The Cybersecurity Maturity Model Certification (CMMC) is now a mandatory certification for companies aiming to win Department of Defense (DOD) contracts. The certification comes in three levels, each progressively more demanding in cybersecurity practices and processes. Understanding whether your organization needs Level 1 or Level 2 certification can save you time, reduce stress, and help ensure that you’re prepared. This article breaks down the core differences between CMMC Level 1 and Level 2 and guides you in identifying which certification level you may need.

Overview of CMMC Certification Levels

To keep up with evolving cybersecurity threats, the Department of Defense developed the CMMC Program to provide a standardized approach to protecting Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the defense industrial base. The CMMC 2.0 model is divided into three levels:

• Level 1: Foundational Cyber Hygiene
• Level 2: Advanced Cyber Hygiene
• Level 3: Expert Cyber Hygiene

Each level builds on the requirements of the previous one, with Level 1 serving as a fundamental baseline and Level 2 implementing more comprehensive controls for added security.

Key Differences Between CMMC Level 1 and Level 2

1. Scope of Protection: FCI vs. CUI

• Level 1: If your organization only handles Federal Contract Information (FCI), you’ll likely need Level 1 certification. FCI is information provided by or generated for the government under contract, not intended for public release but also not highly sensitive.
• Level 2: For those working with Controlled Unclassified Information (CUI), Level 2 is required. CUI includes data that requires protection under laws, regulations, and government policies but is not classified.

Key takeaway: If your contracts involve CUI, then Level 2 is mandatory; if you only deal with FCI, Level 1 may suffice.

2. Number and Complexity of Requirements

• Level 1: CMMC Level 1 (Foundational) requires organizations to implement 15 basic cybersecurity practices aimed at safeguarding Federal Contract Information (FCI). These practices, derived from FAR 52.204-21, focus on foundational security measures, such as:
  • Limiting information system access to authorized users
  • Sanitizing information system media before disposal
  • Protecting media both physically and logically
• Level 2: CMMC Level 2 (Advanced) builds upon Level 1 by introducing 110 additional security requirements, aligned with NIST SP 800-171 standards, to secure Controlled Unclassified Information (CUI). Organizations at Level 2 must implement advanced protections, including multifactor authentication, stringent user access controls, and continuous threat monitoring, to enhance security for CUI.

Key takeaway: Level 2 requires substantial additional resources, technical capabilities, and dedicated cybersecurity policies compared to Level 1. If you’re unsure whether you can meet the demands of these requirements, a CMMC consultant can assess your readiness.

3. Assessment Requirements

• Level 1: Level 1 can be self-assessed, allowing smaller organizations to pursue certification without the cost and complexity of an external audit. However, accurate and complete self-assessment is essential to avoid compliance issues.
• Level 2: Level 2 requires a third-party assessment. This involves an in-depth examination conducted by a Certified Third-Party Assessor Organization (C3PAO) to ensure compliance with CMMC standards. This process can take weeks, requiring considerable preparation and detailed documentation.

Key takeaway: If your organization requires Level 2 certification, prepare for third-party audits and ensure all relevant cybersecurity practices are rigorously followed and documented.

4. Investment and Time Commitment

• Level 1: The financial and operational commitment for Level 1 certification is generally lower than Level 2. Implementing Level 1 involves minimal technology upgrades, focusing on basic controls and employee training.
• Level 2: Level 2 certification requires significantly higher investment in both time and resources. Organizations pursuing Level 2 should be prepared to invest in new technology, conduct extensive employee training, and designate staff to oversee compliance. CMMC consultants can streamline this process, providing tailored solutions to save costs and reduce complexity.

Key takeaway: Organizations needing Level 2 should anticipate higher operational costs, especially in areas like personnel training and technology upgrades.

Determining the Right Level for Your Organization

Knowing which CMMC level applies to your organization depends on two factors: the type of information you handle and the requirements specified in your contracts. Here’s a step-by-step approach to help clarify your path:

1. Review Contractual Requirements

Examine any contracts you have with the Department of Defense. If they include a DFARS 204.52.7012 clause and specify the handling of CUI, you’ll likely need Level 2. However, if only FCI is involved, Level 1 should be sufficient.

2. Conduct a Data Classification Assessment

If you’re uncertain whether your data is considered CUI or FCI, conducting a data classification assessment can help clarify this. Consulting services, like those offered by Alluvionic, can provide a thorough analysis to ensure accurate classification.

3. Assess Organizational Maturity and Resources

If your organization already has basic cybersecurity measures in place, achieving Level 1 may be a smoother, shorter process. For those who lack a formal cybersecurity program but must handle CUI, you’ll need to adopt more advanced measures that align with Level 2’s NIST SP 800-171-based requirements.

4. Seek Professional Guidance

Consulting with a CMMC Registered Provider Organization (RPO), such as Alluvionic, offers an advantage in identifying gaps and preparing for certification. Their team will help align your organization’s cybersecurity practices with the level required, minimizing disruption and costs.

Achieving CMMC Compliance: How Alluvionic Can Help

Complying with CMMC requirements can seem daunting, particularly for organizations that may not have dedicated cybersecurity resources. Alluvionic offers tailored compliance solutions for both CMMC Level 1 and Level 2. As an RPO, Alluvionic provides:

• Gap Analyses: Identify any gaps in your cybersecurity practices quickly to develop a compliance strategy.
• Policy and Procedure Development: Ensure your organization meets the technical and administrative requirements for CMMC certification including development of a Plan of Action & Milestones (POA&Ms).
• Readiness Assessments and Training: Prepare your employees with the necessary knowledge to comply with CMMC’s rigorous standards.
• Project Management Support: Our project managers minimize the operational impact by guiding you through each stage of compliance efficiently, ensuring you can focus on core business functions.
• FCI/CUI Scoping: Our cybersecurity compliance assessors will accurately define the boundaries for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within your organization to focus on safeguarding the specific data required by CMMC, reducing compliance scope and resources. At the end of the analysis, you will receive a scoping diagram to keep as an artifact for your assessment.

In Conclusion

Choosing the correct CMMC level is essential for any organization working with the DOD. Level 1 suffices for basic FCI data, while Level 2 is essential if your contracts involve CUI. By understanding the differences and assessing your organization’s needs, you can save resources and time, ensuring the level you pursue is the one required by your contracts. If navigating this complex certification landscape feels overwhelming, Alluvionic’s team is ready to help guide you toward CMMC success. Visit Alluvionic’s CMMC Services to learn more and schedule a consultation today.

About the Author

Sydney Wright is a project management professional with expertise in guiding organizations through complex cybersecurity frameworks such as CMMC and NIST SP 800-171. Leveraging her strong background in communications, she excels at translating intricate cybersecurity concepts into clear, actionable strategies. Passionate about the intersection of technology and effective communication, Sydney is dedicated to fostering collaboration, simplifying compliance, and delivering measurable results.