Undertaking a Cybersecurity Maturity Model Certification (CMMC) assessment is an essential step for defense contractors seeking CMMC compliance. Through these comprehensive audits, you can uncover vulnerabilities in your cybersecurity architecture and implement the relevant controls to align with CMMC requirements.  

However, conducting a CMMC assessment is far from easy. Even for organizations with a handful of assets handling sensitive information, proper planning is imperative to ensure the success of each audit process.  

In this post, we’ll unpack a step-by-step guide on how to ace the CMMC assessment report like a pro.

1. Understand the Type of CMMC Data Your Company Handles

Following the Department of Defense (DoD)’s publishing of the CMMC Final Rule in October 2024, CMMC compliance will now be mandatory for all defense suppliers. That includes subcontractors, who were previously exempted from rigorous vetting in earlier CMMC frameworks.  

As mentioned, conducting rigorous assessments is the first step in seeking CMMC compliance.  

Ideally, you should begin by understanding whether your business handles DoD-designated sensitive information. And if it does, what type of data is it?  

There are two types of information to focus your CMMC assessment around, namely Controlled Unclassified Information (CUI) and Federal Contract Information (FCI).  

Both CUI and FCI are designated by the DoD as highly sensitive and require extra safeguarding. The difference is that FCI isn’t typically intended for public release, whereas CUI may be disseminated publicly.  

Classic examples of CUI include export control information and defense financial data. Meanwhile, FCI includes things like the architectural plans of military buildings and emails shared between contractors and the DoD. 

2. Familiarize Yourself With CMMC Levels

The original CMMC framework had five levels. However, those were condensed into three per the recently published Final Rule.  

Level 1, the Foundational Level, emphasizes implementing basic cybersecurity measures to avert low-risk threats. It applies to businesses handling federal contract information, with 17 different controls to fulfill.  

CMMC Level 2 (Advanced Level) targets defense suppliers handling FCI and CUI. Assessments under this level seek to establish a vendor’s compliance with 110 cybersecurity controls outlined in the National Institute of Standards and Technology (NIST) 800-171.  

Finally, Level 3 (Expert Level) assessments are intended for suppliers handling highly sensitive defense information and who require additional safeguards. Audits focus on all Level 2 controls plus additional protocols, some currently under development.  

Note that companies can self-audit for Level 1 assessment. However, Level 2 evaluations must be undertaken by authorized CMMC Third-Party Assessor Organizations (C3PAOs), while Level 3 audits are facilitated by government officials directly appointed by the DoD.

3. Set Goals

Now that you’ve established your business handles DoD-designated sensitive information, the next step is to set CMMC assessment objectives.  

Various reasons could justify conducting a CMMC audit.  

Perhaps you’re looking to apply for a soon-to-be-advertised defense tender and need proof of CMMC compliance to be eligible for the contracts. Or, you’re simply seeking to understand your company’s cyber hygiene.  

Ideally, the stakes will be higher if you’re undertaking a mandatory CMMC assessment. That means you’ll need to conduct the audit in line with the DoD’s laid-down procedures.  

In the case of voluntary assessments, you have more flexibility in terms of scope, budget, and timelines. 

4. Inform and Rally the Relevant Personnel

If you’re intending to undertake a CMMC assessment, it’s best to notify your staffers well ahead of the audit date. This affords all concerned departments ample preparation time.  

More importantly, the success of CMMC assessments relies heavily on the seamless collaboration among key stakeholders. These include information technology (IT), human resources (HR), and legal and facility security officers.  

In fact, even seemingly uninvolved departments like the front office have a critical part to play during CMMC audits. That’s especially true if you suffer temporary operational downtimes during the assessments, in which case your customer support team can be instrumental in reassuring your clients.  

5. Set a Budget

CMMC assessment estimates vary considerably. According to most projections, Level 1 assessments start from $1,000, Level 2 from $25,000, and Level 3 from $60,000.  

The key is that these costs aren’t cast in stone. Instead, they’ll vary depending on your company’s size and niche.  

A more prominent IT provider may pay significantly more for CMMC assessments than, say, small-scale stationery vendors. That’s because IT companies likely handle a substantial amount of CUI and FCI data.  

The type of assessors you enlist for CMMC audits will also impact the evaluation costs. While regular auditors may charge reasonably lower rates, they don’t always guarantee professional assessments compared to C3PAOs. 

6. Perform a Pre-Assessment

Pre-assessments are essential before performing a formal CMMC evaluation. They provide an overview of your current cybersecurity posture and help identify any gaps in your cyber practices.  

