CMMC Compliance: It’s Actually Happening

Prepare for Assessment

The most important component of CMMC compliance is scoping; an accurate and tight scope is essential. Inaccurate scoping in a CMMC assessment can lead to significant operational, financial, and contractual consequences for an organization. If the scope is too narrow or incomplete, critical systems, assets, or processes may be left unassessed, resulting in a failure to meet the required CMMC level. This can lead to certification denial, delaying, or preventing eligibility for DOD contracts, which could severely impact revenue and reputation. Conversely, an overly broad scope may lead to unnecessary assessments, requiring additional time, resources, and money to evaluate systems or processes that are not relevant to the actual requirements. Such mismanagement wastes valuable resources and can inflate costs unnecessarily.

When the scope excludes key systems or processes that handle CUI or FCI, the organization risks non-compliance with contractual terms. This non-compliance could result in penalties, contract termination, or the loss of future DOD opportunities. Additionally, an improperly scoped assessment increases the likelihood of overlooking critical vulnerabilities, which could lead to data breaches or unauthorized access to sensitive information. Such incidents can damage trust, attract regulatory scrutiny, and incur financial penalties. An incorrect scope also often necessitates reassessments, further increasing costs, delaying contract awards, and creating administrative burdens. Moreover, repeated errors in managing the assessment process can harm the organization’s reputation, signaling poor oversight to both the DOD and other stakeholders.

To prevent these issues, organizations must conduct a thorough scoping exercise before the assessment, ensuring that all relevant systems, assets, and processes that handle sensitive information are identified. Engaging experienced consultants or assessors to validate the scope and documenting decisions to align with DOD and CMMC guidelines can help avoid costly errors. Proper scoping is essential for successful certification, protecting the organization’s compliance status, and maintaining trust within the DOD supply chain.

Optimizing Your CMMC Compliance

Once you determine that you are required to meet CMMC compliance, how do you complete your assessment? Should you keep it in-house, leveraging your existing resources, or bring in outside expertise through a contractor? There is no right answer; each situation depends on your team’s expertise, the complexity of your needs, and how quickly you need to gain compliance.

Start by evaluating your in-house expertise. Do you already have a team with deep knowledge of cybersecurity frameworks like NIST SP 800-171 and experience with compliance audits? If so, you may have the foundation to manage CMMC internally. This is particularly true if your needs are straightforward—say, achieving Level 1 compliance, which involves basic cyber hygiene practices for handling FCI. But if your staff is unfamiliar with CMMC’s nuances or has little experience managing compliance for sensitive information like CUI, you are likely setting yourself up for complications. Contractors often bring not just expertise but also tools and streamlined processes that can help you avoid costly mistakes.

Resource availability is another critical consideration. Even if your team has the necessary knowledge, do they have the time to focus on compliance without neglecting other responsibilities? Managing CMMC compliance requires a detailed assessment of your systems, policies, and processes, followed by implementing controls, documenting them, and preparing for an assessment. In addition, CMMC is not one-and-done; it must be continually monitored and audited every three years, with an annual attestation of compliance from a senior member of your company. This level of effort can be a burden for already stretched IT or compliance teams. Contractors, on the other hand, can take on the heavy lifting, allowing your internal staff to stay focused on their core responsibilities.

The complexity of your compliance needs plays a significant role in this decision. If your organization requires compliance with Level 2 or Level 3, where robust protections against advanced persistent threats are required, the stakes are higher. These levels involve extensive security controls, mature processes, and often government-led audits, making outside expertise invaluable. For simpler compliance needs, managing in-house may be more realistic.

Of course, there’s the question of cost. Managing compliance internally might seem like the cheaper option, but it’s not without its own expenses. Training your team, purchasing new tools, and reallocating staff can add up. Contractors, while requiring upfront investment, bring efficiency and a higher likelihood of success, potentially saving you the costs of failed assessments or the need for reassessments. If you’re working under a tight deadline to secure a DOD contract, a contractor’s ability to accelerate the process might outweigh the initial cost.

