1. Understanding Basic Safeguarding Requirements for FCI in CMMC Level 1
Federal Contract Information (FCI) is defined as information provided by or generated for the government under a contract that isnot intended for public release.
CMMCLevel 1is designed to ensurebasic safeguardingof FCI, aligning with15 security requirementsfound inFAR 52.204-21 (Basic Safeguarding of Covered Contractor Information Systems).
Contractors handlingonly FCImust meetCMMC Level 1, which alignsdirectlywith the safeguarding requirements set inFAR 52.204-21.
2. FAR 52.204-21 and Its Role in CMMC Level 1 Compliance
FAR 52.204-21establishes the baseline cybersecurity controls that contractors must implement to protectFCI.
The15 basic safeguarding requirementsinclude:
Limiting information accessto authorized users.
Identifying and authenticating usersbefore allowing system access.
Protecting transmitted FCIfrom unauthorized disclosure.
Monitoring and controlling connectionsto external systems.
Applying boundary protectionand cybersecurity measures.
Sanitizing mediabefore disposal.
Updating security configurationsto reduce vulnerabilities.
Providing physical securityprotections.
Controlling physical accessto systems that process FCI.
Enforcing multi-factor authentication (MFA) where applicable.
Patching vulnerabilitiesin software and hardware.
Limiting the use of removable media.
Creating and retaining system audit logs.
Performing risk-based security assessments.
Developing an incident response plan.
These 15 practices form thefoundationof CMMCLevel 1 Self-Assessment, ensuring contractorsmeet minimum cybersecurity expectationsfor handling FCI.
3. Why the Other Options Are Incorrect
B. 22 CFR 120-130:
This refers toInternational Traffic in Arms Regulations (ITAR), which controls the export of defense-related articles and services,notFCI safeguarding requirements.
C. DFARS 252.204-7011:
This clause refers toalternative line item structuresand does not pertain to cybersecurity or safeguarding FCI.
D. DFARS 252.204-7021:
This clause enforcesCMMC requirementsbut doesnot definebasic safeguarding controls. It requires compliance with CMMC but does not specify the foundational requirements (which come fromFAR 52.204-21for Level 1).
4. Official CMMC 2.0 Reference & Study Guide Alignment
TheCMMC 2.0 model documentationconfirms that Level 1 is focused on the15 practices from FAR 52.204-21.
TheDoD’s official CMMC Assessment Guidefor Level 1 explicitly states that meeting FAR 52.204-21 is therequirement for passing a Level 1 Self-Assessment.
TheCMMC 2.0 Scoping Guideclarifies that contractors handling onlyFCIand seekingLevel 1 certificationmust implementonly FAR 52.204-21security controls.
Final Confirmation:The correct answer isA. FAR 52.204-21, as it directly governs the basic safeguarding ofFCIand is the foundational requirement for aLevel 1 Self-Assessmentin CMMC 2.0.
