Ready for the Future: What You Can Do Now to Prepare for CMMC

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The Cybersecurity Maturity Model Certification (CMMC) is reshaping the cybersecurity landscape for organizations working with the U.S. Department of Defense (DoD). While full CMMC implementation may take time, there are steps you can take today to set the stage for success. In this blog post, we’ll explore what you can do now to prepare for CMMC, ensuring that your organization is well-equipped to meet the challenges of this new cybersecurity standard.

1. Understand the CMMC Framework

What is CMMC? The Cybersecurity Maturity Model Certification is a standard designed to assess the cybersecurity capabilities of defense contractors. It introduces a tiered model with three distinct maturity levels, each with its own set of practices and processes.

How to Get Started:

  • Study the CMMC Model: Begin with the CMMC 2.0 Model documentation to understand its structure. Each maturity level represents increasing degrees of cybersecurity rigor.
  • Familiarize Yourself with Domains and Capabilities: The framework is organized into 17 domains, such as Access Control and Incident Response, with specific capabilities at each level. For instance, Level 1 focuses on basic cybersecurity hygiene, while Level 3 emphasizes advanced practices.
  • Review CMMC Guidelines: Read the CMMC 2 Practice Guides for a detailed understanding of requirements.

Pro Tip: Join a CMMC group or attend webinars. The CMMC AB often hosts events and provides resources to help organizations understand the model.

2. Assess Your Current State

Conducting a Self-Assessment:

  • Cybersecurity Policies:

    • Current State: Are your policies documented and comprehensive?
    • Future State: Ensure your policies cover all CMMC domains and are up-to-date. Review the National Institute of Standards and Technology (NIST) Cybersecurity Framework for reference.
  • Security Controls:

    • Current State: How do you currently manage access, monitoring, and data protection?
    • Future State: Identify gaps and start addressing them. Use tools to benchmark your current security posture.
  • Incident Response Plans:

    • Current State: Do you have a documented and tested incident response plan?
    • Future State: Review your incident response plan against the NIST SP 800-61 standards for incident handling.
  • Data Protection:

    • Current State: How is sensitive data stored, processed, and protected?
    • Future State: Ensure you have encryption, access controls, and regular audits in place.

Pro Tip: Use a gap analysis tool to document your current state versus CMMC requirements, which will help in formulating an improvement plan.

3. Identify Key Stakeholders

Who to Involve:

  • Chief Information Security Officer (CISO): Leads the CMMC compliance efforts and ensures alignment with organizational goals.
  • IT and Security Teams: Responsible for implementing technical controls and policies.
  • External Consultants (C3PAOs): Engage with Certified Third-Party Assessment Organizations for official assessments and guidance.

Action Steps:

  • Establish Roles and Responsibilities: Define who will handle specific CMMC practices and processes.
  • Create a CMMC Task Force: Form a team with representatives from key departments to ensure comprehensive planning and execution.

Pro Tip: Consider hiring a consultant with experience in CMMC assessments to provide insights and facilitate the process.

4. Begin Training and Education

Training Resources:

  • CMMC-Specific Training: Look for CMMC-AB accredited training programs.
  • General Cybersecurity Awareness: Offer training on topics like phishing, password management, and data protection.
  • Specialized IT and Security Training: Invest in advanced training for your IT and security teams to understand complex cybersecurity concepts.

Action Steps:

  • Create a Training Plan: Outline mandatory training sessions, certifications, and continuing education requirements.
  • Evaluate Training Programs: Choose programs that are accredited and offer certifications recognized in the industry.

Pro Tip: Regularly update training materials to reflect the latest cybersecurity trends and CMMC updates.

5. Develop an Implementation Plan

Creating a Strategic Plan:

  • Define Goals and Objectives: Set clear, achievable goals based on the CMMC level you are targeting.
  • Develop a Roadmap: Outline key milestones, timelines, and resource allocations.
  • Allocate Resources: Budget for tools, training, and external support.

Action Steps:

  • Develop a Project Plan: Use project management tools to manage tasks and track progress.
  • Set Up a Timeline: Create a Gantt chart to visualize tasks and deadlines.

Pro Tip: Regularly review and adjust the implementation plan based on progress and any new developments in CMMC requirements.

