Standards Comparison

    CMMC

    Mandatory
    2021

    DoD certification verifying cybersecurity for FCI and CUI

    VS

    FERPA

    Mandatory
    1974

    U.S. federal regulation for student education records privacy

    Quick Verdict

    CMMC certifies DoD contractors' cybersecurity for FCI/CUI via tiered assessments, while FERPA protects student education records privacy in schools through access, amendment, and consent rights. Organizations adopt CMMC for contracts, FERPA to safeguard funding and trust.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Three cumulative levels aligned to NIST/FAR controls
    • C3PAO and DIBCAC third-party assessments required
    • Mandatory flow-down across DIB supply chains
    • Scoped enclaves for targeted FCI/CUI protection
    • POA&Ms limited to 180-day closures
    Student Privacy

    FERPA

    Family Educational Rights and Privacy Act

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    6-12 months

    Key Features

    • Rights to inspect, amend, consent to PII disclosures
    • Expansive PII definition with re-identification risks
    • Enumerated exceptions like school officials and emergencies
    • Annual notifications specifying procedures and criteria
    • Mandatory recordkeeping of disclosures and requests

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    CMMC Details

    What It Is

    Cybersecurity Maturity Model Certification (CMMC) 2.0 is a DoD certification framework verifying cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It uses a tiered, risk-based model with three cumulative levels.

    Key Components

    • **Three levelsLevel 1 (17 FAR 52.204-21 practices), Level 2 (110 NIST SP 800-171 Rev 2 controls), Level 3 (+24 NIST SP 800-172 enhancements).
    • 14 domains (e.g., Access Control, Incident Response).
    • Assessment via self, C3PAO, or DIBCAC; SPRS/eMASS reporting; limited POA&Ms (180 days).

    Why Organizations Use It

    Mandated for DoD contractors/subcontractors; ensures contract eligibility, reduces supply chain risks, enhances resilience against APTs. Provides competitive edge, operational maturity, and trust.

    Implementation Overview

    Phased approach: scoping/gap analysis, remediation, assessment preparation. Applies to all DIB sizes; requires SSP, evidence collection, annual affirmations, triennial recertification. (178 words)

    FERPA Details

    What It Is

    Family Educational Rights and Privacy Act (FERPA) is a U.S. federal statute (20 U.S.C. § 1232g; 34 CFR Part 99) regulating privacy of student education records. It applies to institutions receiving federal education funds, using a rights-based approach to balance privacy with educational needs.

    Key Components

    • Core rights: inspect records (45 days), amend inaccuracies, consent to PII disclosures.
    • Disclosure rules: prior consent required, 15+ exceptions (school officials, emergencies, directory info).
    • Obligations: annual notices, disclosure logs, vendor controls.
    • No certification; compliance via DOE enforcement.

    Why Organizations Use It

    • Mandatory for funded K-12/postsecondary institutions.
    • Prevents fund loss, lawsuits, reputational harm.
    • Builds family trust, enables secure edtech/data sharing.
    • Supports innovation with controlled exceptions.

    Implementation Overview

    • Phased: governance, data inventory/classification, policies/training, RBAC/security, vendor DPAs, audits.
    • Suits all funded education entities; self-compliance with complaint-based audits.

    Key Differences

    Scope

    CMMC
    Cybersecurity for FCI/CUI in DoD contracts
    FERPA
    Privacy of student education records/PII

    Industry

    CMMC
    Defense Industrial Base contractors
    FERPA
    Educational institutions receiving fed funds

    Nature

    CMMC
    Mandatory certification program
    FERPA
    Mandatory privacy regulation

    Testing

    CMMC
    Self-assess/C3PAO/DIBCAC every 3 years
    FERPA
    Internal audits, complaint investigations

    Penalties

    CMMC
    Contract ineligibility, debarment
    FERPA
    Federal funding withholding, enforcement actions

    Frequently Asked Questions

    Common questions about CMMC and FERPA

    CMMC FAQ

    FERPA FAQ

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