Securing Higher Education: The Importance of CMMC Compliance
Doug Landoll • February 10, 2025
Higher education institutions performing research and other partnerships with Federal Government agencies are relied upon for insights and advancements but also for their ability to secure sensitive data associated with this work. For over a decade the Federal Government has relied upon contractual agreements and self-assessments to confirm that strict cybersecurity controls were in place. However, such self-assessments have proven inadequate and have resulted in weak security controls, sensitive information leakage, and even lawsuits charging false claims against universities for failure to implement contractual obligations.
Enter the Cybersecurity Maturity Model Certification (CMMC)—a framework designed to ensure robust cybersecurity practices and independent review of their implementation across the supply chain. For higher education institutions, understanding and implementing CMMC is not just a matter of compliance but a necessity for long-term success.
The Importance of CMMC
Higher education institutions often serve as hubs for federally funded research and development. These projects frequently involve sensitive information that must be safeguarded from malicious actors. Understanding CMMC and its implications on higher education is crucial for several reasons:
- Critical Deadline: December 16, 2024
On this date, the final rule for CMMC went into effect, making compliance mandatory for any organization handling controlled unclassified information (CUI) or pursuing Department of Defense (DoD) contracts. For higher education institutions, this deadline solidifies the importance of aligning with CMMC to maintain eligibility for government research grants and contracts. - Protecting Federal Research and Contracts: Many universities conduct research funded by the DoD. CMMC compliance ensures they remain eligible for these critical projects.
- Building Trust with Stakeholders: Compliance with CMMC demonstrates a commitment to safeguarding data, fostering trust with government agencies, private sector partners, and the broader academic community.
- Reducing Cyber Risks: Universities are prime targets for ransomware, intellectual property theft, and espionage. CMMC provides a structured approach to mitigate these risks.
Why It Is Important
The higher education sector is no stranger to cyberattacks. From ransomware to phishing schemes, the threats are constant and evolving. For institutions managing sensitive government contracts, the stakes are even higher. Non-compliance with CMMC after December 16, 2024 can result in:
- Loss of Funding: Failure to meet CMMC standards could lead to the loss of lucrative research contracts and grants.
- Reputation Damage: A cybersecurity breach can erode trust and damage an institution’s reputation, affecting enrollment and partnerships.
- Increased Liability: Universities that fail to secure sensitive data may face legal and financial repercussions.
What Higher Education Institutions Can Do
So, how can your institution prepare for CMMC compliance? Here’s a roadmap to get started:
- Train Your Workforce - Ensure that your organization fully understands how to recognize areas that need to be secured, the CMMC requirements, and how to get started.
- Complete a CMMC Readiness Assessment - Work with a CMMC expert to identify your sensitive data (FCI and CUI), inventory assets, create network and data flow diagrams, and limit assessment scope through architecture.
- Complete a CMMC Self-Assessment - Assess each of the control requirements against your implementation. Determine remediation measures.
- Implement Missing Critical Controls
- Access Management: Ensure that only authorized personnel can access sensitive systems.
- Multi-Factor Authentication (MFA): Add an extra layer of security to user accounts.
- Data Encryption: Protect data at rest and in transit with encryption protocols.
- CMMC
- -
- specific Documentation
- : policies (e.g., access control, awareness and training), Plans (e.g., System Security Plans, Incident Response Plan, Contingency Plan), and other documents (e.g,., list of authorized users, facility diagram, risk mitigation procedures).
- Engage the appropriate Professional (e.g., for Level 2 a Certified Third-Party Assessment Organization (C3PAO) to perform a CMMC certification assessment.
Conclusion
The December 16, 2024, CMMC deadline underscores the urgency of preparing now. Compliance is more than a regulatory requirement—it’s a commitment to safeguarding the future of higher education. By taking proactive steps to secure systems and data, universities can protect their research, reputation, and partnerships. Don’t wait for a cyber incident to take action. Start your CMMC journey today and ensure your institution is prepared for the challenges ahead.