6. Map Out Budget and Resources

Financial Planning:

  • Identify Costs: Include costs for technology upgrades, staff training, and consulting services.
  • Create a Budget: Allocate funds for each phase of the CMMC compliance process.

Action Steps:

  • Prepare a Budget Proposal: Detail costs for each component of the compliance effort.
  • Monitor Expenses: Track spending and adjust as necessary to stay within budget.

Pro Tip: Consider potential funding opportunities or grants for cybersecurity improvements.

7. Establish a Security Culture

Building a Security-Conscious Organization:

  • Promote Awareness: Regularly communicate the importance of cybersecurity and CMMC compliance.
  • Encourage Best Practices: Foster an environment where employees are proactive about security.

Action Steps:

  • Implement Security Initiatives: Organize workshops, seminars, and security drills.
  • Recognize Contributions: Reward employees who demonstrate strong security practices.

Pro Tip: Create a security champions program where enthusiastic employees can advocate for best practices within their teams.

8. Stay Informed and Adapt

Keeping Up with Changes:

  • Subscribe to Updates: Follow CMMC-AB for the latest news and updates.
  • Attend Industry Events: Engage with the cybersecurity community through conferences and forums.

Action Steps:

  • Join Professional Associations: Engage with organizations like ISACA or (ISC)² for ongoing education and networking.
  • Monitor Cybersecurity Trends: Use resources like SANS Institute on Security for the latest security information.

Pro Tip: Establish a regular review schedule for your compliance strategies to integrate new best practices and standards.

9. Engage with CMMC Experts

Finding the Right Help:

  • Seek Qualified Consultants: Look for consultants or firms with experience in CMMC compliance.
  • Work with C3PAOs: Engage Certified Third-Party Assessment Organizations for formal assessments.

Action Steps:

  • Research and Select Experts: Choose firms or individuals with a track record of successful CMMC compliance projects.
  • Establish Clear Contracts: Define the scope of work and expectations in contracts with consultants.

Pro Tip: Ask for references and review case studies from other organizations that have successfully achieved CMMC certification.

10. Build CMMC Documentation Practices

Documenting Your Efforts:

  • Develop Documentation Standards: Create and maintain comprehensive records of your cybersecurity practices.
  • Ensure Consistency: Implement a standardized approach for documenting policies, procedures, and incidents.

Action Steps:

  • Establish Documentation Procedures: Create templates for policies and incident reports.
  • Regularly Review Documentation: Schedule periodic reviews to ensure accuracy and completeness.

Pro Tip: Use document management systems like SharePoint to keep documents organized and accessible.

Conclusion

Preparing for CMMC is more than just a compliance checklist—it’s about strengthening your organization’s cybersecurity resilience. By taking these proactive steps, you not only prepare for future requirements but also enhance your overall security posture. Start today to make your CMMC compliance journey a successful one. Embrace the challenge with a strategic mindset and be ready to navigate the evolving landscape of cybersecurity.

Provincia Government Solutions, LLC is a Nashville-based security and risk assurance firm specializing in government regulatory and compliance cybersecurity requirements. Our expertise encompasses a wide range of standards, including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E, and Zero Trust Architecture (ZTA) solutions.

Our client base comprises government agencies, contractors, and commercial organizations affiliated with government entities. Whether you require audit preparedness, compliance and assurance assessments, security consulting, or CMMC certification, we have the knowledge and experience to assist you.

For a no-cost consultation, please don’t hesitate to contact us at (615) 807-2822 or via email at info@provincia.io. We look forward to discussing your security needs and finding solutions tailored to your specific requirements.

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Provincia Government Solutions is a SBA certified Small  Business cybersecurity assurance firm and a CMMC Certified Third Party Assessment Organization (C3PAO).  We were the first organization to become a  C3PAO in the Middle Tennessee (Nashville) area and provide a full range of services including CMMC consulting and certification assessments. Our assessment team is trained in CMMC and other government assessment disciplines and we are experienced working with organizations of all sizes. Please reach out with any cybersecurity or CMMC related inquiries. We look forward to speaking with you!