Pre-assessments also let you estimate the duration the actual audits will take. Besides, you can leverage the opportunity to review your existing cybersecurity documents ahead of the formal evaluation.  

Now, you don’t necessarily have to outsource an external consultant for CMMC pre-assessments. You can conduct the process internally by tasking your in-house IT team. 

7. Prepare an SSP

Every CMMC pre-assessment should culminate in preparing a System Security Plan (SSP) or a review of existing SSPs.  

An SSP is a comprehensive document detailing the cybersecurity control measures an organization has put in place. It’s designed to give auditors an overview of currently implemented cyber procedures to quickly identify gaps and vulnerabilities.  

As a critical CMMC policy template, an SSP should include the specific cybersecurity threats assessed during the previous tests. It should also indicate whether such threats were detected, as well as control measures to avert them or mitigate their impact.  

Other critical details include the human personnel and technological solutions deployed to monitor and thwart attacks. If you already have an SSP, simply focus on the areas addressed by the pre-assessment report.

8. Undertake Actual Assessments

With your SSP properly reviewed, you can now perform a comprehensive assessment.  

Remember that you’re not obligated to enlist third-party assessors for Level 1 evaluations, although external auditors would offer a more objective assessment. However, for Levels 2 and 3, applying for independent assessors is mandatory.  

Focus on hiring an accredited C3PAO, as the success of Level 2 assessment determines whether you can apply for Level 3 evaluations. Ensure you choose a C3PAO accredited by the Cyber AB – CMMC’s accreditation body.  

Head to the Cyber AB marketplace and search for your preferred C3PAO. Then, read reviews and contact references for deeper insights into the auditor’s experience and professionalism.  

After finding the right C3PAO, engage them on your expectations, timeline, and budget. If you agree, the auditor will assemble a team of at least one Lead Certified CMMC Assessor (CCA), one secondary CCA, and an extra individual charged with performing Quality Assurance.  

The team will then appear in your company on the agreed date to conduct the CMMC assessment. Each evaluation will focus on the assets that handle FCI or CUI, including hardware drivers and cloud storage locations.  

After the conclusion of the audit, your C3PAO will prepare a comprehensive report indicating whether you’ve “met” or “not met” the requirements. In the latter case, you can invoke a Plan of Action and Milestones (POA&Ms).  

POA&Ms is a roadmap detailing how you’ll remediate the risks uncovered during CMMC Level 2 assessments. It confers your company a temporary privilege to continue enjoying all applicable benefits as you endeavor to seal the gaps highlighted in the audit report. Businesses have up to 180 days, after which they may achieve total compliance or have their conditionally issued certification revoked altogether.  

Note that POA&Ms are only invoked upon meeting 80% of all Level 2 requirements. Closing out on the POA&M within the 180-day window is essential, or you’ll need to reapply for CMMC certification. 

9. Maintain Compliance

CMMC assessments are only effective as of the date they’re performed. An audit report may give your company a clean bill of health today, only for cybersecurity risks to emerge tomorrow.  

Therefore, conducting ongoing compliance assessments is paramount.  

While there’s no standard rule on how frequently you should undertake a CMMC assessment, you could schedule third-party audits once every six months. Self-audits can be undertaken regularly, as they’re less resource-intensive.  

Regular assessments can protect your company from cyber-attacks and fully comply with CMMC’s requirements. The insights from each report can also help you better understand your organization’s cyber hygiene, thereby averting threats in your supply chain.  

Remember to review each assessment report against your existing cybersecurity templates and make adjustments where necessary.  

If subsequent audits uncover any cybersecurity risks, remediate them immediately. Waiting much longer could cause an initially benign threat to become highly aggressive and more costly to manage. 

Acing CMMC Compliance With Professional Help

CMMC assessment is essential for both prospective and existing DoD contractors.  

Initial CMMC audits can help preapprove suppliers for lucrative defense tenders, while ongoing evaluations are necessary to help DIB companies better understand their cybersecurity architecture. It’s only by staying on top of the cybersecurity game that vendors can effectively fend off unforeseen threats.  

While you can self-assess for CMMC Level 1, the subsequent levels require professional assistance. For Level 2 CMMC audits (which applies to most DIB companies), you’ll need to liaise with an accredited C3PAO.  

Choose a C3PAO with a stellar cybersecurity background and a proven track record of excellence. Besides, the agency should be able to tailor solutions that align with your company’s size and the type of sensitive data it handles.  

Excellent communication and organization are other key competencies when looking for a C3PAO.