Organizations may require additional steps to ensure they are CMMC compliant
By Corinne Minard
Just because an organization has completed a Cybersecurity Maturity Model Certification (CMMC) checklist doesn’t mean that it’s ready to work with the Department of Defense (DoD). It takes more than checking things off a list—it also requires evidence that controls have been implemented and are functioning.
“Auditors want proof that processes are executed consistently. Evidence can include system logs, access records, user activity and other documentation demonstrating control effectiveness. A policy sitting on a shelf will not satisfy CMMC requirements,” says Carly Devlin, chief information security officer at Clark Schaefer Consulting.
Devlin has identified several common issues that prevent checklists from ensuring readiness:
– Ownership is unclear: If the organization doesn’t assign responsibility for each control, gaps can go unnoticed.
– Evidence is incomplete or inconsistent: Auditors expect verifiable documentation.
– Process are not integrated: Controls need to be part of everyday operations.
-Changes over time are not tracked: Controls need to be implemented consistently, not just one time.
“Consider a contractor who checked off every item on a CMMC checklist without validating active implementation. During the official assessment, auditors discovered incomplete access logs and inconsistent incident response procedures. The contractor failed the assessment, delayed a contract award and incurred extra costs to remediate deficiencies. Real-world examples like this highlight why checklists alone cannot guarantee readiness,” says Devlin.
According to Clark Schaefer Consulting, there are several ways to ensure an organization is truly CMMC compliant:
- Conducting a thorough gap analysis to identify weaknesses.
- Assigning clear ownership for each control to ensure accountability.
- Collecting evidence of implementation that auditors can verify.
- Implementing continuous monitoring to maintain compliance over time.
“A readiness assessment identifies vulnerabilities, establishes accountability and creates a roadmap to meet CMMC requirements. CMMC readiness is an investment in protecting your contracts, operations and reputation. Organizations that understand this distinction are more likely to achieve compliance and maintain it long-term,” says Devlin.
If you’re unsure where you stand or lost on where to begin, contact Clark Schaefer Consulting to schedule a readiness assessment and take the first step toward full CMMC compliance.
To learn more about why a checklist won’t work for CMMC compliance, watch this video featuring Clark Schaefer Consulting’s Ross Patz.