While managed service providers (MSPs) play a crucial role in ensuring the seamless operation of information technology, there may come a time when it is necessary to find a new one. The factors that follow will help you determine whether your organization needs to make that switch, and how this may influence your compliance with the Cybersecurity Maturity Model Certification (CMMC).
The Importance of Managed Service Providers
Managed service providers perform a variety of tasks that are vital for businesses to thrive in the digital age. From handling routine IT maintenance and cyber defense, to data backups and cloud integration, MSPs streamline operations so that organizations can focus more on their core competencies. Their proactive monitoring and support prevents common issues with data management, while contributing to a more resilient and secure infrastructure.
How Do You Know When It’s Time to Look for a New Provider?
Before you begin an active search, it’s important that you assess the current and future needs of your organization. (This is especially relevant to small- and medium-sized businesses.) If there are critical areas that your current MSP is unable to suppport, but you know that you’ll need in order to scale, then it’s worth looking for others that can help you. Those areas can include the following.
Factors to Consider When Switching Managed Service Providers
Service Offerings and Scalability
Your new MSP should offer a wide range of services that align with the current level of your business, as well as its capacity for growth. This can involve scalable cloud solutions like software as a service (SaaS), to network architecture and on-premises data backups that can adapt to increased workloads.
Expertise and Industry Experience
You need an MSP that has worked in your industry and understands the unique requirements of your business. Look for one with a proven track record that can provide you with references. Depending on their pricing structure and any subscription-based services, you’ll want to make sure that you get what you’re paying for.
Security Measures
Managed service providers should be aware of the latest tools for keeping data organized and secure, especially with the continued rise of cyberattacks and ransomware. Your MSP should be transparent with you about their security measures, including what they use for threat detection, data encryption, and secure access controls.
Data Handling and Compliance
Make sure that your MSP understands the compliance requirements for your data, especially in relation to CMMC. This will dictate how they handle Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). Your MSP should know the difference between CUI and FCI, and have the resources to manage both. Your CMMC compliance will depend on this — more on that below!
Transition Plan
A well-defined transition plan from your current MSP to a new one is crucial for minimizing disruptions to your service. Work with your new MSP to create a detailed roadmap, ensuring a smooth transition without compromising ongoing projects or deliverables.
Communication and Support
It should go without saying, but customer service is the key to any business partnership. You should know what level of technical support and response times to expect from your managed service provider, whether it’s addressing issues promptly, minimizing downtime, or reacting to a digital threat like a data breach.
Service-level agreements (SLAs) should also outline what your business can expect from your MSP in the event of a data breach — specifically, what role your MSP will play in that process, and whether they will be available to you for support during any follow-up proceedings.
Switching MSPs and CMMC Compliance
The decision to switch MSPs is not made in isolation; it has implications for cybersecurity and regulatory compliance. For organizations involved in government contracts, compliance with the Cybersecurity Maturity Model Certification is critical. The CMMC framework is designed to enhance their cybersecurity posture to protect any Controlled Unclassified Information (CUI).
Know the Difference Between CUI and FCI
Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) are two types of data that are crucial for your MSP to know about. While they may sound similar, they each have different requirements when it comes to organization and protection.
Controlled Unclassified Information (CUI) is data that requires safeguarding or dissemination controls. The term “controlled” highlights the need for measures that protect it from unauthorized access or disclosure. CUI can involve areas like data privacy, proprietary business operations, and law enforcement. Both the handling and protection of CUI are dictated by specific guidelines and standards established by the Department of Defense (DoD).
Federal Contract Information (FCI) is a subset of CUI that specifically relates to information created or possessed by or for the government. It may include proprietary information, financial data, and other sensitive details that are essential for the performance, integrity, and completion of a federal contract.
One key difference between CUI and FCI lies in their scope. CUI encompasses a broader range of sensitive information, including data that may not necessarily be associated with federal contracts. FCI, on the other hand, falls strictly under those contracts.
The handling and protection of CUI and FCI are governed by various regulations and standards. Executive Order 13556 provides the framework for managing and protecting CUI. For FCI, requirements are often outlined in the contract itself. Government contractors are obligated to comply with these terms and conditions, as failure to do so can lead to serious consequences like contract termination or legal action.
If you work with the government and deal with CUI or FCI, you’ll be required to implement stringent security measures, including access controls, encryption, and other safeguards noted in the CMMC framework.
CMMC Requirements and MSP Transition
Perhaps the reason you’re deciding to change managed service providers is because they don’t fully meet the requirements for the level of CMMC certification that you need. Make sure that your new MSP outlines how they intend to fulfill those requirements and complete a successful transfer without introducing vulnerabilities or gaps in your cyber defense.
Data Migration and CUI Protection
If your organization handles CUI, you can imagine the potential consequences of unprotected data migration when switching to a new MSP. Therefore, that provider should have encryption methods and secure data transfer protocols in place as safeguards during that process.
Continuous Network Monitoring and Reporting
If your organization requires CMMC, you will need regular compliance audits. Ensure that your new MSP has the capabilities to implement and maintain continuous monitoring practices, as well as the necessary reporting for documentation.
Latest News on CMMC’s Proposed Rule
CMMC 2.0 has long been a topic of discussion within the defense industry, with its proposed rule only recently released by the DoD at the end of last December. As of this post, a comment period is currently in effect through February 26, 2024.
The proposed rule aims to amend the Defense Federal Acquisition Regulation Supplement (DFARS) by updating CMMC requirements for all government contractors. These requirements have been consolidated into three (3) maturity levels that outline the best practices and services for protecting sensitive data. Contractors must achieve and maintain these requirements, and provide two pieces of evidence for each.
Timeline and Implementation
The proposed rule provides a timeline for the phased implementation of CMMC 2.0. If your self-attestion score doesn’t align with your CMMC third-party audit, you’ll be at risk for losing your current and future contracts. Since your MSP will be dealing with the bulk of your CMMC requirements, you will need to partner with one that understands their role in your compliance.
Evolution of CMMC
CMMC is expected to evolve over time, adapting to emerging cyber threats and technology solutions. You and your MSP will need to stay informed about updates and revisions to its framework so that you don’t put your data at risk.
Brenda Doles: Your Partner in CMMC Compliance
Brenda Doles is the knowledge expert you need for balancing your search for a new managed service provider with the implementation of CMMC requirements. As your trusted advisor, she will work with you to identify the key factors for your MSP selection, and how those relate to the CMMC framework.
Ms. Doles specializes in tailored solutions for organizations seeking enhanced cybersecurity. As an early adopter and proponent of CMMC, her expertise allowed her to lead her own company through the rigors of compliance, giving her unique insight into its challenges.
Let Brenda Doles provide your team with guidance and support for effective data management and long-term success. Click here to schedule an introductory consultation.