Prepare for a CMMC Assessment: Key Steps After a Gap Analysis

Graphic by Alluvionic promoting a CMMC Gap Analysis service, featuring a checklist of benefits and an image of hands typing on a keyboard surrounded by digital icons. — Alluvionic simplifies CMMC compliance with expert gap analysis services tailored to your organization’s needs.

Achieving Cybersecurity Maturity Model Certification (CMMC) is a critical milestone for organizations aiming to secure or maintain Department of Defense (DOD) contracts. The journey to certification involves multiple steps, including a third-party assessment conducted by a Certified Third-Party Assessment Organization (C3PAO). You’re already on the right path if you’ve recently undergone a gap analysis. If not, that’s an essential first step. Read more about Alluvionic’s gap analysis offering here. Preparing for an official assessment, however, requires a targeted, thorough approach to close any remaining gaps and streamline the CMMC certification process. Here, we’ll explore what a C3PAO will look for during a CMMC assessment and how you can leverage an Alluvionic gap analysis to ensure you’re well-prepared.

What Is a C3PAO and Its Role in CMMC Assessments?

A C3PAO (Certified Third-Party Assessment Organization) is a company accredited by the Cybersecurity Maturity Model Certification Accreditation Body (Cyber AB) to conduct CMMC assessments. For Level 2 certification, the C3PAO is required to evaluate how well your organization’s cybersecurity practices align with the requirements in NIST SP 800-171 and other CMMC standards. They will thoroughly verify your organization’s adherence to access controls, data handling, and response procedures essential to securing CUI against cyber threats. A CMMC Level 2 assessment typically includes:

Compliance with NIST SP 800-171 requirements
Documentation and consistency of cybersecurity protocols

Let’s dive into the specific focus areas that a C3PAO will assess.

Key Areas a C3PAO Will Assess

Understanding these critical areas will help you address gaps and ensure a successful assessment.

Graphic listing 5 key review areas for CMMC compliance, including Access Control, Audit & Accountability, Incident Response, System and Communications Protection, and Personnel Security, with checkmarks beside each. — Understand the 5 key areas assessed during CMMC compliance preparation to ensure your organization meets cybersecurity standards.

1. Access Control (AC)

What a C3PAO Looks For: Documented access policies that ensure only authorized personnel can access sensitive systems or data. This includes role-based controls for systems handling CUI.
Preparation Steps: Verify that access controls are implemented consistently and aligned with your documented policy. Regularly audit and update access rights.

2. Audit and Accountability (AU)

What a C3PAO Looks For: Systems to log and monitor activities. This ensures traceability and accountability of user actions, essential for detecting and responding to security events.
Preparation Steps: Set up a log management system for activity tracking, and document your incident response plans. Be prepared to provide logs and demonstrate regular review processes.

3. Incident Response (IR)

What a C3PAO Looks For: A structured approach for handling incidents that includes detection, response, and recovery procedures.
Preparation Steps: Ensure your incident response plan aligns with CMMC standards. Conduct tabletop exercises to validate preparedness and document employee training activities.

4. System and Communications Protection (SC)

What a C3PAO Looks For: Encrypted communication channels and secure data transmission protocols, especially for data at rest and in transit.
Preparation Steps: Confirm encryption is applied wherever necessary, and document your data protection measures, including access control and encryption protocols.

5. Personnel Security (PS)

What a C3PAO Looks For: Screening and training processes that ensure individuals handling CUI are both trustworthy and knowledgeable in cybersecurity practices.
Preparation Steps: Document employee screening and training policies. Maintain detailed records of training sessions and provide regular cybersecurity updates.

Leveraging Your Gap Analysis with Alluvionic

An Alluvionic gap analysis is your roadmap for closing compliance gaps ahead of your C3PAO assessment. Here’s how to use your gap analysis results effectively.

1. Prioritize High-Risk Gaps

Focus: Address high-priority areas first, as these are often the biggest vulnerabilities. Alluvionic will highlight urgent issues like access control, encryption, or incident response gaps.
Action Steps: Implement and document corrective measures for each high-risk gap. Ensure your actions meet CMMC control standards.

