If you’re looking to delay your Department of Defense (DoD) contracts, waste company resources, and ensure your cybersecurity efforts fall short, failing your Cybersecurity Maturity Model Certification (CMMC) assessment is an excellent way to do it.
This guide will outline exactly what not to do if you want to remain eligible for defense contracts. However, if passing is your goal, consider these common pitfalls as warnings.
As a CMMC Level 2 Certified company, Alluvionic understands firsthand the challenges of undergoing an assessment. We’ve been through the process, and we’re here to help you navigate your own path to compliance.
Step 1: Ignore Pre-Assessment Preparation
Some companies assume that their existing security practices are good enough and schedule an official CMMC assessment without any internal review. This is a guaranteed way to fail.
Why This Leads to Failure:
- CMMC assessments follow the 110 security requirements outlined in NIST SP 800-171. Without a gap analysis, you may not even know which controls your organization is missing.
- Technical issues, such as improperly configured encryption or logging mechanisms, are often discovered during pre-assessments. If you wait until the actual assessment, you won’t have time to fix them.
- Many organizations assume they meet requirements because they follow general cybersecurity best practices. However, CMMC compliance is highly specific, and missing even a few details can result in non-compliance.
What to Do Instead:
- Conduct a thorough gap analysis to identify security gaps well before your assessment.
- Fix any non-compliant practices before a CMMC Third-Party Assessment Organization (C3PAO) begins its review.
- Review all documentation, security policies, and technical implementations to ensure they align with CMMC Level 2 requirements.
Step 2: Neglect Proper Documentation
Many companies assume that having cybersecurity measures in place is enough. However, CMMC assessors require formal, written documentation to verify compliance. If your policies are incomplete, outdated, or nonexistent, you will not pass.
Why This Leads to Failure:
- The System Security Plan (SSP) must be detailed, accurate, and signed by an authorized representative. Many companies forget to sign and date their SSP, which can result in an automatic failure.
- Policies must be specific and actionable. Vague statements such as “We follow cybersecurity best practices” do not meet CMMC standards.
- Documentation should match real-world practices. If your company claims to enforce multi-factor authentication (MFA) but fails to do so in practice, the assessors will identify the discrepancy.
What to Do Instead:
- Develop a comprehensive System Security Plan (SSP) that clearly defines your security measures.
- Ensure all security policies and procedures are documented, reviewed, and signed by the appropriate personnel.
- Regularly update your documentation to reflect any changes in security controls or procedures.
Step 3: Assume IT Will Handle Everything
Many companies make the mistake of treating CMMC compliance as solely an IT issue. While IT plays a critical role, cybersecurity is an organization-wide responsibility.
Why This Leads to Failure:
- Assessors will interview multiple departments, potentially including HR, executive leadership, and marketing.
- Employees must demonstrate an understanding of security policies. If a staff member is asked how to handle Controlled Unclassified Information (CUI) and provides an incorrect answer, this will raise concerns about compliance.
- Cybersecurity training is required for all employees. If training records are incomplete or missing, this will count against your organization.
What to Do Instead:
- Conduct organization-wide training to ensure that all employees understand their cybersecurity responsibilities.
- Ensure leadership is actively involved in cybersecurity decision-making and policy enforcement.
- Maintain detailed training records to demonstrate compliance with CMMC requirements.
Step 4: Overlook Technical Security Controls
Some companies assume that since they have firewalls and anti-virus software, they are secure. However, CMMC requires specific technical controls that must be fully implemented and verified.
Why This Leads to Failure:
- Multi-Factor Authentication (MFA) must be enforced for all users accessing CUI. Partial implementation or selective enforcement is not acceptable.
- Data encryption must be applied to CUI both at rest and in transit. If encryption is improperly configured or missing, it will result in non-compliance.
- Logging and auditing mechanisms must be in place and functional. If logs are not being reviewed or alerts are not configured, assessors will flag this as a security risk.
What to Do Instead:
- Verify that MFA is enforced for all accounts and that no exceptions exist.
- Ensure that CUI is encrypted using FIPS-validated encryption methods.
- Conduct regular log reviews and security audits to demonstrate continuous compliance.
Step 5: Assume Employees Will Perform Well in Interviews
CMMC assessments include personnel interviews to evaluate whether employees understand and follow cybersecurity policies. If employees are unprepared, they can unintentionally cause the organization to fail.
Why This Leads to Failure:
- If employees do not understand how to report a security incident, assessors will flag a deficiency in security awareness training.
- If personnel handling CUI do not know how to properly store, transmit, or dispose of CUI, this will result in non-compliance.
- If leadership is unable to explain their role in cybersecurity governance, it signals that security is not a priority at the executive level.
What to Do Instead:
- Conduct mock interviews with employees to ensure they understand their cybersecurity responsibilities.
- Provide ongoing cybersecurity training to reinforce key policies and procedures.
- Ensure leadership is well-versed in CMMC requirements and can confidently explain the organization’s security strategy.
Step 6: Underestimate the Consequences of Failing
Some companies believe that failing an assessment is a minor setback. In reality, failing can have significant business consequences.
Why This Leads to Failure:
- A failed assessment can result in a loss of contract eligibility, preventing your company from bidding on DoD contracts that require CMMC certification.
- You may need to undergo a full reassessment, which increases costs and extends the timeline for certification.
- Competitors that pass their assessments will have a competitive advantage, potentially securing contracts that your organization is unable to bid on.
What to Do Instead:
- Treat CMMC compliance as a business-critical priority rather than an IT checklist.
- Invest in pre-assessment preparation to address compliance gaps before they become problems.
- Work with a CMMC-Registered Practitioner Organization (RPO) to ensure your company is fully prepared.
How Alluvionic Can Help
Achieving CMMC compliance is challenging, but failing your assessment can be costly. Alluvionic is a CMMC Level 2 Certified company that has gone through this process firsthand. Our team provides:
- Pre-assessment readiness & gap analysis to identify security weaknesses.
- Policy & documentation support to ensure compliance with CMMC requirements.
- Technical security validation to confirm security controls are correctly implemented.
- Employee training & interview preparation to ensure your team is ready.
Don’t risk your DoD contracts due to non-compliance. Contact Alluvionic today and take control of your cybersecurity future.
