CMMC Challenges Demystified: Overcoming Barriers & Building Resilience
Anwita
Jan 21, 2025
hustle isn’t about securing million-dollar weapon contracts; it’s about mastering cybersecurity compliance. In this world, CMMC is your shield, and certification is a new mission.
The stakes couldn’t be higher. One misstep in your compliance journey can mean losing not just a business contract but also your credibility. But if you play your cards right, CMMC is more than a box to check—it’s your golden ticket to becoming a trusted partner in U.S. defense operations.
But CMMC is quite the Herculean feat—developing policies, conducting gaps assessments, implementing controls – it’s a long and complex list.
Let’s understand what these challenges are and how you can overcome them.
TL;DR
- Some of the challenges of CMMC certification are understanding which data or system has CUI, meeting expenses, managing time and resources, and gaps in policies.
- Some common ways to meet CMMC challenges are to use an automated risk management and monitoring solution and parenting with third party assessors.
Is this CUI?
Apart from Federal Contract Information, Controlled Unclassified Information is also included in the government’s list of data that must be protected. While CUI does not fall within the “sensitive level,” it is still sensitive enough to warrant loss of contract if unprotected.
If you process military grade data, you likely know that your organization is required to implement controls to protect CUI. The challenging part is identifying which data within their system is CUI, and understanding what exactly constitutes it.
To solve this conundrum, start by looking for DFARS 252.204-7012 or references to NIST SP 800-171 in contracts, subcontracts, or purchase orders. If the clause does not exist, you don’t have CUI.
If yes, check if you process export controlled information like the International Traffic in Arms Regulations, or ITAR.
If not, move on to the next identification step; check if you receive information marked as CUI from the DoD contractors or directly.
If not, check the Security Classification Guide (SCG) to determine if generated data qualifies as CUI.
If not, compare your data with NARA’s CUI categories like Controlled Technical Information or Critical Infrastructure Security Information. If there’s a match, you have CUI.
Cost concerns
Running an end-to-end compliance program involves a lot of work. Typically, this includes assessment costs, audit preparation costs, training expenses, the cost to implement controls, consultation charges, and cloud migration costs.
Depending on how much work you have already done (level of readiness with NIST) and what technology you are using (semi or fully automated tools) to manage the compliance activities, companies spend millions to earn DoD’s trust.
Needless to say, investing in CMMC certification has a high long-term return. However, organizations, especially smaller ones, initially struggle to bear the cost, necessitating the need to optimize the cost.
One way to reduce costs is by using compliance automation tools like Sprinto. Platforms like Sprinto connect with your cloud stack to automatically monitor controls and alert your team in case of non-compliance. This helps you significantly reduce the resource and time constraints to get compliant. Get a demo today.
Resource and time constraints
Cost concerns are not the only drawback of running an extensive compliance program. Concerns around the bandwidth of resources and deadlines are also a constant source of apprehension among CMMC aspirants.
CMMC compliance is not a one-time task. The certification’s validity expires every three years, making the program a continuous commitment of time and resources.
Given that federal contracts will not start pouring in until you are certified, businesses generally set an internal deadline to complete the compliance project.
Time and resources are squeezed even more with a chasing deadline and budget constraints. Both these constraints go up as the maturity Level increases. For example, NIST 800 171 has 320 requirements categorized within 110 controls. A significant amount of time and resources goes into implementing them and collecting evidence.
Unfortunately, there is no shortcut to CMMC’s finish line. However, a few strategies can help you manage these challenges.
First, try to plan every aspect from the beginning. Since compliance involves many bits and nuances, businesses easily torpedo it into chaos.
Second, using an automated tool to map controls to checks, collect evidence, and continuously monitor the CUI environment for non-compliance significantly reduces the manual workload.
Completing third-party assessments
If you are undergoing a CMMC certification assessment of Level 2 or up, a Third-Party Assessment Organization (C3PAO) evaluates your posture. Logistically speaking, this differs from a self-assessment in quite a few aspects. External auditors may not be forgiving of your shortcomings, and if you are getting assessed for the first time, there might be quite a few road bumps to getting it right.
To give you a rough idea, the assessment process entails:
- Developing a System Security Plan (SSP) that includes the network diagram, software inventory, and more
- Policies and plans for all 14 security domains in NIST, along with its supporting documents
- Physical inspection of your systems and CUI if any
In short, the assessor evaluates whether the controls are functioning effectively and whether you have done what you claim to have done.
Given the scope and complexity of CMMC audits, you should partner with a service provider to guide you through the process.
Poorly documented policies
The proof is in the pudding, and your pudding is documented. Like any other compliance audit, the CMMC regulators take documentation quite seriously. Every activity from start to finish should be documented clearly and comprehensively.
While businesses understand its importance, they stumble at the requirements. Often, the result is inadequate and insufficient documentation, leading to assessment failure. As previously stated, you need policies and procedures for all applicable security domains of NIST.
The System Security Plan (SSP) is a comprehensive document that outlines how an organization meets each of the 320 requirements across 110 CMMC controls. It maps the entire in-scope infrastructure, inventories all assets, tracks data flow, identifies risks, and details the measures and policies implemented to mitigate those risks.
Despite its critical role, many organizations struggle to grasp the specific SSP documentation requirements under CMMC fully.
To successfully prepare for certification, those leading CMMC efforts must ensure the SSP:
- Clearly defines how each requirement is addressed with adequate detail.
- Includes all necessary elements, including infrastructure scope, asset inventories, data flow maps, and risk mitigation strategies.
- Provides objective evidence to demonstrate compliance with CMMC controls.
Organizations must also structure the SSP for clarity and accessibility, enabling assessors to locate the required information during evaluations quickly. This means organizing content logically, using consistent formatting, and providing cross-references to supporting evidence.
Tackling CMMC challenges with Sprinto
Obtaining CMMC 2.0 compliance is no small feat. For contractors handling sensitive DoD data, the stakes are high—every step requires precision, from monitoring and documentation to remediation. Sprinto steps in to streamline this daunting process.
Sprinto supports 15 industry-standard frameworks like ISO 27001, SOC 2, GDPR, PCI, and HIPAA, Sprinto offers a comprehensive compliance solution. It recognizes the unique demands of mid-market companies and frameworks like CMMC.
One standout feature is the new ‘Bring Your Own Framework’ functionality, enabling users to integrate custom frameworks like CMMC directly into the platform. Sprinto also enhances framework mapping to provide more granular controls to ensure seamless alignment with diverse requirements.
Here’s a gist of how it helps you tackle CMMC challenges:
- Continuous Compliance Monitoring: Tracks controls continuously, flagging anomalies in near real-time.
- Proactive Issue Remediation: Automatically detects deviations and triggers corrective actions.
- Automated Evidence Collection: Saves time by gathering audit-ready evidence effortlessly.
- Pre-Built Templates & Training: Ready-to-use policies and modules aligned with SOC 2, ISO 27001, and now CMMC.
- Collaborative Audit Dashboard: Centralizes evidence review and simplifies certification prep.
- White-Glove Support: Expert guidance from setup to certification.
With Sprinto, compliance becomes a part of your daily operations—and not an overwhelming task that saps your resources. It helps you ensure you’re always audit-ready and aligned with the rigorous demands of CMMC 2.0. Schedule a demo today.
