Top CMMC Compliance Mistakes to Avoid: A Guide for Business Professionals

The Cybersecurity Maturity Model Certification (CMMC) 2.0 is a requirement for organizations in the Defense Industrial Base (DIB). While final implementation is still pending, compliance with NIST SP 800-171 remains mandatory for contractors handling Controlled Unclassified Information (CUI).  Non-compliance can result in the loss of eligibility for DoD contracts. Additionally, misrepresenting compliance status may lead to potential legal implications under the False Claims Act (FCA). Navigating the CMMC certification process is complicated and confusing.  

To help businesses navigate this complex landscape, let’s take a look at some of the most common CMMC compliance mistakes businesses make when going through the process and see how we can mitigate those missteps. 

1. Underestimating the Scope and Complexity of CMMC

• • Mistake: Assuming CMMC is simply about installing antivirus software and running occasional security scans. For many companies, CMMC Compliance seems like something someone in IT should just be able to handle quickly on their own. In fact, this is a critical mistake as it requires buy-in from leadership and other areas within the organization to coordinate and get done on time. This is not something to simply hand to an intern, nor is it a process that may take a week to accomplish. 

• • Impact: CMMC addresses a wide range of security controls, including asset management, incident response, and supply chain risk management. Underestimating its scope can lead to inadequate preparation and significant delays in achieving compliance. 

• • Solution: The first step is to analyze your compliance status, identify requirements, and initiate meetings with all relevant stakeholders. Get those at the top to understand why this is so crucial for business and work together to move forward. 

2. Lack of Executive Buy-in and Commitment

• • Mistake: Failing to secure the necessary support and resources from senior leadership. As mentioned above, there are executive decisions that might need to be made here and not making those decisions can cost you huge amounts in lost revenue from contracts you cannot win without this.  

• • Impact: Without executive sponsorship, CMMC initiatives can face roadblocks, lack of funding, and insufficient prioritization. This can significantly hinder progress and increase the risk of non-compliance. 

• • Solution: Start early and get the executive suite involved right from the start. Impress upon them the critical business need for this and start the process as soon as possible.  

3. Failing to Conduct a Thorough Risk Assessment

• • Mistake: One of the first steps you should take is an initial self-assessment. Often, companies just assume they’ve been meeting the requirements all along. Neglecting to identify and prioritize the most critical security risks facing the organization. Not knowing where you are can lead to lots of heading down the wrong path and time wasted. 

• • Impact: poorly conducted risk assessment can lead to the implementation of ineffective controls and wasted resources. It can also increase the likelihood of cyberattacks and data breaches, jeopardizing CMMC compliance. 

• • Solution: Start this process early. If you start doing your self-assessments early, you can do them multiple times and prepare for the actual third-party assessment and the official self-assessment you must take as part of the process. By learning the process this way, you can prepare yourself and go a long way toward ensuring a successful outcome. 

4. Neglecting Supply Chain Security

• • Mistake: Failing to assess and manage the cybersecurity risks posed by third-party vendors and suppliers. This question does come up a lot and many do not realize how strict the rules are when applied to vendors and third parties that you might use for business. Not all vendors require CMMC certification. However, subcontractors handling CUI must meet CMMC Level 2 or higher. Prime contractors are responsible for ensuring their supply chain meets the required security standards. 

• • Impact: CMMC places significant emphasis on supply chain security. Your organization’s compliance efforts will fail if your vendors lack adequate security. You could end up doing everything right internally within your organization but by not ensuring security with vendors, lose out on CMMC certification and lose those contracts you rely on. 

• • Solution: When you start doing your self-assessments, make sure you include everything, including all of the access points for vendors and others within your supply chain.  

5. Insufficient Documentation and Record-Keeping

• • Mistake: Failing to maintain adequate documentation of security controls, assessments, and incident response activities. Get it all down in writing. In fact, having written policies to address gaps you find in your security measures, and ensuring everyone is aware of those policies will help fill those gaps and provide solutions the assessment organizations will approve.  

• • Impact: CMMC requires robust documentation to demonstrate compliance. Insufficient record-keeping can lead to audit failures and significant delays in the certification process. It is not enough to implement a policy verbally. Write it all down and make sure people know the rules and the policies and processes involved to ensure compliance and for compliance to remain in place. 

• • Solution: Write, write, write. Begin writing your cybersecurity and CMMC policies and procedures and ensure regular updates. This is an ongoing process, and you need to treat it that way.  

