CMMC 2.0: A Practical Guide for DoD Level 1 Contractors

The Cybersecurity Maturity Model Certification (CMMC) 2.0 is the U.S. Department of Defense (DoD) framework for protecting Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). With CMMC 2.0, the DoD has streamlined compliance into three levels, with Level 1 serving as the foundational baseline for contractors handling FCI.

For organizations working with the DoD, achieving CMMC 2.0 Level 1 is crucial to maintaining contracts and ensuring basic cybersecurity hygiene. More than 120,000 organizations worldwide are subject to Level 1 compliance, making it a critical aspect of the Defense Industrial Base (DIB) security strategy. This article explores who must comply, the specific security requirements, and how an Identity Governance & Administration (IGA) solution like Omada Identity Cloud can support compliance efforts.

Who Is Subject to CMMC 2.0 Level 1?

CMMC 2.0 Level 1 applies to all defense contractors, foreign and domestic, that handle U.S. Federal Contract Information (FCI). This includes any organization contracted by the DoD that does not process Controlled Unclassified Information (CUI) but still interacts with federal data that must be safeguarded.

Key Characteristics of CMMC 2.0 Level 1 Organizations:

1. Typically includes small and medium-sized businesses in the DoD supply chain.
2. Covers manufacturers, service providers, and vendors with access to FCI.
3. Requires annual self-assessments, rather than third-party audits.
4. Aligns with Federal Aquisition Regulation – FAR Clause 52.204-21 (Basic Safeguarding of Covered Contractor Information Systems).
5. Represents over 120,000 organizations globally that interact with DoD contracts.

CMMC 2.0 Level 1 Requirements and FAR Clause 52.204-21 Alignment

CMMC 2.0 Level 1 consists of 17 cybersecurity practices that align with the 15 basic safeguarding requirements of FAR 52.204-21. These controls focus on basic cyber hygiene and include specific access controls to protect FCI.

CMMC 2.0 Level 1 Controls Mapped to FAR 52.204-21

CMMC 2.0 Implementation Timeline

CMMC 2.0 is expected to be in full effect by 2025, with rulemaking completed by the end of 2024. While compliance is currently voluntary, contracts started including CMMC 2.0 requirements in late 2024. Organizations that fail to meet Level 1 requirements may lose eligibility for DoD contracts.

How Omada Identity Cloud Supports CMMC 2.0 Level 1 Compliance

Implementing CMMC 2.0 Level 1 requires strong identity governance to ensure only authorized users access FCI and critical IT systems. An IGA solution like Omada Identity Cloud plays a key role in establishing and maintaining compliance.

1. Strengthening Access Control (AC.L1-3.1.1 & IA.L1-3.5.1)

1. Role-Based Access Control (RBAC): Restricts FCI access to only authorized personnel.
2. Automated User Provisioning & Deprovisioning: Ensures users receive appropriate access based on job roles and are removed when no longer needed.
3. Multi-Factor Authentication (MFA): Enforces strong authentication before access is granted.

2. Enforcing Least Privilege & Reducing Insider Threats

1. Access Reviews & Certifications: Automates periodic user access reviews to ensure ongoing compliance.
2. Separation of Duties (SoD): Prevents conflicts in access permissions to reduce insider risks.
3. Policy-Based Access Controls: Limits access based on business rules, user risk profiles, and compliance mandates.

3. Automating Audit Logs & Compliance Monitoring (AU.L1-3.3.1)

1. Centralized Audit Logging: Tracks and records all user access activities.
2. Integration with SIEM & Compliance Tools: Streamlines security monitoring and incident detection.
3. Real-Time Alerts & Risk Scoring: Identifies suspicious access patterns or unauthorized changes.

4. Managing Physical & Remote Access (PE.L1-3.10.1)

1. Physical Identity Governance: Integrates with badge systems to restrict facility access.
2. Remote Work Security Policies: Ensures only compliant devices and authenticated users can access FCI remotely.

How a Modern IGA Solution Aids in the Self-Assessment Process

CMMC 2.0 Level 1 requires annual self-assessments, a modern IGA solution such as Omada Identity Cloud streamlines compliance tracking and evidence collection, simplifying user access governance, and ensuring continuous compliance monitoring. The following points illustrate how these features reduce the administrative burden and help maintain a high level of security.

1. Automating Self-Assessment Reports

1. Mapping User Access Policies to CMMC Controls
   An IGA platform automatically correlates user access policies (e.g., least-privilege, role-based access) with specific CMMC Level 1 requirements. Having this mapping available in a centralized dashboard allows organizations to quickly identify potential gaps and address them before finalizing any self-assessment documentation.
2. Generating Audit-Ready Reports
   With the click of a button, teams can compile comprehensive, audit-ready reports detailing control effectiveness, policy violations, and remediation steps. These reports can be submitted during DoD assessments, demonstrating compliance with minimal manual effort.

Key Benefit: Reduces the time and resources spent on manually gathering and mapping user and system access data to each control requirement.

2. Enhancing Continuous Monitoring & Documentation

1. Comprehensive Audit Trail
   Every policy change, access request, approval, or revocation is logged. This creates a chain of evidence showing that proper procedures are followed and that any deviations from CMMC policies are identified and addressed. It also eases the creation of artifacts needed for the self-assessment process.
2. Risk-Based Recommendations
   An IGA solution can analyze access patterns and compare them against best practices or known security baselines. From there, it can recommend actions to strengthen identity security (e.g., removing excessive privileges, tightening password policies, or segmenting user access).

Key Benefit: Provides real-time visibility into user provisioning and ensures ongoing adherence to CMMC 2.0 requirements through automatic logging and incident tracking.

3. Reducing Assessment Complexity

1. Streamlined Evidence Collection
   Because identity lifecycle events and policy changes are centrally managed and documented, organizations reduce duplication of effort when collecting artifacts needed for annual self-assessments. The solution captures relevant data in one place, making the process more efficient.
2. Alignment with SPRS Scoring Methodology
   The DoD’s Supplier Performance Risk System (SPRS) scoring methodology involves understanding risks associated with contractors’ security practices. An IGA solution designed with this methodology in mind helps map each control domain to a corresponding SPRS score. This alignment simplifies the self-assessment scoring process and provides a clear roadmap for improvement.

Key Benefit: Offers a straightforward way to gauge the security posture against DoD standards, decreasing the complexity of identifying where additional measures are needed.

Strengthening Compliance with IGA

As CMMC 2.0 Level 1 becomes a contractual necessity, organizations handling FCI must prioritize basic cybersecurity hygiene. An IGA solution like Omada Identity Cloud provides the automation, governance, and visibility needed to meet compliance requirements efficiently.

By implementing strong access controls, automated compliance monitoring, and secure identity governance, contractors can reduce cybersecurity risks, pass self-assessments, and remain eligible for DoD contracts.

Are you preparing or working on CMMC 2.0 Level 1 compliance? Contact us to learn how Omada Identity Cloud can simplify your journey toward secure and compliant identity governance!