Ah, the Paradox of Choice, a concept defined by Barry Schwartz in his 2004 book by the same title. In a nutshell, with each choice there’s expected utility, then following the experience there’s remembered utility. The more expectation aligns with experience, the greater the satisfaction.
Expectations for small businesses often don’t line up with experience when tackling CMMC solutions. It’s like assembling a puzzle with pieces that don’t quite fit, or sometimes it feels they’re pieces from a different puzzle altogether.
Leadership sometimes overestimates these solutions, believing they’ll do more to solve their compliance problems. Instead, they end up with a mix of tools that don’t integrate well. Each tool comes with its own cost and a steep learning curve, which takes additional time and attention from other priorities. Overlapping features can clash, turning a straightforward task into a complex challenge. What’s more, many solutions that promise to be comprehensive often fall short, leaving businesses wondering what went wrong.
Sound familiar?
What’s in a Name?
We’ve coined the CMMC Incomplete Solution Paradox to mean the dilemma where solutions designed to meet CMMC requirements are themselves incomplete, insufficient, or simply not compliant, leading to a cycle of non-compliance and increased cost and risk.
We should also clarify that CMMC is the assessment protocol for the NIST SP 800-171r2 framework, so wherever CMMC is mentioned, it equally refers to the NIST framework.
Here we’ll explore nine solutions that address only parts of the CMMC requirements, leaving gaps that must be filled with alternative solutions or are otherwise navigated.
Piecemeal Solutions
GRC Platforms:
Governance, Risk, and Compliance (GRC) platforms primarily provide compliance evidence and artifacts. They often assist in defining the Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) boundaries and may offer pre-planned self-help questions and might include generic policies, procedures, and plans. Generally presented as a “pane of glass” that is used as an information display, they typically only show compliance progress of controls being met by other technical solutions and can lack comprehensive integration with necessary cybersecurity tools.
SOC/SIEMs:
Security Operations Centers (SOC) and Security Information and Event Management (SIEM) systems focus on auditing, logging, and active threat mitigation. While essential, they do not cover the full spectrum of CMMC requirements, such as policy development, compliance documentation or physical access control. Integrating log reporting into a useful and cohesive portion of compliance is challenging, and only meets a small segment of CMMC controls.
FedRAMP Cloud Solutions:
Federal Risk and Authorization Management Program (FedRAMP) solutions must be configured correctly by the cloud service provider’s software to ensure compliance. Some software providers may house their software in a FedRAMP environment, but the configuration of what they provide doesn’t meet the FedRAMP or CMMC requirements. Small businesses must also ensure their activities align with these configurations while in many cases working outside of the environment, like needing G-code transferred to CNC machines, or other file sharing requirements, adding another layer of complexity in a hybrid network.
Secure Email and File Sharing:
Even when stored in a FedRAMP-authorized environment, a secure email and file sharing software provider must also configure its solution in parallel to meet FedRAMP requirements. The risk is that even when companies store their software in FedRAMP servers, their software and their company may not meet FedRAMP or CMMC requirements. Additionally, all CUI must be contained within these systems to prevent leakage, strictly maintaining data within the compliant confines, which can be challenging to manage.
Endpoint Detection and Response (EDR) Tools:
EDR tools are excellent at detecting and responding to threats on endpoints. However, they often do not address broader compliance requirements such as policy management, user training, and documentation. Further, these tools may not integrate seamlessly with other cybersecurity tools, leading to fragmented security efforts.
Identity and Access Management (IAM) Solutions:
IAM solutions are crucial for managing user identities and access controls. However, they likewise do not cover other CMMC requirements such as continuous monitoring and incident response. While IAM solutions can enforce access policies, they require comprehensive written policy development and compliance documentation
Vulnerability Management Tools:
These tools are effective at identifying and prioritizing vulnerabilities. However, they do not typically address the remediation process or the broader compliance requirements of CMMC. Vulnerability management tools usually focus on specific areas, leaving gaps in overall security posture.
Data Loss Prevention (DLP) Solutions:
DLP solutions are designed to prevent data leakage and ensure that sensitive information is not shared outside the organization. However, they do not cover other aspects of CMMC such as user training and policy management. Proper configuration of DLP solutions is essential for effectiveness, but small businesses may lack the expertise to ensure these configurations are correct.
Patch Management Systems:
Patch management systems automate the process of applying updates and patches to software. However, they do not address other CMMC requirements such as incident response and continuous monitoring. These systems may not integrate well with other cybersecurity tools, and may even deliver false positives from EDR tools, leading to fragmented security efforts.
What Does it All Mean?
Imagine trying to complete a jigsaw puzzle with pieces from different sets—frustrating, right? That’s the essence of the Incomplete Solution Paradox for small businesses tackling CMMC compliance. Each tool or service is like a puzzle piece that fits only part of the picture, leaving gaps that need creative navigation. This piecemeal approach can turn compliance into a fragmented adventure, adding layers of complexity and a dash of chaos to the mix. Small businesses must become master puzzle solvers to piece together a coherent compliance strategy from this scattered assortment
What’s the Solution?
So glad you asked…
FNI has a holistic approach to assisting our clients in meeting CMMC compliance. It’s not an “Easy Button”, but it is comprehensive and based on our CORE enclave.
Make a one-on-one appointment with us to learn how to streamline CMMC. Depending on your situation, FNI has a 4-to-6-month compliance track to meet CMMC.