 

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Bolstering Supply Chain Security: CMMC and Its Impact on Subcontractors and Suppliers

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In today’s interconnected world, supply chain security has become a top priority, especially in sectors where sensitive information and national security are at stake. The U.S. Department of Defense (DoD) recognizes the critical importance of securing its supply chain, and that’s where the Cybersecurity Maturity Model Certification (CMMC) comes into play. In this blog, we will delve into how CMMC is aimed at enhancing supply chain security in the defense sector and what it means for subcontractors and suppliers.

Understanding the Significance of Supply Chain Security

Supply chains in the defense sector are complex, involving multiple tiers of subcontractors and suppliers. These networks handle sensitive information, classified data, and technology that are vital to national security. Ensuring the security and integrity of this supply chain is of paramount importance.

The Role of CMMC in Supply Chain Security

CMMC, or the Cybersecurity Maturity Model Certification, is a framework designed to strengthen cybersecurity practices within the defense industrial base. It introduces a comprehensive set of security controls and practices that must be met by organizations handling Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) as part of the DoD supply chain.

Here’s how CMMC contributes to enhancing supply chain security:

1. Standardized Cybersecurity Requirements:

CMMC establishes a standardized set of cybersecurity requirements that all organizations handling FCI and CUI must adhere to. This consistency ensures that every entity, from the primary contractor to the smallest subcontractor, follows a unified security framework.

2. Data Protection and Classification:

One of the key aspects of CMMC is the protection and classification of data. It defines how sensitive information should be handled and protected at every stage of the supply chain. This includes marking and controlling the flow of data and reducing the risk of data breaches and leaks.

3. Continuous Monitoring:

CMMC places a strong emphasis on continuous monitoring of security practices. Subcontractors and suppliers must regularly assess their compliance with CMMC requirements, identify vulnerabilities, and implement remediation strategies to maintain a high level of security.

What CMMC Means for Subcontractors and Suppliers

While CMMC offers significant benefits, it also presents challenges for subcontractors and suppliers:

  1. Resource Constraints: Smaller organizations may face resource limitations when striving for CMMC compliance. Allocating budget and expertise can be a challenge.
  2. Data Handling: Understanding how to classify and protect sensitive data according to CMMC standards is a key consideration.
  3. Training and Expertise: Ensuring that employees are trained and knowledgeable about CMMC requirements is crucial for successful compliance.

For subcontractors and suppliers in the defense sector, CMMC compliance is not just a matter of regulatory adherence; it’s a fundamental part of securing business opportunities and safeguarding sensitive data.

Here’s what it means for these entities:

  1. Business Opportunities:

CMMC compliance will be a prerequisite for participating in many DoD contracts. Subcontractors and suppliers must meet the CMMC requirements associated with the level of data they handle. Compliance opens doors to lucrative defense contracts.

  1. Data Security and Trust:

CMMC compliance helps build trust between subcontractors, suppliers, and the DoD. Demonstrating the ability to protect sensitive information fosters confidence in the supply chain.

  1. Competitive Edge:

In a highly competitive market, CMMC compliance sets subcontractors and suppliers apart. It positions them as reliable partners who prioritize supply chain security and data protection

Conclusion

CMMC plays a pivotal role in enhancing supply chain security for the defense sector. Subcontractors and suppliers must understand the significance of CMMC compliance, not only as a regulatory obligation but as a means of securing business opportunities, safeguarding data, and maintaining the integrity and security of the defense supply chain. The effort required to meet CMMC requirements is an investment in the future of these organizations and, more importantly, in the national security of the United States.

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Provincia Government Solutions is a SBA certified Small  Business cybersecurity assurance firm and a CMMC Certified Third Party Assessment Organization (C3PAO).  We were the first organization to become a  C3PAO in the Middle Tennessee (Nashville) area and provide a full range of services including CMMC consulting and certification assessments. Our assessment team is trained in CMMC and other government assessment disciplines and we are experienced working with organizations of all sizes. Please reach out with any cybersecurity or CMMC related inquiries. We look forward to speaking with you!

 

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C3PAOs: Their Vital Role in CMMC Compliance

C3PAOs: Their Vital Role in CMMC Compliance

CMMC has ushered in a new era of cybersecurity standards for DoD supply chain organizations. As companies strive to meet CMMC requirements, they must navigate a complex landscape, and one critical aspect is working with C3PAO’s. In this blog post, we will outline the role of C3PAO’s in CMMC compliance and explore their significance in the certification process

Who Are C3PAOs?