In a higher education world where cybersecurity, data protection and data privacy activities are bathed in multiple regulations, policies, procedures, standards and all the rest, what happens when victims claim, “compliance is just not good enough”? The answer can be quite costly. The March 2025 data breach incident at the Yale New Haven Health System (https://www.ynhhs.org/legal-notices) could potentially be such a case. Yale New Haven Health reported a data breach incident to the public on March 11, 2025, and a pair of 52-page federal lawsuits were filed on behalf of victims were already filed just over a month later. There are reports that as many as six additional suits were filed in the following days. A variety of law firms have created web pages where victims can seek legal engagement, so the number of suits could potentially increase. It does not appear Yale New Haven Health is being accused of specifically failing to meet a given governmental regulation – such as HIPAA, PCI, GLBA, or a state breach notification law. The fact that a generic notification letter about the incident can be found at the Massachusetts Office of the Attorney General website implies at least that state’s requirements have been met. But according to the Hartford Business Journal (https://www.hartfordbusiness.com/article/yale- new-haven-health-faces-lawsuits-over-data-breach-health-system-discloses-more-details), the suit claims Yale New Haven Health did not “…properly secure and safeguard Plaintiff ’s and Class Members’ sensitive personally identifiable information (PII) and personal health information (PHI), which, as a result, is now in criminal cyberthieves’ possession.” These lawsuits understandably infer that provider storing sensitive or confidential customer needs to use a portion of its revenue to fund customer data protection measures. The goal should be protecting data even beyond regulatory compliance demands. A Big Year For Settlements Beyond the question of governmental regulations and their relationship to lawsuits, there is no doubt higher education is suffering increased direct financial penalties resulting from data breaches. Just one example from 2025 is the $2 million settlement of the class action data breach lawsuit against St. Louis University and SSM Health Saint Louis University Hospital from mid-April, stemming from the data breach of up to 93,000 individuals (https://www.hipaajournal.com/saint- louis-university-data-breach-lawsuit-settlement/). Besides the common practice of receiving identity theft protection benefits, claimants can receive up to $2,500 in unreimbursed expenses resulting from the breach. St. Louis University and SSM Health Saint Louis University Hospital are not alone, as various similar suits are on schedule to be settled later in 2025. Large or small, public or private, no institution appears immune. Too Early? Too Late? Another new lawsuit is among those that confront the long-debated ”time to notify the victims” issue. Michael Harris, a potential incoming student at Lee University, filed the suit against Lee in the U.S. District Court Eastern District of Tennessee (https://www.local3news.com/local-news/lee-university-sued-for-negligence-after-data-breach-impacts-thousands/article_ca5ecb44- 8872-4692-9dd8-4ce35defe574.html). The lawsuit includes multiple complaints, among them is the claim that Lee waited for more than one year to notify the impacted individuals. One could argue notifying potential victims before all facts are known runs the risk of providing incomplete information. But waiting for an investigation to complete runs the risk of victims suffering the consequences of the breach without even knowing a breach of their information occurred. Damage Over Dollars? Of course, data breaches are often about a lot more than money. They hold the potential to devastate victims by inflicting non-economic temporary and sometimes even permanent damage. The recent takeover of the New York University (NYU) website by a hacker who briefly exposed NYU applicant information datasets back to 1989 (https://nyunews.com/news/2025/04/01/nyu-data-breach-lawsuits/) serves as a reminder. Public policy – often via regulation – tries to limit the damage by requiring those who house sensitive and confidential data adhere to strict standards. But higher education institutions need to know that compliance with all regulations and data breach laws might not be enough. These large settlements should provide institutions with a constant reminder. Bill Balint is the owner of Haven Hill Services LLC, contracted as Trivigil’s Advisory CIO for Education.
TriVigil is dedicated to providing educational institutions with comprehensive cybersecurity solutions that harmonize people, policies, and technology. This commitment includes highlighting selected opportunities where cybersecurity and privacy professionals in the education sector can network, learn, meet with solutions providers and gain other insights. There are literally hundreds of cybersecurity and data privacy events – local, regional, national, international and virtual. Everything from a one-hour webinar to global large-scale events with thousands of attendees. Some are purely focused on cybersecurity and/or data privacy, while others list these as merely a sub-interest or track. Some emphasize the education sector, while others do not focus on any specific industry. Among the plethora of quality events blanketing every area of interest, TriVigil notes a pair of late spring 2025 events that include education as a specific focus. The 2025 Educause Cybersecurity and Privacy Professionals Conference will take place in Baltimore May 19-21 ( https://events.educause.edu/cybersecurity-and-privacy-professionals-conference/2025 ). It is perhaps higher education’s best-known event focused solely on these topics. This year’s “Stronger Connections for Stronger Protections” theme is evident in all five attendee tracks: · Awareness, Education, and Human Factors · Governance and Strategic Alignment · Transformational Leadership · Navigating Compliance with Confidence · Evolving Technologies and Practices With the emphasis on collaboration, it is fitting the 2025 conference is efficiently expanded such that a small increase in time spent onsite provides a large increase for attendee opportunities. The opening pre-conference workshop day remains from previous years (May 19), but the opening general session has been moved to the end of the first day, as well. This change allows for breakout sessions to begin immediately on the second day (May 20). The third day (May 21) has been extended to a full day agenda. May 19 opens with eight preconference workshops. These include two full-day, three morning half-day and three afternoon half-day options. Derrich Phillips, founder of Aspire Cyber and of the CMMC Professionals Network (CPN), provides the opening general session entitled “Beyond the Firewall: How Community Strengthens Cybersecurity in Higher Education”. May 20-21 should also be a treat as attendees can take advantage of 12 breakout session time slots, each 45 minutes in length. This is especially impressive as there are conferences twice as long that struggle to offer that many breakout session slots. Furthermore, the agenda also provides three separate times for attendees to take part in poster sessions. The conference concludes with a closing general session. Better than 45 breakout sessions spread across those 12 timeslots will be delivered in presentation and panel discussion formats by representatives from about 40 different institutions and some 20 solutions providers. Presenters and panelists from institutions span large R1 institutions and state system offices to small liberal arts schools, community colleges and those in between. 2025 NICE Conference and Expo The 2025 NICE Conference & Expo will take place in Denver on June 1-3, 2025 ( https://niceconference.org/ ). The conference touts itself as “… the annual convening of community members and thought leaders from education, government, industry, and non-profits to explore ways of developing a skilled cybersecurity workforce ready to meet the challenges of the future.” NICE itself is a program led by the National Institute of Standards and Technology (NIST), established by the Cybersecurity Enhancement Act of 2014. Florida International University is a conference co-host, further underscoring the important role of higher education at the event. New America, a non-profit think tank, serves as the conference’s other co-host. This year’s “Climbing Higher: Educating & Sustaining a Resilient Cybersecurity Workforce” theme would appear very relevant for a higher education sector challenged with talent acquisition and employee development. This is especially true with the internal cybersecurity workforce. The event opens with half-day afternoon workshops on June 1, with the conference running for two full days on June 2-3. Although the list of sessions is not available yet, a glance at the 2024 agenda indicated eight breakout session timeslots and five plenary slots in addition to the pre-conference workshops. Over 30 breakout sessions in 2024 were delivered by a mix of academia, government and industry representatives. Bill Balint is the owner of Haven Hill Services LLC, contracted as TriVigil’s Advisory CIO for Education.
