentication, and Media Protection—these impact scope and enable other controls.
AC: Access Control (22)
AT: Awareness & Training (3)
AU: Audit & Accountability (9)
CM: Configuration Management (9)
IA: Identification & Authentication (11)
IR: Incident Response (3)
MA: Maintenance (6)
MP: Media Protection (9)
PE: Physical Protection (6)
PS: Personnel Security (2)
RA: Risk Assessment (3)
CA: Security Assessment (4)
SC: System & Communications Protection (16)
SI: System & Information Integrity (7)

Critical Practices#

These practices frequently cause assessment failures. Pay special attention to implementation and evidence.

System Security Plan#

The System Security Plan is your primary compliance artifact. It documents how you implement each of the 110 practices.

1

Use DoD Template

Start with the NIST SP 800-171A assessment template or CMMC assessment guide. Assessors expect familiar formats.

2

Be Specific

Describe exactly how you implement each practice in your environment. Generic statements like "we use MFA" are insufficient—specify what systems, which users, and what methods.

3

Link to Evidence

Reference specific evidence artifacts for each practice. This makes assessment walkthroughs efficient and demonstrates thoroughness.

4

Track POA&Ms

Document Plan of Action & Milestones for any incomplete implementations. Assessors may accept POA&Ms for partial credit if remediation timelines are reasonable.

Assessment Preparation#

Prepare thoroughly before engaging a C3PAO. Assessment readiness directly impacts assessment duration and success.

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Common Failure Point

Many organizations fail their first assessment due to inadequate evidence, not inadequate controls. If you can't prove a control exists, it doesn't exist for assessment purposes.

Next Steps#

CMMC compliance requires sustained effort. Start your journey now to be ready when requirements take effect.

1

Gap Assessment

Evaluate your current state against all 110 practices. Use our gap assessment template to identify remediation priorities.

2

Scope Definition

Define your CUI boundary. Consider enclave strategies to minimize scope and reduce compliance burden.

3

SSP Development

Begin documenting your System Security Plan. This is a living document that evolves as you implement controls.

Get Expert Help

Defense compliance has unique requirements. Our team has helped contractors from startups to primes achieve CMMC certification. Schedule a consultation to discuss your assessment timeline.
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