EXECUTIVE SUMMARY: 

This article provides a comprehensive overview to navigating the Cybersecurity Maturity Model Certification (CMMC) assessment and securing your business’ future in the defense industrial base.

• How to prepare for a C3PAO audit: start with a self-assessment, form an internal team, leverage any tools and resources to address gaps, and continue reviewing and updating systems

• What to expect during your audit: document review (SSP, evidence of cybersecurity controls, incident response plans, … etc.), interviews with involved personnel, onsite/remote evaluation, verification of controls, and certification decision
• Audit mistakes to avoid: incomplete documentation, underestimating CMMC complexities and timeline to become compliant, and lack of preparedness

Mastering the CMMC Assessment: A Step-by-Step Guide to Success

Cybersecurity is no longer optional—it's essential, especially in the defense sector. With a surge of cyber threats, businesses working with the Department of Defense (DoD) must take extra measures to protect their sensitive information. But with cyberattacks becoming more frequent and sophisticated, how can companies ensure their data stays secure?

Enter the Cybersecurity Maturity Model Certification (CMMC).

CMMC is a comprehensive security framework built to prepare businesses and protect the defense industrial base (DIB) from cyber threats. More than just a requirement, it’s a strategic advantage that allows companies to maintain their eligibility for DoD contracts and avoid facing penalties for non-compliance.

The stakes are high when it comes to safeguarding the security of our nation's sensitive data, and if your company plans to work with the DoD, you cannot ignore CMMC certification. If you’re just getting started, follow along with this guide to ensure your business masters the assessment (or audit) and achieves the appropriate level of CMMC certification. This guide will walk you through the critical aspects of the CMMC assessment and provide actionable steps to ensure your business is fully prepared to meet the required cybersecurity standards.

What Is a CMMC Assessment?

A CMMC assessment measures a company's compliance with cybersecurity best practices. The assessment is outlined in the CMMC framework, and its primary purpose is to verify that contractors handling sensitive defense information have the necessary controls to protect it.

There are two main types of assessments: self-assessment and third-party audits.

Self-Assessment:

• Conducted internally by the company
• Useful for evaluating current compliance status
• Can be a preliminary step to identify gaps before a formal audit

Third-Party CMMC Audit:

• Provides an objective, external review of the company's security practices
• Performed by a CMMC third-party assessment organization (C3PAO)
• C3PAOs ensure compliance with DoD standards, offering an unbiased assessment

No matter what level of maturity your company wants to reach or whether a self-assessment or third-party audit is required, your business's cybersecurity practices must be evaluated to ensure compliance.

Businesses undergoing the CMMC audit should be ready to pass or fail based on both the documentation and verification of their cybersecurity practices. The audit involves providing detailed records of cybersecurity policies and then demonstrating that those practices are correctly implemented and functioning as intended. Passing the audit will be determined by how well your business meets the compliance requirements, specifically NIST 800-171a rev2 controls and objectives.

Understanding the Levels of CMMC Certification

The CMMC framework is divided into three maturity levels, each progressively building upon the previous one to enhance cybersecurity strength. They’re built this way to give businesses the option to choose the type of projects they want to bid on based on their security level readiness. Level 1 is far easier to achieve than level 3 and can often be less time-consuming and resource-draining. The options provide your business with the opportunity to choose the level and prepare for the certification.

Level 1 – Foundational (17 Controls)

Level 1 focuses on basic cybersecurity practices and safeguarding requirements, outlined in FAR 52.204-21. This level establishes a cybersecurity baseline and suits businesses handling Federal Contract Information (FCI) and working with less sensitive data. Level 1 certification requires an annual self-assessment.

Level 2 – Advanced (110 Controls)

Level 2 signifies an intermediate stage of cybersecurity maturity for businesses handling Controlled Unclassified Information (CUI). At this level, businesses must adopt more advanced measures, like incident response and risk management, outlined in NIST 800-171a rev2. Level 2 certification requires a triennial audit conducted by a C3PAO.

Level 3 – Expert (130 Controls)

Level 3 is the highest tier of CMMC certification, requiring the most comprehensive set of cybersecurity practices. It builds on the requirements of Levels 1 and 2, along with 24 additional controls selected from NIST SP 800-172. Organizations at this level must implement advanced security measures such as continuous monitoring and threat detection. They must also undergo a multi-year government-led assessment to ensure robust protection of sensitive information.

Choosing the correct CMMC certification level depends on the nature of your contract and the type of data you handle. Determine which level is necessary for your business to avoid under- or over-preparing.

Why Your Business Needs a CMMC Audit

For businesses seeking DoD contracts, a formal CMMC audit is essential. This audit verifies that your organization meets the DoD's cybersecurity standards and evaluates your cybersecurity practices, from data handling to security measures in place. It also helps your business identify areas for improving its cybersecurity posture, showing gaps or weak areas.

Failing a CMMC audit can result in significant consequences, such as lost contracts, reputational damage, and sometimes penalties. The negative impact of a failed audit makes it essential for your business to view the audit as a long-term commitment rather than a box-checking exercise.

How to Prepare for a CMMC Level 2 Audit: Best Practices

Preparation is critical to successfully passing a CMMC audit. Here's a step-by-step guide to get you started:

1. Start with a self-assessment: Before engaging a C3PAO, conduct an internal review to identify any gaps in your cybersecurity practices. To self-assess before the formal audit, focus on the CMMC preparation steps that you would likely need to follow with a third-party assessor. This should include reviewing your security controls and documenting any existing practices.
2. Form a CMMC preparation team: Bring together key stakeholders from IT, legal, HR, and facility security officers to oversee your compliance efforts. The certification process is extremely robust and will cover all levels of your organization. For a smooth audit, collaboration between departments is essential to ensure everyone is on the same page and all cybersecurity requirements are met.
3. Use all tools and resources: Leverage any possible cybersecurity software, checklists, and frameworks to streamline the preparation process. Many resources are available to help streamline your audit processes, including contacting a team like ISI for outside assistance.
4. Internal reviews and updates: Continuously evaluate your cybersecurity controls and implement necessary updates. Compliance is not a one-time thing - it requires continuous monitoring and ongoing vigilance.