C3PAO’s, or Certified Third-Party Assessment Organizations, are independent entities authorized by the Cyber-AB to conduct assessments of organizations seeking CMMC certification. These organizations play a pivotal role in the CMMC ecosystem, serving as assessors that evaluate an organization’s adherence to the CMMC framework.

The Role of C3PAO’s in CMMC Compliance

  • Objective Assessment: C3PAO’s and their assessment staff objectively assess an organization’s cybersecurity practices. They evaluate whether an organization’s policies, procedures, and controls align with CMMC requirements.
  • Impartial Evaluation: C3PAO’s are neutral third parties, which means they are not vested in whether an organization passes or fails the assessment. This impartiality ensures the integrity of the certification process.
  • Certification Determination:  C3PAO’s make recommendations for certification based on the results from the testing.
  • Compliance Guidance: C3PAO’s can offer guidance and recommendations to organizations seeking certification during consulting engagements but not during certification assessments.
  • Assessment Expertise: C3PAO’s employ cybersecurity professionals with expertise in the CMMC framework and related cybersecurity practices. Their assessors have undergone rigorous training to conduct assessments effectively.

The C3PAO Assessment Process

The assessment process conducted by C3PAO’s typically involves the following steps:

  1. Pre-Assessment Preparation: Organizations seeking certification work to prepare their cybersecurity practices and documentation.
  2. Assessment: Lead Assessors conduct on-site or remote assessments to evaluate the organization’s cybersecurity controls and practices.
  3. Report Submission: After the assessment, the Lead Assessor submits a report detailing the organization’s compliance status to the C3PAO,  Cyber-AB and eMASS (Department of Defense).
  4. Certification Decision: The C3PAO makes a recommendation for certification based on the results from the testing, and the recommendation and testing is reviewed by the Cyber-AB.
  5. Ongoing Compliance: CMMC certification is not a one-time event. Organizations must maintain compliance continuously, and periodic assessments are part of the process.

Why C3PAOs Matter

C3PAO’s are integral to the CMMC certification process for several reasons:

  1. Expertise and Objectivity: Their expertise and impartiality ensure a fair and accurate assessment of an organization’s cybersecurity practices.
  2. Certification Credibility: C3PAO involvement enhances the credibility of CMMC certification, as qualified, independent entities conduct assessments.
  3. Guidance and Improvement: C3PAO’s can provide valuable guidance to organizations, helping them improve their cybersecurity posture.
  4. Consistency: C3PAO’s follow standardized assessment processes, ensuring consistency in evaluating organizations.

C3PAO’s are key players in the CMMC certification journey. Their role in assessing and verifying an organization’s cybersecurity practices is vital for achieving compliance with the CMMC framework. By working with C3PAOs, organizations can navigate the complex landscape of CMMC more effectively and contribute to the overall enhancement of cybersecurity in the defense supply chain.

Conclusion

As organizations strive for CMMC compliance, partnering with a trusted C3PAO becomes a strategic move toward achieving and maintaining certification, bolstering cybersecurity practices, and securing valuable DoD contracts.

Provincia Government Solutions, LLC is a Nashville-based security and risk assurance firm specializing in government regulatory and compliance cybersecurity requirements. Our expertise encompasses a wide range of standards, including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E, and Zero Trust Architecture (ZTA) solutions.

Our client base comprises government agencies, contractors, and commercial organizations affiliated with government entities. Whether you require audit preparedness, compliance and assurance assessments, security consulting, or CMMC certification, we have the knowledge and experience to assist you.

For a no-cost consultation, please don’t hesitate to contact us at (615) 807-2822 or via email at info@provincia.io. We look forward to discussing your security needs and finding solutions tailored to your specific requirements.

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ABOUT US

Provincia Government Solutions is a SBA certified Small  Business cybersecurity assurance firm and a CMMC Certified Third Party Assessment Organization (C3PAO).  We were the first organization to become a  C3PAO in the Middle Tennessee (Nashville) area and provide a full range of services including CMMC consulting and certification assessments. Our assessment team is trained in CMMC and other government assessment disciplines and we are experienced working with organizations of all sizes. Please reach out with any cybersecurity or CMMC related inquiries. We look forward to speaking with you!