A note on contractors: not all contractors are created equal. No one can sell you an easy button for CMMC. No one can get you compliant in two weeks. We recommend reviewing the Cyber AB (the official accreditation body for CMMC) marketplace for registered organizations. They have full lists of certified third-party assessment organizations, registered practitioner organizations, CMMC certified professionals, and CMMC certified assessors, organized by categories like region or service scope. Speaking of region, finding a local servicer may save money (Level 2 certification will require boots-on-the-ground assessing), and they may also understand your needs and environment more readily.

Ultimately, this decision comes down to weighing the risks and resources. If you have the time, knowledge, and staff to manage compliance effectively, an in-house approach might be a good fit. But if your organization is facing tight timelines, complex requirements, or limited internal expertise, hiring a contractor could be the key to a smoother, faster path to certification. For many organizations, a hybrid approach works well—handling simpler aspects internally while outsourcing the more complex tasks to a trusted expert.

Documenting Policies and Procedures

One of the most daunting parts of a cybersecurity and compliance project like CMMC is the amount of documentation required, particularly for Levels 2 and 3. The primary document that is required by CMMC is a System Security Plan (SSP), which is considered your security road map. An SSP describes your assessment scope at a high level and has a section for each control describing your implementation details. The idea behind an SSP is that it defines your information security program, and anyone who reads it can understand what you’re doing and how. A typical SSP can easily approach 100 pages, even for a small organization.

While an SSP is the only document explicitly required for CMMC, passing or even initializing an assessment will require many more policies and procedures. To demonstrate that you meet the requirements of CMMC, a typical organization must have other policies addressing security domains such as, but not limited to, access control, configuration management, and change management as well as the procedures to back them up.

Consider this example. A policy requirement is derived from a particular control, e.g., “system access is limited to authorized users.” The term “authorized” further raises the questions, “Who is an authorized user? How do they get authorized? By whom are they authorized?” This list of sub-queries can be lengthy and indeterminate, but these considerations must be dealt with in your policies and procedures.

Prior to a full assessment, assessors must review your documentation to ensure that you have a well-defined information security program. This step ensures that you have enough information available for an assessment to take place. At the end of this review, the assessor will determine whether the assessment should proceed as planned, be rescheduled, or, in the worst case, cancelled. Poorly organized and incomplete documentation is the greatest risk to having your assessment postponed or canceled. This, coupled with the large volume of companies trying to get assessed and the currently low number of assessors, can mean a significant delay in your certification if items are not in order. Careful and meticulous assessment preparation might seem like a lift, but it is well worth the time to stay on track.

Prepare for CMMC Now

Business leaders in the DIB space often say they don’t think these CMMC requirements are going to stick or that most of the work is “complete” so they should be audit ready in a couple of weeks. Unless you have previously completed an assessment or have been advised by an organization that has completed assessments in the past, this may not be the case. Don’t underestimate the amount of work that is required to prepare for an assessment!

Working with a knowledgeable, local firm as soon as it makes sense for your organization can only benefit you in the long run. Additionally, even if you don’t have any current DOD contracts but are considering them for future work, now is the time to get started.

As the CMMC rules continue to roll out, staying informed and proactive is more critical than ever. As the ecosystem continues to grow, the Cyber AB is being split into two separate organizations: the Cyber AB and the Cybersecurity Assessor and Instructor Certification Organization. The goal is for CMMC to not only assess subcontractors but to also replace cybersecurity requirements for other government entities.

This is important for two reasons. First, it is likely that this split heralds a new slate of requirements that extend far beyond DOD contracts and into other sectors of the federal government. In other words, just because CMMC does not apply to you today does not mean that it (or something similar) will not be required in the future. Second, finding a good news source like the Cyber AB to stay informed about updates in this space is crucial to maintaining your competitive edge when attempting to procure contracts.