While National Cybersecurity Month (October) and National Data Privacy Week (late January) seemingly growing in adoption, a couple of more-recent cybersecurity events will hopefully take that next step. AI Fools Week (Naturally Kicking off ‘AI’pril) The good folks over at the National Cybersecurity Alliance (NCA) have created their inaugural artificial intelligence (AI) awareness campaign, fittingly entitled “AI Fools Week”, taking place the Week of March 31 ( https://www.staysafeonline.org/aifools ). NCA even jokingly refers to the month as “AIpril”. As is often the case, NCA offers a very well-done toolkit of tip sheets, infographics, posters, etc. for those looking to initiate a ‘be safe when using AI” campaign at their institution or place of business. One of the NCA toolkit’s more ironic, but interesting ideas is to leverage a concept dating back to Ancient Greece by creating a shared password (safe word) to combat “deepfake” voicemails, messages, even video calls. The kit suggests safe word systems are worthy for consideration beyond families – such as with fellow employees, close friends, caregivers and groups reliant upon virtual communication. Identity Management Day 2025 Identity Management Day 2025 ( https://www.idsalliance.org/event/identity-management-day-2025 ) will take place immediately after AI Fools Week on April 8. The awareness focus is a free, day-long online conference. The NCA and the Identity Defined Security Alliance play host to the event, which started in 2021. Of course, adhering to safe computing practices in this rapidly changing landscape is a 365-day per year battle (366 during leap years - LOL). Some might consider it impossible to avoid deepfakes for long because so much is beyond the individual’s control – especially in a GenAI world. But the silver lining is any improvement in protection is a positive and the event is geared toward promoting best practices. Higher Education Cybersecurity Digital Magazines Awareness days and weeks are nice and all, but this is also a daily effort where timely, helpful information made available within a few clicks is a vital asset. This is one way digital magazines can make a difference. Higher education might increasingly be operating ‘like a business’, but access to information from those who understand the unique higher education environment remains a plus. Fortunately, higher education cybersecurity professionals can find plenty of education-specific content without cost. It is true the mix of public sector, non-profit and for-profit websites are valuable. But targeted digital magazines also provide critical additional insight. Though not a comprehensive review, three sites appear to be among the leaders in this space. EdTech magazine’s cybersecurity site ( https://edtechmagazine.com/higher/security ), for example, published nine (9) new articles during a recent three-month period, featuring diverse topics like identity and access management (IAM), student BYOD security challenges, AI, and the age-old technical debt implications for security and privacy. Each article places the material into a higher education-centric context. One specific nice feature is the site’s article filtering, which allows readers to deep dive into 14 sub-topics in an instant. Campus Technology magazine has been a friend to the higher education IT community for some 35 years (known as Syllabus from 1988-2004 before adopting its current name). Cybersecurity has been part of its content for multiple decades and its website touts a cybersecurity portal ( https://campustechnology.com/Portals/Cybersecurity.aspx ) full of articles, podcasts, webcasts and whitepapers. The site included 10 articles in a recent 90-day timeframe and these included information about subjects ranging from AI, Educause HECVAT’s release, Jamf’s purchase of Identity Automation, etc. Education Technology Insights ( https://www.educationtechnologyinsights.com ) offers content spanning the education sector, with a focus on “…bringing forth a complete picture of how teachers are using different classroom technologies…”. Although there does not appear to be a cybersecurity-specific part on the site, there is plenty of content found via a general search. There are loads of higher education-focused sites that offer cybersecurity content, but most do not have it as a specific focus area. Inside Higher Ed, University Business, and GovTech are just a few. Of course, there are also many cybersecurity digital magazines that cut across all industries and certain content has implications for the education sector. Bill Balint is the owner of Haven Hill Services LLC, contracted as TriVigil’s Advisory CIO for Education.