6. Ignoring the Importance of Employee Training and Awareness

• • Mistake: Failing to educate employees about cybersecurity best practices and the importance of CMMC compliance. This all goes back to the idea that CMMC 2.0 compliance goes beyond IT and a few departments within the organization. It involves everyone within the organization potentially. Even those who may not have the need to know now, might need to later. This is why there has to be training at all levels, and everyone needs to be aware of CMMC and what it entails.  

• • Impact: Human error is a significant factor in many cyberattacks. Without proper training and awareness, employees may inadvertently put the organization at risk. 

• • Solution: No one wants to have more required training in their work life, but this has to happen when it comes to the CMMC framework. Set up time with the whole organization either as a group or individually and go through what it is, why it is important and how it impacts their daily tasks and their job. 

7. Delaying Implementation

• • Mistake: Procrastinating and delaying the initiation of CMMC compliance efforts. You think you have time. You think this won’t take too long. What you don’t realize is that the timeline for CMMC compliance varies based on company size and complexity. Some businesses may take six months or more to prepare, while others may need over a year. The availability of Certified Third-Party Assessment Organizations (C3PAOs) is limited, so early preparation is essential. 

• • Impact: CMMC compliance is a complex and time-consuming process. Delaying implementation can lead to significant challenges in meeting deadlines and achieving certification.  With the final CMMC 2.0 rule expected in 2025, businesses should begin preparing now by aligning with NIST SP 800-171 requirements and submitting their Supplier Performance Risk System (SPRS) score. 

• • Solution: The solution here is pretty simple. Start now. Start as soon as you can and don’t waste a minute figuring out what you already have in place, where there are gaps, and what you still need to do.  

8. Selecting the Wrong Level of CMMC Certification

• • Mistake: Choosing the wrong CMMC Level based on inaccurate assessments or a lack of understanding of the requirements. If you choose the wrong level, you will not be compliant at the level you need to be and that will cost you down the road. 

• • Impact: Achieving a higher level of CMMC certification than necessary can be costly and time-consuming. Conversely, choosing a lower level that does not meet contractual or regulatory requirements can expose the organization to significant risks. 

• • Solution: Do your research, reach out to experts, but figure out early on what level you need to achieve so you can complete your plan and roadmap for achieving compliance.  

9. Relying Solely on Internal Resources

• • Mistake: Attempting to navigate the CMMC landscape without seeking expert guidance and support. Since CMMC 2.0 is complex and evolving, organizations may benefit from working with third-party compliance experts to ensure accurate implementation and avoid costly mistakes. 

• • Impact: CMMC compliance involves a complex set of requirements and best practices. Attempting to “go it alone” can lead to costly mistakes, delays, and an increased risk of non-compliance. 

• • Solution: Now is the time to seek out third-party help. Do your research, find a reputable partner here, and get to work. These partners can provide you with assistance and guidance so you don’t miss something that could set you back. 

10. Failing to Conduct Regular Audits and Assessments

• • Mistake: Neglecting to conduct regular internal and external audits to assess compliance status and identify areas for improvement.  CMMC compliance is an ongoing process. While certifications last three years, organizations must conduct annual self-assessments, maintain security controls, and stay updated with evolving CMMC requirements. C3PAO assessments under CMMC 2.0 are valid for three years, but annual self-assessments are required to maintain compliance.  

• • Impact: Continuous monitoring and assessment are crucial for maintaining CMMC compliance. Failing to conduct regular audits can lead to unexpected findings and jeopardize certification status. 

• • Solution: Stay on top of things. Sign up for newsletters. Subscribe to Reddit threads about CMMC. Or sign up with software and a business partner that will continue to stay on top of changes, adjust and ensure you stay compliant. 

You Cannot Afford Mistakes So Learn from These Examples 

By avoiding these common mistakes and leveraging the expertise of trusted partners like Exostar®, businesses can navigate the CMMC landscape successfully and achieve and maintain compliance. Exostar’s comprehensive suite of solutions, coupled with its deep domain expertise, can empower organizations to: 

• Reduce risk: Identify and mitigate cybersecurity threats effectively. 
• Improve efficiency: Streamline compliance efforts and minimize the associated costs. 
• Gain a competitive advantage: Differentiate themselves in the marketplace as a trusted and reliable partner. 
• Build customer trust: Demonstrate a strong commitment to cybersecurity and data protection. 

Exostar® Has Solutions that Will Help 

By partnering with Exostar®, businesses can confidently address the challenges of CMMC compliance and build a strong foundation for long-term success in the evolving cybersecurity landscape. 

Exostar® offers a comprehensive CMMC Ready Suite™, which covers all of the issues that we discussed above in one way or another. It is a complete and comprehensive solution that will help you get to CMMC compliance.  

So, visit our CMMC Ready Suite™ page and then contact us for a demonstration and discussion about how we can help.