Practices found in CMMC Levels 1-3 called out an aggregated 130 Practices and 51 Processes that lead to Level 3 compliance. Level 4 specifically includes 26 additional technical practices derived from multiple sources such as NIST 800-171, CERT Resilience, CIS Controls v7.1, and more. See the Practices and Processes below:
Scott Edwards, President of Summit 7 and national security/compliance speaker, spoke on the importance of the Incident Response (IR) Domain and stated "Incident Response is something that I almost want to call the core of CMMC Level 4".
CMMC Level 4 is broken up into a total of 18 Technical Practices and 8 Procedural / Policy Practices. According to acq.osd.mil "Each practice is specified using the convention of [DOMAIN].[LEVEL].[PRACTICE] where:
DOMAIN is the two letter domain abbreviation
LEVEL is the level number
PRACTICE NUMBER is the identifier assigned to that practice"
Access Control (AC):
Asset Management (AM):
Audit and Accountability (AA):
Awareness and Training (AT):
Configuration Management (CM):
Incident Response (IR):
Risk Management (RM):
Security Assessment (CA):
Situational Awareness (SA):
System and Communication Protection (SC):
System and Information Security (SI):
Upon CMMC Level 3 compliance, or the implementation of the appropriate 130 Practices, you'll need to implement the additional 26 shown in the accordion section above.
A few ways to meet new practices and additional resourcing requirements (software, hardware, personnel, outsourcing) are:
For more information on recommendations for remedying these technical practices, watch this clip from the CMMC Level 4 webinar from the Summit 7 Team.
SIEM solutions to meet Incident Response requirements:
Summit 7 Preferred: Microsoft Azure Government Sentinel
Solutions for meeting Incident Response requirements specific to a SOC:
Summit 7 Preferred: Microsoft Azure Sentinel for alerting and Microsoft Cloud Access Security (MCAS) broker for the CASB
Risk Management port scanning solutions:
Summit 7 Preferred: Qualys Vulnerability Management System
Threat indicator and threat hunting subscriptions to meet System and Information Integrity requirements:
Summit 7 Preferred: Microsoft's Azure Sentinel supports input from MISP Project
Summit 7 has architected a solution set to help organizations achieve CMMC Level 4 compliance that is developed for Office 365 GCC High and Azure Government. To discuss with our team and develop your roadmap for Level 4, click the button below.
As the image below details, Level 4 requires organizations to practice "Proactive Cyber Hygiene", while having "reviewed" security processes and methods for "reducing risk of Advanced Persistent Threats (APT)s and increasing protection of CUI". For contractors in the DoD, Level 4 compliance may be more uncommon than Level 3, as it will be contractually required far less in RFPs and is seen as more of a transitional step to Level 5. It is also an increase in responsibility and likely cost. Levels are cumulative, meaning a Level 4 certified organization will need to meet the practices found in Levels 1, 2, 3, and 4. Access a more detailed explanation and overview of CMMC, as well as history and background here.
OUSD A&S and the CMMC-Accreditation Body solidified their partnership, November 25, 2020, in signing a No-Cost contract to support this very important mission for our cybersecurity, information security, and thus national security.
If you still have questions about CMMC Level 4, or anything around understanding the Cybersecurity Maturity Model Certification as a whole please do not hesitate to reach out to us.
Here are some ways you can stay connect to the Summit 7 team and hear the latest and greatest on all things security and compliance: