Across CMMC certification and ongoing monitoring and assessment, the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) plays a pivotal role in verifying contractor compliance. Here, we will cover the relationship between DIBCAC and CMMC assessments, providing expert-level guidance for organizations seeking Level 2 or Level 3 certification.
The Role of DIBCAC in the CMMC Ecosystem
The DIBCAC is a specialized unit within DCMA responsible for conducting cybersecurity assessments of defense contractors. Prior to the finalization of the CMMC rule, DIBCAC primarily focused on validating NIST SP 800-171 implementation under DFARS clause 252.204-7012. However, with the formal establishment of the CMMC Program under 32 CFR Part 170, DIBCAC now has a dual function:
- Performing Level 3 Certification Assessments: DIBCAC is the exclusive entity authorized to conduct CMMC Level 3 assessments. These assessments evaluate compliance with enhanced security requirements derived from NIST SP 800-172.
- Validating CMMC Level 2 Certification Assessments: DIBCAC may also verify Level 2 certifications conducted by C3PAOs if necessary or requested by DoD Components.
Understanding CMMC Assessment Levels
The CMMC model is a tiered cybersecurity framework that reflects increasing levels of maturity and threat resilience:
- Level 1 (Foundational): Focuses on safeguarding Federal Contract Information (FCI) through 15 basic security requirements derived from FAR 52.204-21.
- Level 2 (Advanced): Requires implementation of the 110 security requirements from NIST SP 800-171 Rev. 3 and may involve a self-assessment or a C3PAO-led certification assessment, depending on the contract.
- Level 3 (Expert): Designed to protect CUI against APTs using a subset of controls from NIST SP 800-172.
The DIBCAC Assessment Process
DIBCAC assessments follow a strict, predictable methodology that combines examination, interviews, and comprehensive testing to evaluate your cybersecurity posture. Understanding each phase of this process is critical for organizations seeking Level 3 certification.
The assessment unfolds through four distinct phases, each building upon the previous to create a comprehensive evaluation:
- Pre-Assessment Planning: The journey begins with contractors submitting their current System Security Plan (SSP) and, if necessary, a Plan of Action and Milestones (POA&M).
- Scoping and Asset Categorization: This phase requires contractors to clearly define their CMMC Assessment Scope in accordance with 32 CFR 170.19(c). That means identifying all CUI assets, contractor risk-managed assets, and any specialized assets that fall within your boundary.
- Execution Phase: During this active assessment period, DIBCAC assessors conduct either onsite or remote evaluations, depending on the specific assessment objectives outlined. These assessments are comprehensive, examining not only the presence of controls but also their effectiveness and maturity.
- Reporting and SPRS Submission: The process concludes with formal documentation of findings recorded in the Supplier Performance Risk System (SPRS), creating an official record of the organization’s compliance status. If the assessment reveals that not all requirements have been met, the organization must complete a POA&M closeout assessment within 180 days to address identified deficiencies and demonstrate remediation.
Preparing for a DIBCAC Level 3 Assessment
Achieving DIBCAC Level 3 certification requires meticulous preparation and a demonstrated track record of cybersecurity maturity. Before an Organization Seeking Certification (OSC) can begin the Level 3 assessment process, it must first achieve Final Level 2 (C3PAO) status, establishing baseline compliance with fundamental CMMC requirements.
NIST SP 800-171 and 800-172 form the cornerstone of Level 3 preparation. This goes far beyond checking boxes on a spreadsheet, however. You must configure robust technical, administrative, and operational controls throughout their environment, with particular emphasis on controls designed to mitigate APTs.
While Level 2 assessments may accept that specific requirements are addressed through documented procedures, Level 3 demands that every control be implemented, maintained, and integrated into daily operations. Assessors look for evidence that security practices as part of your culture. This means producing audit logs, incident response records, configuration management histories, and other tangible proof that controls function consistently over time.
You should also invest in internal readiness reviews and mock assessments well before the official DIBCAC evaluation. Engaging experienced assessors or specialized consultants to simulate the actual assessment proves invaluable. These practice runs identify gaps in documentation, reveal weaknesses in control implementation, and familiarize staff with the assessment process.
Common Pitfalls in DIBCAC Assessments
Even well-prepared organizations can stumble during DIBCAC assessments due to recurring issues that undermine otherwise strong cybersecurity programs. Understanding these common pitfalls helps organizations avoid costly mistakes and assessment delays.
Organizations frequently encounter the following critical challenges:
- Incomplete SSPs or Outdated Documentation: One of the most common problems is System Security Plans that fail to accurately reflect the current state of the environment. SSPs must include recent changes to infrastructure, personnel, or processes. Assessors will quickly identify discrepancies between documentation and reality, which can cast doubt on the organization’s overall governance maturity and raise questions about the reliability of other documentation presented.
- Unrealistic or Non-Specific POA&Ms: Plans of Action and Milestones must contain concrete, achievable steps with realistic timelines and assigned responsibilities. Each milestone should be measurable, time-bound, and adequately resourced.
- Failure to Implement CUI Boundary Protections and Data Flow Restrictions: Simply knowing where CUI exists is insufficient. Organizations must demonstrate that appropriate technical and procedural safeguards prevent unauthorized access, egress, or commingling with non-CUI data. This includes proper network segmentation, access controls, and data-handling procedures consistently enforced across all systems and touchpoints where CUI is present.
- Inadequate Logging and Monitoring Practices: Level 3 requires comprehensive visibility into system activities, user behaviors, and security events. Organizations must collect, analyze, and retain logs sufficient to detect anomalous activity and support incident investigations.
- Misclassified or Improperly Scoped Assets: Assets that should be included in the assessment boundary but are omitted, or conversely, unnecessary assets that are included, create confusion and can result in incomplete evaluations or wasted effort examining irrelevant systems. This fundamental scoping error can derail an assessment before it truly begins and may require restarting the entire process once discovered.
Strategic Recommendations for OSCs
Organizations dramatically improve their DIBCAC success by following strategic recommendations that address both technical requirements and assessment preparedness.
Develop a comprehensive understanding of where you store CUI, how it transmits across networks, and where systems process it. Create detailed data flow diagrams and document protection mechanisms at each stage.
Simultaneously, harden your IAM infrastructure. Mandate strong multi-factor authentication for all users accessing CUI or systems within the assessment boundary. Implement role-based access controls that strictly limit privileges according to job functions. Deploy robust session monitoring to detect anomalous authentication patterns or suspicious access attempts.
Beyond basic compliance, demonstrate cybersecurity resilience through proactive security. Implement continuous monitoring into your system security posture. Engage with threat-hunting programs, penetration testing, and red-team testing that proactively search for indicators of compromise. Ensure incident response capabilities are mature, tested, and aligned with the enhanced requirements of NIST SP 800-172.
Most importantly, engage early with DIBCAC and maintain that relationship throughout preparation. Initiate contact before you think you’re ready, participate actively in pre-assessment planning sessions, and provide all requested materials proactively and thoroughly. Maintain open communication channels with assessors throughout the process.
Work Within CMMC and DIBCAC Efficiently with Continuum GRC
DIBCAC’s role in executing CMMC Level 3 assessments is critical to the DoD’s effort to secure the DIB from sophisticated threats. Continuum GRC and our sister company, Lazarus Alliance, have been helping organizations like yours meet and exceed
We provide risk management and compliance support for every major regulation and compliance framework on the market, including:
- FedRAMP
- StateRAMP
- GDPR
- NIST 800-53
- FARS NIST 800-171
- CMMC
- SOC 1, SOC 2
- HIPAA
- PCI DSS 4.0
- IRS 1075
- COSO SOX
- ISO 27000 Series
- ISO 9000 Series
- ISO Assessment and Audit Standards
And more. We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.
Continuum GRC is a proactive cybersecurity® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect your systems and ensure compliance.
[wpforms id= “43885”]