 

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Mastering CMMC Documentation: Your Comprehensive Guide

CMMC Documentation

Mastering CMMC Documentation:
Your Comprehensive Guide

Understanding CMMC Documentation

Before delving into the specifics of CMMC documentation, it’s essential to comprehend why documentation is such a fundamental component of the framework. CMMC requires organizations to implement cybersecurity practices and thoroughly document their processes, policies, and security controls. Documentation serves several crucial purposes:

  1. Evidence of Compliance:  Documentation provides tangible evidence that your organization is adhering to the cybersecurity practices mandated by CMMC.
  2. Audit Trail: It creates an audit trail that verifies compliance during assessments and audits.
  3. Continuous Improvement: Documentation fosters a culture of continuous improvement by helping organizations identify areas where cybersecurity practices can be refined.
  4. Knowledge Sharing: It facilitates knowledge sharing among team members, ensuring everyone is on the same page regarding cybersecurity policies and procedures. 

The Components of CMMC Documentation

CMMC documentation covers a range of elements that align with the specific requirements of the chosen maturity level. Here are the key components:

  1. Policies: Organizations must establish and document comprehensive cybersecurity policies that outline their commitment to cybersecurity practices. These policies should cover areas such as data protection, incident response, and access control.
  2. Procedures: Documented procedures detail how cybersecurity processes are executed within your organization. For instance, you may have procedures for conducting vulnerability assessments, patch management, and employee training.
  3. Plans: Develop cybersecurity plans that map out your strategy for achieving and maintaining compliance. These plans should be dynamic, adapting to changing threats and technologies.
  4. Incident Response Plan: An incident response plan is a critical component of CMMC documentation. It outlines the steps your organization will take in the event of a cybersecurity incident, ensuring a swift and effective response.
  5. Security Controls: CMMC requires organizations to implement specific security controls. Documenting how these controls are implemented and maintained is crucial for compliance.

Best Practices for CMMC Documentation

Creating effective CMMC documentation requires careful planning and execution. Here are some best practices to consider:

  1. Centralized Repository: Maintain a centralized repository for all cybersecurity documentation. This ensures easy access and version control.
  2. Clear Language: Use clear and concise language in your documents. Avoid jargon or technical terms that may be unclear to non-experts.
  3. Version Control: Implement version control to track changes and updates to your documentation. This helps maintain an accurate historical record.
  4. Regular Reviews: Periodically review and update your documentation to ensure it remains current and reflects your cybersecurity practices.
  5. Training: Train your team members on the importance of documentation and how to create and maintain compliant documents.
  6. Compliance Validation: Regularly validate your documentation against CMMC requirements to identify gaps or inconsistencies.

Concluding Thoughts

CMMC documentation is not merely a compliance requirement; it’s a cornerstone of effective cybersecurity practices. Documenting your cybersecurity efforts will help you achieve and maintain compliance and enhance your organization’s overall security posture. As you embark on your CMMC compliance journey, remember that meticulous documentation is your ally in safeguarding sensitive information, bolstering cybersecurity, and building trust with government entities.

Provincia Government Solutions, LLC is a Nashville-based security and risk assurance firm specializing in regulatory and compliance cybersecurity requirements. Our expertise spans a wide range of standards, including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E, and Zero Trust Architecture (ZTA) solutions.

Our client base comprises government agencies, contractors, and commercial organizations affiliated with the U.S. government. Whether you require audit preparedness, compliance and assurance assessments, security consulting, or CMMC certification, we have the knowledge and experience to assist you.

For a no-cost consultation, please don’t hesitate to contact us at (615) 807-2822 or via email at info@provincia.io. We look forward to discussing your security needs and finding solutions tailored to your specific requirements.

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CMMC in the Federal Register

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CMMC in the Federal Register

By Heather Bennett

January 8,2024

What's the Buzz?

CMMC is in the Federal Register. That’s the new buzz in the cybersecurity world. What does that mean exactly? We have waited a few weeks to respond to this. After reading countless articles and blogs and attending webinars on this specific, we found that one thing remains true. There is still so much we don’t know.

