What Does “Good Enough” Look Like in CMMC?
Executive Brief
CMMC assessments are not always black and white. Requirements can leave room for interpretation—and that's where many DoD contractors get stuck.
A Managed Service Provider (MSP) can help bridge the gap between interpretation and compliance—giving organizations the confidence and clarity needed to pass their assessments and secure long-term contract eligibility.
Here’s what defense contractors need to know:
- CMMC requirements often include subjective language like “adequate” or “as needed,” making interpretation a challenge.
- “Good enough” means meeting the intent of a control with appropriate implementation, documentation, and justification.
- MSPs, like ISI, can help interpret ambiguous language to help your business meet all 110 controls and achieve certification
Understanding the “Gray Areas” in CMMC
The Cybersecurity Maturity Model Certification (CMMC) framework is structured, but many of its controls include language like “as needed,” “adequate,” or “reasonable.” These terms introduce ambiguity into what should otherwise be a technical, checklist-driven process.
CMMC compliance, especially at Level 2 (aligned with NIST SP 800-171), requires not just technical implementation—but documentation and justification of your approach. For smaller or resource-limited contractors, that’s easier said than done.
So What Is “Good Enough”?
In CMMC, “good enough” means that the way your business implemented the controls meets the intent of the requirement—and that you can prove it. This doesn’t always mean perfect or enterprise-grade implementation, but it does mean:
- The control is implemented and operating effectively
- There is documented rationale for your decisions
- You can demonstrate that it mitigates risk to federal information systems
Example: For log retention, CMMC doesn’t specify an exact timeframe—but your organization might choose 90 days based on risk and document that rationale. That could be considered “good enough” if it aligns with your environment and is consistently applied.
How MSPs Help You Prepare for CMMC Assessments
CMMC assessments can feel like you're aiming at a moving target. MSPs bring industry context, experience, and structure to help you aim true. Here’s how they help:
Contextual Expertise
MSPs work with contractors across the Defense Industrial Base and know how assessors are interpreting requirements in practice. This insight helps ensure your implementation aligns with what assessors typically accept.
Pre-Assessment Readiness Checks
Before undergoing an official assessment, many MSPs conduct mock audits or readiness assessments. These simulate real assessment conditions and help pinpoint controls that need strengthening or clarification.
Evidence Development
Knowing a control is in place isn’t the same as proving it. MSPs help you collect, organize, and present evidence that aligns with assessor expectations—whether it’s log files, user access lists, or written procedures.
Risk-Based Tailoring
Every organization is different. MSPs help you tailor your implementation based on risk, size, and operational needs. This helps avoid over-engineering while still meeting CMMC standards.
Why This Matters for DoD Subcontractors
Misinterpreting or underestimating a requirement could lead to audit failure, added costs, or delays in the contract award. Overcompensating could mean wasted time and budget. MSPs reduce the guesswork, helping ensure that:
- Your implementation aligns with your environment
- Your controls are defensible
- You’re ready for both self-assessments and third-party audits
For DoD subcontractors aiming to grow in the defense industrial base, achieving and maintaining CMMC compliance is essential.
Partner with ISI to Interpret “Good Enough”
At ISI, we understand the unique compliance pressures faced by defense contractors. As a CMMC Level 2 certified organization, our team is well-equipped to help you bridge the gap between compliance intent and implementation reality.
From readiness assessments to documentation development, we’ll help ensure you’re not just compliant, you’re confident.
FAQs About CMMC Assessments and MSS Providers
Is “good enough” a formal designation in CMMC?
No, but it reflects whether your control meets intent and can be justified and evidenced to an assessor.
Do all companies need MSP support to pass CMMC?
Not necessarily—but MSPs can offer significant advantages in understanding the nuance behind certain requirements as well as potential cost savings (i.e. smaller overhead, preferred pricing for software licensing, ... etc.).
Can I rely on internal IT staff to interpret the gray areas?
If your internal team has the necessary budget, staffing, and compliance experience, they may be able to manage. But many contractors benefit from external validation and guidance.
What’s the risk of over-implementing a control?
Over-implementation can waste resources, introduce unnecessary complexity, and still miss the mark if not properly documented. For example, a small contractor might deploy an expensive enterprise Identity and Access Management system when simple access controls and Multi-Factor Authentication would suffice. If it’s not aligned with your size or risk profile or isn’t well documented, it may still fail to meet CMMC expectations.