2. Develop and Update Policies and Procedures

Focus: CMMC certification relies on having formalized policies and procedures that support consistent, repeatable practices.
Action Steps: Use your gap analysis to identify policies needing updates or development. With Alluvionic’s help, ensure your policies comprehensively address CMMC requirements.

3. Document and Demonstrate Compliance Efforts

Focus: C3PAOs require evidence of implemented CMMC controls.
Action Steps: Gather and organize documents such as access logs, incident response records, and training materials. Use Alluvionic’s templates to streamline and standardize documentation for easy assessment review.

4. Establish a Continuous Monitoring Program

Focus: Compliance requires ongoing vigilance, not a one-time effort.
Action Steps: Implement regular audits, access reviews, and monitoring activities. Document these processes to show your proactive approach to maintaining compliance.

Practical Tips for a Successful C3PAO Assessment

After implementing all required controls and addressing the gaps identified in your gap analysis, these additional steps will help you prepare for the final C3PAO assessment.

1. Conduct a Mock Assessment

Simulate the C3PAO assessment to identify any overlooked areas. Alluvionic offers CMMC readiness reviews, which serve as effective mock assessments, allowing you to refine your approach.

2. Assign a CMMC Compliance Lead

Designate a team member to oversee compliance activities, coordinate with the C3PAO, and address any last-minute issues.

3. Prepare Your Team for Interviews

The C3PAO will interview various staff members to verify compliance. Alluvionic can train your team to confidently articulate their cybersecurity roles and responsibilities.

4. Organize and Simplify Documentation

Make sure all documentation is accessible and organized. This will streamline the assessment process and help avoid delays.

5. Schedule Regular Compliance Check-Ins

Continue reviewing compliance progress post-gap analysis. Regular check-ins allow you to stay ahead of new issues and reinforce best practices across your organization.

Partner with Alluvionic for CMMC Compliance Success

The path to CMMC Level 2 certification can seem complex, but with expert guidance from a Registered Provider Organization (RPO) like Alluvionic, your organization can tackle each stage with confidence. From conducting gap analyses to facilitating mock assessments, Alluvionic’s tailored CMMC preparation services cover every aspect of compliance. Partnering with Alluvionic means more than just preparing for an assessment; it’s an investment in establishing a cybersecurity culture that aligns with CMMC standards and strengthens your overall security posture. Visit Alluvionic’s Cybersecurity Services to schedule a consultation and take the next step toward achieving CMMC certification. By following these preparation steps and leveraging your Alluvionic gap analysis, your organization can navigate the CMMC assessment with confidence and poise.

About the Author

Sydney Wright, project management and cybersecurity consultant.

Sydney Wright is a project management professional with expertise in guiding organizations through complex cybersecurity frameworks such as CMMC and NIST SP 800-171. Leveraging her strong background in communications, she excels at translating intricate cybersecurity concepts into clear, actionable strategies. Passionate about the intersection of technology and effective communication, Sydney is dedicated to fostering collaboration, simplifying compliance, and delivering measurable results.

CMMC FAQs

1. What is CMMC, and why is it required?

If you’re feeling overwhelmed by the thought of yet another compliance requirement, you’re not alone. The Cybersecurity Maturity Model Certification (CMMC) may feel like a tall order, but it exists for an important reason: to protect sensitive DOD information from cyber threats. By meeting these standards, you’re not just complying; you’re playing a vital role in national security.

CMMC ensures that contractors in the Defense Industrial Base (DIB) have the cybersecurity measures needed to safeguard Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). While the process can feel daunting, achieving compliance sets you apart as a trusted partner in the defense community.

2. How do I know if my organization needs CMMC, and what level do I require?

Many contractors worry about whether they’re required to meet these standards. Here’s how to know:

Does your work involve FCI or CUI? If so, compliance is almost certainly necessary.
What level is needed? Contracts will specify the required level:
- Level 1 for basic FCI safeguarding.
- Level 2 for advanced protections for CUI.
- Level 3 for high-risk CUI scenarios.