What is missing?

There is on things that we know for sure. The official cut-off date for comments is February 26, 2024. Beyond that, there are no concrete dates. A great among speculation on when the rule will become law is circulating. Some say summer 2024, and some say December 2024. After the final ruling, there will be a phased rollout to all DIB contractors. Despite CMMC not being official yet, there has been CMMC language in new contracts to cover contracts that could extend into the expected CMMC rollout.

You can view the official Register entry here . At the time of this blog, and there have been 12,615 views and 32 public submitted comments. These comments consist of requests for clarity, noting discrepancies, and reporting errors. The common sentiment from the community outside of the official channel has been similar. There has also been a sense of “we knew this was coming.”

CMMC has been a buzzword for 5 years. Despite its slow crawl, we can now see the finish line. Many experts are agreeing that those who have not been preparing will be left behind. At the very least, they will be caught in the bottleneck that is inevitably on the horizon.

Below, you will find information you may find useful in understanding the Federal Register process and how to monitor its progress.

The Federal Register and CMMC:

The Federal Register serves as the official repository for all federal agency rules, proposed rules, and notices. It plays a crucial role in disseminating information to the public, and CMMC is no exception. The documentation related to CMMC in the Federal Register provides insights into the framework’s development, updates, and implementation.

Key Elements in the Federal Register:

  1. Rulemaking Notices: The Federal Register publishes rulemaking notices related to CMMC, including proposed rules, final rules, and interim rules. These notices outline the changes to be made, the rationale behind them, and the implications for defense contractors.
  2. Public Comments and Feedback: One significant aspect of the Federal Register’s role in the CMMC context is the opportunity for public engagement. Interested parties can submit comments, suggestions, and feedback on proposed rules, allowing for a more inclusive and collaborative approach to refining the framework.
  3. Updates and Amendments: As the CMMC framework evolves, the Federal Register reflects any regulation updates or amendments. Staying abreast of these changes is vital for contractors aiming to comply with the latest cybersecurity requirements.
  4. Implementation Guidelines: The Federal Register may provide additional guidance on implementing and interpreting CMMC requirements. This can include clarifications on specific controls, assessment procedures, and compliance timelines.

Benefits of Monitoring the Federal Register for CMMC Updates:

  1. Timely Compliance: Regularly checking the Federal Register ensures that defense contractors are promptly aware of any CMMC requirements changes. This proactive approach helps organizations stay ahead in their compliance efforts.
  2. Informed Decision-Making: Accessing information in the Federal Register allows contractors to make informed decisions about cybersecurity investments, strategy adjustments, and overall compliance efforts.
  3. Engagement in the Regulatory Process: The opportunity to submit comments and participate in the regulatory process fosters collaboration between the government and industry stakeholders, resulting in a more robust and effective CMMC framework

Final Thoughts

CMMC is a pivotal step in bolstering the cybersecurity defenses of defense contractors. The information disseminated through the Federal Register serves as a crucial resource for understanding, implementing, and staying current with CMMC requirements. By actively engaging with the Federal Register, organizations can navigate the complexities of the framework and contribute to its continuous improvement, ultimately enhancing the overall cybersecurity posture of the defense industrial base.

Provincia Government Solutions, LLC is a Nashville based HUBZone certified security and risk assurance firm with advanced expertise in government regulatory and compliance cybersecurity requirements including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E and ZTA (Zero Trust Architecture) solutions. Our client base includes  government agencies, contractors, and commercial organizations affiliated with government entities. Whether you are seeking audit preparedness, compliance and assurance assessments,  security consulting, or CMMC certification, we have the expertise to help.  Contact us at (615) 807-2822 or at info@provincia.io to discuss your security needs today. Consultations are free of charge and we look forward to speaking with you!

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Provincia Government Solutions is a SBA certified Small  Business cybersecurity assurance firm and a CMMC Certified Third Party Assessment Organization (C3PAO).  We were the first organization to become a  C3PAO in the Middle Tennessee (Nashville) area and provide a full range of services including CMMC consulting and certification assessments. Our assessment team is trained in CMMC and other government assessment disciplines and we are experienced working with organizations of all sizes. Please reach out with any cybersecurity or CMMC related inquiries. We look forward to speaking with you!