Determining Your CMMC Readiness

The SSP is the cornerstone of your compliance efforts. It outlines how your organization's IT systems protect Controlled Unclassified Information (CUI). This document should include:

• System boundaries: Clearly define which systems are in scope for CMMC.
• Network diagrams: Show how data flows within your organization and where security controls are applied.
• Implemented controls: Describe how each NIST SP 800-171 control is addressed.
• Responsibility matrix: Assign roles and accountability for each control.

A well-written SSP should be comprehensive yet concise, detailing your cybersecurity posture in a way that is easily understandable by assessors.

ISI INSIGHT: If you have policies and procedures in multiple documents, link the other applicable documents in your SSP when describing a security measure. This will help keep you organized and save time during the audit.

While a POA&M cannot replace full compliance for certification, it is an essential readiness tool. If you undergo a CMMC audit by a C3PAO without every security control yet fully in place, a good POA&M could mean the difference between failing your audit and achieving conditional compliance.

Your POA&M should list:

• Identified deficiencies: Gaps in compliance uncovered during self-assessments or audits.
• Remediation steps: Specific actions to address each gap.
• Timelines: Deadlines for closing gaps.
• Resource allocation: Who is responsible for each remediation task and what resources are required.

POA&Ms help your organization stay on track as you work toward full CMMC compliance.

These records provide real-time evidence of security control implementation. They include:

• Access logs: Track who accessed systems and data and when.
• Change management logs: Document alterations to critical systems or configurations.
• Incident logs: Record security breaches, attempted attacks, or anomalies.

Ensure these logs are properly maintained and protected to preserve their integrity.

These documents ensure consistency and security in system settings. Include:

• Baseline configurations: Specify approved settings for hardware and software.
• Change control logs: Track all updates and modifications to systems.
• System inventory: Maintain an up-to-date list of all assets, including hardware, software, and licenses.

Configuration management ensures systems remain compliant as they evolve.

Regular risk assessments and testing demonstrate proactive identification and mitigation of vulnerabilities. Keep records of:

• Vulnerability scans: Results from tools like Nessus or Qualys.
• Penetration testing reports: Summaries of simulated attacks and their outcomes.
• Risk assessment reports: Documentation of identified risks, their severity, and mitigation plans.

These reports are key to demonstrating a proactive approach to security.

Document all instances of CUI in your systems. Include:

• Data inventory: Where CUI is stored, processed, and transmitted.
• Data flow diagrams: How CUI moves through your network and who has access to it.

These tools clarify how CUI is handled and help ensure its protection throughout its lifecycle.

CMMC extends compliance responsibilities to your supply chain. Be sure to keep records of your Service Level Agreements (SLAs), contracts with vendors that handle CUI, and subcontractor compliance attestations to show your partners are also CMMC proficient.

Many organizations struggle to accurately identify what constitutes CUI within their systems. Some believe that all data handled in a defense contract is considered CUI, while others assume none of their data qualifies. This can result in either overestimating or underestimating the scope of compliance efforts.

Review the DoD's CUI registry: this official resource lists categories of CUI and clarifies its definition. If you're a subcontractor, ask your prime contractor to specify what data qualifies as CUI. Then conduct a thorough review of your data systems to identify where CUI resides and how it flows.

Proper identification ensures that security measures are applied only where necessary, avoiding both overreach and non-compliance.

Many organizations assume that achieving compliance will only take weeks rather than  several months, only to find themselves scrambling when deadlines approach.

That’s why you should start early, engage External Service Providers (ESPs) like Managed IT or expert CMMC consultants, and create a realistic timeline that allows for assessments, gap remediation, control implementation, and unexpected delays.

Organizations often rely too heavily on POA&M documents, assuming that incomplete compliance can be excused with a robust POA&M. CMMC 2.0 requires all controls to be fully implemented for certification. A good POA&M can guide readiness and even help you achieve conditional compliance, but it cannot replace actual compliance and you’ll only have 180 days to remediate the controls that haven’t been met and pass a POA&M closeout assessment.

Instead, address high-risk deficiencies first to ensure key controls are operational and use POA&Ms as interim tools. Employ them for internal tracking and readiness assessments, but ensure all gaps are closed before engaging a Certified Third-Party Assessor Organization (C3PAO).

Many organizations lack the technical expertise or dedicated personnel to manage compliance efforts effectively, assuming that existing IT staff or generalists can handle the complexities of CMMC requirements. Consider engaging consultants, Registered Practitioners (RPs), or Managed IT providers to fill knowledge gaps. Otherwise, you’ll have to develop in-house expertise through training or hiring professionals familiar with NIST 800-171 and CMMC standards.

Subcontractors often fail to recognize their responsibility for ensuring downstream partners meet compliance requirements, assuming that compliance is only a concern for prime contractors.

Collaborate with your subcontractors to verify that all partners handling CUI are meeting the required standards, include compliance obligations and flow down requirements:  in contracts with subcontractors, and regularly review subcontractor practices to ensure ongoing adherence.