As CMMC is finalized, many organizations will find themselves scrambling to schedule their third-party audit with a C3PAO. However, when the time comes, a good portion of these businesses may find they are woefully unprepared for CMMC compliance. Oftentimes, these failures present themselves in the opening discussions of the audit. The most common reason that organizations fail their audit is incorrect scoping. Alongside poor documentation and training, failure to understand your CUI boundary is a surefire way to lose contracts and business.
Why Organizations Fail CMMC - Scoping
The make-or-break moment for every contractor usually comes before the audit even begins -- with scoping. Scoping lays out the foundation of your upcoming audit -- building a map of where CUI exists, who has access, and how it is secured. Accurate scoping will determine how much work is required to achieve compliance and defines the systems and services that will be audited. Think of these phase as building a map. Your "map" must show where your critical information lives or moves and how it is accessed. Without this understanding, there is no way to protect your data or to prove that you do.
Failing to accurately scope your CUI boundary can lead to an immediate failure. Businesses tend to leave out the small things including printers or mobile devices. If an employee views CUI via an email on their phone -- then that device is in scope. If you print CUI -- then that printer is now in scope. These things must be documented before your audit.
Why Organizations Fail CMMC - Documentation
As previously mentioned, it isn't enough to simply "do" all of the things -- you also have to "prove" you do all the things. Even if your organization has implemented every control perfectly, if there is no documentation explicitly proving you have, then it ultimately means nothing. This means that your organization must have evidence for all 320 assessment objectives, covering all 110 NIST 800-171 controls. Your documentation must be both specific and dynamic. CorpInfoTech has gone through a CMMC level 2 audit, so we understand just how granular this evidence can get. Your documentation must also be up to date. Employees leave and are hired, devices are upgraded, permissions are changed -- the process in which you make these changes must be documented.
Why Organizations Fail CMMC - Training
Your users don't know what they don't know. Educating them on the importance of protecting CUI for not only your organization, the nation's security posture as a whole, is a crucial part of CMMC compliance. Every level of the organization needs to have an understanding of how to identify CUI, what to do if they encounter CUI, and how to respond to potential CUI leaks. Many organizations are already on top of this and have robust training libraries with great information-- but is it tracked? When your audit comes, it isn't enough to say that you train your users.
Why Organizations Pass CMMC - Choosing the Right MSP
For many small-medium sized defense contractors, compliance can be complex, tedious, and expensive. This is why many of these organizations partner with a managed service provider (MSP) to help reach their compliance goals. However, not every MSP is created equal. Some MSPs may claim to be "self-certified" under CMMC and, while possible, cannot offer the same level of service as a C3PAO-certified MSP. If your MSP has not undergone their own third-party CMMC audit, their compliance posture is part of your businesses scope. This means that if your MSP fails to meet a particular requirement, it will directly impact your audit. Additionally, any tool or application change within your MSP that may impact the security of CUI will trigger a reaudit. You will start the whole process over again-- and these audits aren't cheap.
Conversely, a C3PAO-certified MSP is one that has already gone through their audit and passed. These MSPs have proven to the DoD that they are able to secure CUI and provide their services to contractors. CorpInfoTech is an example of a C3PAO-certifed MSP that has achieved CMMC level 2 compliance via a third-party audit. Through TAS for CMMC Compliance, contractors are able to inherit 200+ of the 320 assessment objectives required by CMMC. This ensures achieving compliance is efficient, simple, and cost effective. Our solution is also flexible, offering fully or co-managed support for on-prem technologies. Our comprehensive solution helps contractors achieve and maintain CMMC compliance while giving your business the freedom to access your data when needed.
Connect with CorpInfoTech to discover how our experts can guide your organization to CMMC compliance.
CorpInfoTech, a Managed Service Provider (MSP) with over 25 years in the SMB space, is a trusted partner for business pursuing compliance and cybersecurity. We are a CMMC Level 2 (C3PAO) certified MSP and a Cyber AB Registered Provider Organization (RPO). Also, as the first CIS accredited organization, we help organizations implement the CIS controls as it pertains to CMMC and your overall cybersecurity posture. CorpInfoTech is your trusted partner for secure, compliant growth in every changing digital landscape.
