Identify where FCI and CUI exist in your systems. Build a boundary around systems that process, store, or transmit CUI. Only these systems need full NIST SP 800-171 controls. Use network segmentation to separate CUI environments from the rest of your infrastructure. Smaller scopes mean faster assessments and lower costs.
Compare your current state to the 110 security requirements in NIST SP 800-171. Mark each control as MET, NOT MET, or NOT APPLICABLE. Common gaps include missing multi-factor authentication, incomplete audit logging, and weak incident response plans. Fix critical issues first. These cannot go into Plans of Action and Milestones (POA&Ms).
Address gaps before scheduling your C3PAO audit. Deploy needed security tools. Write required policies. Train staff on information security requirements. Build evidence as you go. Screenshots, config exports, and training records prove compliance during assessment. Document remaining items in POA&Ms if you score 88 or higher.
Schedule your C3PAO assessment once remediation is complete. The assessor reviews your System Security Plan, interviews staff, and validates all 110 controls. A score of 88 or higher passes. Perfect scores of 110 earn Final Level 2 status immediately. Failed audits require complete reassessment and add months to your timeline.
Hire experts to handle documentation and policy work. This frees engineers for technical fixes only. Automate logging, patching, and scanning. Leverage existing tools before buying new ones. Run internal mock audits before the formal C3PAO review. Catch issues early when fixes are cheap.
Start by reading the DoD CMMC about page and downloading NIST SP 800-171. Define your scope and run an honest gap assessment. Budget 12 to 18 months if starting from scratch. Companies with strong security can move faster.
Remember that CMMC certification requires triennial C3PAO assessments and annual affirmations. Plan for ongoing compliance without constant engineering involvement.
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