CMMC Assessments – What You Need To Know
Whether Cybersecurity Maturity Model Certification (CMMC) is new to you or not, it could be a deciding factor in your government contracts. CMMC is a Department of Defense (DoD) assessment that ensures government contractors meet certain cybersecurity standards to handle sensitive information like Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). It will start being required on new contracts when Phase 1 begins on November 10, 2025.
With growing cyber threats in the defense supply chain and the increased sophistication of hackers worldwide, maintaining a high standard of security is critical to the mission of both you and your government customers. Based on the requirements of NIST SP 800-171, CMMC verifies that you meet the level of cybersecurity required to protect sensitive information and safeguard the supply chain.
Compliance is subject to verified assessments, and failure to meet standards could result in losing your government contract. On the other hand, maintaining CMMC and demonstrating your well-thought security standards gives you a competitive advantage when it comes to securing government contracts in the future. Read on for all you need to know about achieving and maintaining CMMC.
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There are three levels of CMMC maturity with different assessment requirements
CMMC leverages a three-tiered framework with progressively advanced cybersecurity requirements at each level. The level you’ll be expected to reach will be determined by your government contract and the amount of CUI or FCI you handle. Your level will be clearly defined in RFP you responded to. The higher the level, the more involved your assessment. Most contractors will require Level 2 assessment.
Here is a breakdown of the three levels:
- Level 1 CMMC—Foundational. Level 1 protects FCI with 15 basic security controls from the Federal Acquisition Regulation (FAR) 52.204-21 . This is the only level where you perform your own annual self-assessment.
- Level 2 CMMC—Advanced. Level 2 protects CUI with the full implementation of the 110 security controls in NIST SP 800-171. Assessment requires a third-party audit every three years from an independent third-party assessor organization (C3PAO).
- Level 3 CMMC—Expert. Level 3 CMMC—Expert. Level 3 focuses on reducing the risk of Advanced Persistent Threats (APTs) and requires full compliance with NIST SP 800-172 controls. Assessments are conducted by the DIBCAC (Defense Industrial Base Cybersecurity Assessment Center) on behalf of the DoD to validate the highest level of cybersecurity maturity.
Here’s what to expect during your CMMC assessment
Assuming you are mandated to reach CMMC Level 2 or Level 3, a C3PAO will evaluate your organization’s cybersecurity controls to ensure compliance by reviewing documentation, conducting interviews with personnel, performing technical tests and verifying NIST 800-171 and/or NIST 800-172 implementation.
The process has three phases:
- Pre-Assessment Phase. The Organization Seeking Certification (OSC) and the C3PAO define the scope of the assessment, including locations, assets and CUI flow. The OSC will conduct a self-assessment to identify gaps and prepare for their third-party review. The OSC will also provide documentation, such as a System Security Plan (SSP) and a preliminary list of evidence supporting their compliance.
- Assessment Phase. The C3PAO will review the provided documentation to ensure cybersecurity policies and procedures align with CMMC requirements. They will conduct interviews with employees to assess their awareness of cybersecurity measures and their own application of security policies. They may perform technical tests, inspect physical security measures and observe control implementation. The C3PAO will also examine artifacts and other evidence to confirm controls are implemented and functioning as intended, with continuous monitoring. The C3PAO will deliver daily checkpoints so the OSC can follow up.
- Post-Assessment Phase. This is when the C3PAO presents their final findings and results. If deficiencies are found, the OSC may need to create a POA&M outlining their next steps and a timeframe for completion. Then the results are uploaded to the CMMC eMASS system for the DoD to review. If the OSC meets all requirements, they will earn their CMMC certification.
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Challenges and best practices to keep in mind
CMMC compliance comes with its own set of challenges for OSC contractors. Legacy systems, a lack of understanding about requirements, and inconsistent security practices can muddy the path to certification. Resource constraints can cause added stress and compliance fatigue. And, after passing the assessment, having difficulty maintaining compliance can be a challenge.
We suggest the following best practices to help you better prepare for your CMMC assessment:
- Conduct a gap analysis against CMMC requirements and update policies, procedures and security practices to remediate those gaps
- Create a SSP and Plan of Actions & Milestones (POA&M) to help guide your journey
- Align your security policies and procedures to framework requirements
- Engage in ongoing monitoring and self-assessments to best prepare for your C3PAO assessment
- Train staff on compliance responsibilities and make them aware that they will be accountable to the assessors
- Ensure that your own subcontractors who will process, store or transmit FCI or CUI also meet CMMC requirements
- Maintain continuous compliance and an ability to adhere to security requirements over time
- Consider using automation to align with required controls, ease the burden on your staff and simplify compliance and continuous compliance
Creating new processes and practices
for a more secure futureÂ
CMMC is not a one-time exercise or milestone. It requires continuous compliance, supported by proactive leadership and meticulous preparation. Many will find automation to be a lifesaver when it comes to successful CMMC assessments.
Automation can do all the scanning and remediation required for filling in gaps. Once policy is set, unified automated solutions scan and remediate consistently and without the errors and delays that manual compliance is beset with. They also simplify compliance evidence gathering and reporting, saving considerable time and effort. In fact, once implemented, automated compliance makes compliance fast, easy, trustworthy and continual for stress-free assessments.
Look for a unified automation tool—one that scans, remediates, monitors and reports from a single solution—that is proven in this environment. SteelCloud’s ConfigOS is one that the DoD trusts for their own cybersecurity strategies and it covers all their CMMC requirements, setting you up for long-term readiness and enhanced competitiveness.  To see a demo of how ConfigOS simplifies and supports CMMC compliance, or to ask questions, contact Steelcloud today. Â
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Datasheet: ConfigOS DashView
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