What to Expect During the CMMC Audit 

If you followed the CMMC preparation steps above and consistently conducted internal and external security reviews, you will be well-prepared for the formal assessment. However, understanding the CMMC assessment process can help ease any lingering uncertainty, even with thorough preparation. Here's a breakdown of the seven typical areas of assessment you should expect:

• Pre-Audit Preparation
• Document Review
• Interviews with Involved Personnel
• Onsite/Remote Evaluation
• Verification of Security Controls
• Certification Decision

Pre-Audit Preparation

Before the formal audit, review all the CMMC related terms and timelines and get your documentation in order. This includes records of your cybersecurity policies, processes, and any self-assessments or internal reviews you've conducted. Many companies undergo a pre-assessment, either internally or through an external consultant, to educate themselves on what’s coming and to identify gaps before the official audit.

Document Review

The assessor will start by reviewing the documentation you provide. This includes evidence of your cybersecurity controls, incident response plans, policies for protecting sensitive data, and System Security Plan (SSP). It's crucial that your documentation aligns with the security practices you have in place and meets the required CMMC level you're seeking to achieve.

Interviews with Involved Personnel

The assessor may interview key personnel to ensure they understand and follow the company's security policies. These interviews can cover various roles, from IT and security teams to management, to confirm that everyone is knowledgeable about their responsibilities in maintaining security protocols.

Onsite/Remote Evaluation

The CMMC assessment can be conducted onsite or remotely. The assessor will verify that the cybersecurity practices outlined in your documentation are implemented and function as expected. They may inspect your IT systems, physical security measures, or network configurations to confirm compliance.

Verification of Security Controls

The assessment involves verifying that the security controls you've implemented meet the level of maturity you're trying to hit. The assessor may test or observe certain practices to confirm that they align with DoD standards.

Certification Decision

After the assessment, the assessor submits the results for review. You will receive a certification if your company meets the required standards for the desired CMMC level. If gaps are found, you may need to address them and undergo a re-assessment before receiving certification.

Common CMMC Audit Mistakes to Avoid

CMMC certification is not a walk in the park. It requires time, effort, and collaboration across your entire organization. You can't expect to be ready without thorough preparation. Failing to take the process seriously can lead to costly mistakes during the audit. Avoid being one of those companies by staying proactive and avoiding these common pitfalls.

• Incomplete Documentation: Don't show up without all of your ducks in a row. Your documents need to be up to date and readily available for assessors. This process can be very time-consuming, so if even one piece of documentation is missing, you could delay it and set your timeline back.
• Underestimating the Complexity: The CMMC framework can be complex, and it's easy to underestimate the preparation required. Set realistic timelines and deadlines so you’re not playing catch up or getting overwhelmed. Last, make sure you and your team are familiar with the specifics for each requirement. For example, while most know NIST 800-171 a rev 2 has 110 controls, few realize that each control has a number of objectives. For Level 2, there are a total of 320 objectives to achieve compliance. 
• Lack of Preparedness: Do not wait until the last minute. Proactively plan your next move and seek expert guidance if needed. Very few contractors are compliant at the start of their journey - almost all have some level of remediation that needs to be completed ahead of their C3PAO audit. It is recommended to start your compliance journey at least six months ahead of your scheduled audit.

Your CMMC journey might not be perfect, but that's okay. If you’re prepared and give yourself a long enough runway to create and organize the required documentation, you can ensure a smoother, more successful audit process.

Post-Assessment: Maintaining Compliance After the CMMC Audit

You passed the assessment and received your maturity level! What a relief—you can now put it all behind you, right?

Wrong!

Passing the CMMC audit is only the beginning. After you’re certified, you must remain vigilant and engage in continuous compliance efforts to maintain your certification. This includes regular internal audits, updating cybersecurity measures, maintaining all associated policies and procedures, and providing ongoing security training for staff.

The CMMC framework is still evolving, and to continue to be certified and work with secure information, you need to stay ahead of any new requirements or updates. Implementing cybersecurity standards into your company culture ensures long-term compliance and readiness for future assessments.

Master Your Assessment with ISI

The CMMC assessment is more than just a compliance requirement—it's an opportunity to enhance your company's cybersecurity. Your business can ensure long-term security and compliance by understanding the CMMC levels, preparing thoroughly, and conducting regular self-assessments.

Success in the CMMC assessment requires commitment, organization, and continuous engagement with your cybersecurity practices. With ISI's guidance, you'll be equipped to navigate the process confidently and achieve the certification your business needs to thrive in the defense sector. Reach out to us today and let's get started! 

Frequently Asked Questions about the CMMC Assessment

Who Issues CMMC Certification?

CMMC Level 2 certification is issued by C3PAOs, CMMC third-party assessment organizations, after thoroughly assessing a company's cybersecurity practices.

What Is CMMC Self-Assessment?

A CMMC self-assessment is a review that businesses can conduct internally to gauge their current cybersecurity readiness before undergoing a formal third-party audit.

How Long Does a CMMC Assessment Take?

The duration of a CMMC assessment can vary depending on the complexity of a business's operations and the level of maturity the company is trying to achieve. An evaluation and preparation can typically take a few weeks to several months.

Is CMMC Replacing NIST?

No, CMMC is not replacing NIST (National Institute of Standards and Technology). Instead, CMMC incorporates NIST standards into its framework to enhance cybersecurity requirements.