It may seem like a heavy lift, but with the right guidance, you can turn this requirement into a differentiator. Acting early gives you the time to prepare and position your business as a leader in security.

3. How do I know what CMMC level I need, and what’s the difference?

To determine the right CMMC level for your organization, first identify what kind of information you handle (FCI or CUI). Additionally, check your DOD contract requirements as this will explicitly state any CMMC level requirements.

The CMMC Framework is organized in three maturity levels.

Level 1 – Foundational: Organizations must follow 17 basic cybersecurity practices, like requiring employees to change passwords regularly. This protects Federal Contract Information (FCI), which is non-public data shared or created under a government contract.

Level 2 – Advanced: Organizations need a formal plan to manage and implement 110 cybersecurity practices. This includes meeting all NIST 800-171 security requirements to protect Controlled Unclassified Information (CUI).
Level 3 – Expert: Organizations must have highly refined processes to detect and respond to advanced cyber threats. These threats, called Advanced Persistent Threats (APTs), come from skilled attackers with significant resources to launch complex attacks and analyze data.

Each step builds your credibility and resilience. While the journey can be challenging, it’s one that Alluvionic’s experts can guide you through, ensuring you reach the summit successfully.

If you’re still not sure which level applies to your organization, reach out for a quick consultation. Our experts are happy to help.

4. How much does CMMC certification cost, and how long does it take?

Cost and time are common concerns, and it’s natural to feel uncertain. Certification expenses typically come from several areas:

Consulting Support: Many organizations hire a Registered Practitioner Organization (RPO) to help navigate the CMMC readiness process.
Technical Upgrades: Costs may arise from hardware and software updates needed to meet compliance requirements.
Assessment Fees: Engaging a Certified Third Party Assessment Organization (C3PAO) is another significant expense.
Ongoing Maintenance: After certification, there will be some ongoing costs to maintain compliance.

With these expenses in mind, a Level 1 self-assessment may only cost a few thousand dollars. The cost of CMMC Level 2 compliance is often much higher—typically in the tens of thousands—while Level 3 can require an even greater investment depending on your organization’s size and scope. For a more precise cost estimate, connect with one of our experts to discuss your needs.

Timelines can range from 9-12 months, though it’s not uncommon for some organizations to experience multi-year remediations due to lack of strategic management.

The good news? By starting now and with expert support, you can streamline the process, avoid costly delays, and gain a significant competitive edge.

5. What happens if my organization doesn’t meet the required CMMC level?

It’s natural to worry about falling short, but here’s the silver lining: gaps can be fixed. If you don’t meet the requirements, you may lose out on contracts. However, with a strategic plan and expert guidance, you can address deficiencies and ensure you’re ready to compete when opportunities arise.

6. What are the key cybersecurity practices evaluated during a CMMC assessment?

The technical details can be intimidating, but they boil down to one goal: protecting critical information. Assessments focus on practices like:

Access control.
Incident response.
Media and physical protection.
System and communication security.

By addressing these areas, you’re not just meeting requirements—you’re making your business more secure and resilient.

7. How is CMMC different from NIST SP 800-171?

While NIST SP 800-171 outlines requirements, CMMC adds a layer of accountability through certification. It may feel like an added hurdle, but it’s also an opportunity to validate your commitment to security and stand out in the marketplace.

8. How often do organizations need to recertify?

Certification lasts three years and contractors must provide annual affirmations of compliance between assessments. While that might seem like a recurring challenge, it’s also a way to ensure your security practices stay sharp and competitive. The key is staying proactive—let us help you plan ahead and avoid scrambling at the last minute.

9. Do subcontractors also need CMMC certification?

Absolutely, and this often causes stress for prime contractors. Subcontractors must meet the same level as the prime contractor, ensuring consistency across the supply chain. But don’t worry—Alluvionic can help manage compliance throughout your network.

10. What are my next steps to get started with CMMC?

The journey to CMMC compliance can feel overwhelming, but you don’t have to face it alone. With Alluvionic by your side, you can turn this challenge into an opportunity.