Consulting CMMC

APEX Accelerators (formerly known as Procurement Technical Assistance Centers or PTACs) play a supportive role in helping businesses especially small and medium-sized enterprises navigate the requirements of the Department of Defense's Cybersecurity Maturity Model Certification (CMMC).

While they are not certifying bodies or technical implementation specialists, their responsibilities in aiding clients with CMMC compliance typically include the following:

1. Education and Awareness

• Hosting workshops, webinars, and one-on-one sessions to introduce clients to CMMC requirements.

• Explaining the different CMMC levels and what each requires from a cybersecurity perspective.

• Helping clients understand where CMMC fits into DoD contracting requirements.

2. Pre-Assessment Guidance

• Assisting companies in determining their appropriate CMMC level based on their contract type and data handling (e.g., FCI vs. CUI).

  • Step-by-Step Process

    1. Review Contract Requirements

       • Check solicitation, RFP, or existing DoD contract clauses.

       • Look for indicators like:

         • DFARS 252.204-7012 (usually means CUI is involved → Level 2)

         • FAR 52.204-21 only (likely means just FCI → Level 1)

    2. Determine the Data Type Handled

       • Federal Contract Information (FCI):

         • Not intended for public release

         • Basic administrative data

         • 👉 Requires CMMC Level 1

       • Controlled Unclassified Information (CUI):

         • Technical, export-controlled, or mission-related info

         • Protected under NIST 800-171

         • 👉 Requires CMMC Level 2

    3. Interview Key Stakeholders

       • Ask questions like:

         • Do you process, store, or transmit technical drawings, ITAR data, cybersecurity plans, etc.?

         • Are you a prime or sub on a contract requiring NIST 800-171 compliance?

    4. Review Current Practices

       • Analyze IT systems, subcontractor flows, and document types.

       • Evaluate whether they have System Security Plans (SSPs) or POA&Ms in place.

    5. Document Recommendation

       • Provide a written recommendation stating:

         • Contract(s) analyzed

         • Data types identified (FCI/CUI)

         • Recommended CMMC level

         • Suggested next steps (e.g., gap assessment, remediation)

    Example Summary for Client

    Based on your current subcontract under Contract XYZ with DFARS 252.204-7012, and your handling of engineering specifications and technical manuals, you are required to protect CUI. Therefore, CMMC Level 2 is the appropriate certification target.

• Offering checklists or readiness tools to identify cybersecurity gaps relative to the desired CMMC level.

• Referring businesses to self-assessment resources or maturity model documentation.

CMMC Pre-Assessment Guidance Checklist

3. Strategic Planning Support

• Helping companies develop an action plan to meet CMMC requirements in a cost-effective and phased manner.

• Advising on timelines and budgeting for eventual assessment or certification.

• Connecting businesses to vetted cybersecurity professionals or Registered Provider Organizations (RPOs) for more advanced support.

4. Navigation of Certification Ecosystem

• Helping clients understand the roles of C3PAOs (Certified Third-Party Assessment Organizations), RPOs, and the CMMC Accreditation Body.

• Assisting in locating or connecting with C3PAOs and guiding on what to expect during formal assessments.

5. Ongoing Compliance Assistance

• Providing general support on maintaining compliance over time.

• Offering updates on evolving DoD regulations or CMMC framework modifications.

Limitations:

APEX Accelerators are not cybersecurity implementation experts. They do not perform gap assessments or conduct CMMC audits themselves, nor do they install cybersecurity controls or software. Instead, they act as educators, guides, and connectors within the broader CMMC compliance landscape.

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Free CMMC Level 1 and Level 2 Assessment Tool

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