For defense contractors eager to keep the cost and time requirements of CMMC compliance to a minimum, there’s a simple strategy: close the most common gaps before pursuing certification. Having helped numerous contractors prepare for certification and plan sustainable cybersecurity, these are the problem areas we see most often:
1 – Lack of Visibility into Data and Systems
CMMC readiness begins with visibility. Until you know all the federal contract information (FCI) and controlled unclassified information (CUI) you have in your possession, and all the systems and silos that data interfaces with, you have no idea where your cybersecurity requirements start and stop. We’ve found that many contractors have a sense of where protected data is located rather than a clear, accurate, and comprehensive map. Part of the problem is the scale of FCI and CUI and the complexity of today’s IT environments. Shadow IT and undocumented processes add to the uncertainty. Before doing anything else, make sure you have the ability to see into all your data and systems to locate DoD data everywhere it exists.
2 – Access Controls Issues
Access controls are the cornerstone of cybersecurity, which means that anywhere weak controls are present puts data—and by extension compliance—at risk. In our experience, contractors give too much access to too many users. Instead of limiting access to only the people who need to see FCI or CUI, and only the information they need to complete their jobs, access is granted broadly, usually because it seems more efficient. We have also encountered many instances of shared credentials and legacy permissions, which are not only prohibited by CMMC but create easy targets for attackers (and a breach is much worse than non-compliance). The solution starts by identifying who needs access to what, prohibiting everyone else, and enforcing strict password hygiene.
3 – Documentation that Doesn’t Match Reality
One of the most common mistakes around CMMC is focusing too much on compliance and not enough on cybersecurity. We’ve worked with many contractors that have policies claiming they do everything CMMC requires. But they don’t have proof it’s actually being done. For example, their documentation says multi-factor authentication is enforced at all entry points, but a simple login attempt proves it’s not. The gap between documentation and reality is a problem because an audit makes it quickly apparent. And once assessors find one discrepancy, it calls all policies and protections into question. Rather than raising the specter of doubt, make sure there’s proof for everything the documentation claims.
4 – ERP and Line-of-Business Systems Overlooked
Maybe the biggest misconception we come across is the idea that ERP (and other line-of-business systems) are for running a company, not handling the production process, therefore they fall outside the scope of CMMC. That’s not necessarily the case. Furthermore, ERP systems that are in scope may not meet the requirement for cloud-based systems to be FedRAMP compliant. The reality is that ERPs can complicate and jeopardize compliance in many ways, especially when they’re considered out of scope. Doing the opposite, treating them as in scope until proven otherwise, often makes the process easier overall even if it makes the scope greater than expected.
How to Efficiently Close Cybersecurity Gaps
Many if not most of the defense contractors we’ve assisted have dealt with one or more of the gaps outlined above. The reality is that few companies are ready for CMMC compliance out of the gate, and even those that have been planning and preparing may still struggle to check all the boxes. Instead of expecting perfection, we recommend following a process:
- Identify the biggest gaps and make those the priority. Look for what will take the longest or require the largest amount of time, staff, and disruption.
- Make incremental improvements rather than large-scale changes. Equally important, ensure that improvements will stick, not just until the first audit but permanently.
- Be realistic about whether you can find and fix all the compliance gaps or need to enlist outside assistance. Hiring experts may ultimately be faster, cheaper, and easier than proceeding in-house.
If you’re looking to close gaps and get compliant or realizing you need help from specialists in CMMC and cybersecurity, Guide Technologies is here to help. Use our experience and expertise to your advantage and turn compliance and cybersecurity into competitive strengths.
We’re ready to have a conversation whenever you are. Contact Guide Technologies.
