A CMMC Gap Assessment is a systematic review that compares your organization's current security posture against CMMC requirements. It measures how well your cybersecurity practices, technical controls, and documentation align with the standards needed to achieve CMMC Level 2, the certification level required for contractors handling Controlled Unclassified Information (CUI).
The assessment identifies gaps where security controls are missing, partially implemented, or lack proper documentation. These gaps show exactly where you must improve policies, strengthen technical protections, or create evidence before pursuing formal certification. Contractors who perform a gap assessment early understand their cybersecurity posture and can prioritize remediation by risk and contract deadline.
The CMMC 2.0 framework integrates NIST SP 800-171 controls, so CMMC gap analyses reference the NIST 800-171a assessment procedures available through the National Institute of Standards and Technology (NIST) here. This alignment means organizations address both CMMC compliance and NIST 800-171 requirements simultaneously.
DoD contractors must achieve CMMC to bid on and execute contracts involving Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). Without the required CMMC Level, companies lose contract eligibility before proposals are evaluated. CMMC Level 2 is the standard for protecting CUI and requires documented policies, implemented security controls, and evidence that cybersecurity practices operate consistently.
A CMMC gap assessment prevents costly surprises during formal CMMC assessments. It builds a roadmap for closing weaknesses before the C3PAO arrives. This proactive approach reduces audit risk, compresses compliance timelines, and increases first-pass certification rates. Most gap assessments take 2-4 weeks and deliver actionable findings organized by severity.
The gap assessment also strengthens your security posture beyond compliance. Organizations learn which controls reduce breach risk, which policies need updating, and where staff training has gaps. This insight drives continuous improvement and demonstrates to contracting officers that your cybersecurity practices protect sensitive defense information.
The gap assessment process reviews your cybersecurity policies, procedures, technical configurations, and artifacts against specific CMMC Level requirements. Experienced assessors compare current controls to the 110 practices in NIST SP 800-171 and document findings with remediation priorities.
Key steps include:
Document Review: Evaluate existing policies, incident response plans, access controls, and your System Security Plan (SSP).
Interviews: Engage personnel responsible for cybersecurity to verify practices, test awareness, and confirm control operation.
Technical Evaluation: Assess system configurations, network segmentation, logging, and implementation of security controls.
Control Mapping: Align current controls with CMMC practices and identify gaps where controls are missing or incomplete.
The assessment produces a detailed report that categorizes compliance gaps by severity and impact. This report becomes the foundation for your Plan of Action and Milestones (POA&M) and guides remediation planning.
For organizations seeking methodology guidance, the Department of Defense provides a NIST SP 800-171 Assessment Methodology that complements CMMC assessment efforts.
Organizations pursuing CMMC Level 2 readiness encounter predictable gaps. Common findings from CMMC gap analyses include:
Incomplete or Missing Policies: Lack of formally documented cybersecurity policies or procedures that do not reflect actual practices.
Insufficient Access Controls: Weak user authentication, improper privilege management, or missing multifactor authentication for systems processing CUI.
Inadequate Incident Response Plans: No formal incident response process, untested procedures, or missing post-incident review documentation.
Poor Configuration Management: Systems not configured to DoD security baselines or missing change control procedures.
Lack of Continuous Monitoring: Insufficient logging, no centralized log review, or vulnerability scans without closure tracking.
Training Deficiencies: Employees unaware of security policies, missing role-based training, or no documentation proving training completion.
Identifying these gaps early allows contractors to allocate budget strategically and close deficiencies before CMMC assessments begin. Organizations that address high-severity gaps first reduce overall remediation time and improve audit outcomes.
Conducting an effective CMMC Gap Assessment requires structure and attention to evidence. Follow these steps:
Define Scope: Determine which systems, processes, and personnel fall under CMMC requirements. Map where CUI and FCI flow through your environment and document boundaries clearly.
Gather Documentation: Collect existing cybersecurity policies, your System Security Plan (SSP), access control records, and relevant artifacts that prove control operation.
Engage Stakeholders: Involve key personnel responsible for cybersecurity, IT operations, and compliance. Confirm who owns each control and who can demonstrate implementation.
Perform Assessment: Evaluate current controls against CMMC requirements through document review, staff interviews, and technical validation.
Analyze Findings: Identify gaps and prioritize based on risk, contract timing, and remediation complexity.
Report Results: Document findings in a clear, actionable report that specifies which controls need work, what evidence is missing, and where policies diverge from practice.
Develop Remediation Plan: Use the gap assessment to create a Plan of Action and Milestones (POA&M) with owners, deadlines, and acceptance criteria.
Neutral Partners guides organizations through this process to ensure thoroughness and alignment with DoD expectations. We structure findings the way C3PAOs review controls, which reduces back-and-forth during formal assessments.
A Plan of Action and Milestones (POA&M) is the working document that tracks how you will close identified cybersecurity gaps. The CMMC gap assessment report directly informs the POA&M by specifying which controls require remediation, the resources needed, responsible parties, and target completion dates.
A well-constructed POA&M structures remediation efforts, makes progress measurable, and aligns timelines with contract award dates. It also demonstrates to C3PAOs and DoD contracting officers that your organization actively manages cybersecurity risks and tracks closure with evidence.
Organizations can use POA&M tools available through the DoD's Procurement Integrated Enterprise Environment (PIEE) to track progress and maintain compliance documentation. Keep the POA&M synchronized with your System Security Plan (SSP) and SPRS score so discrepancies do not create audit risk.
Neutral Partners conducts CMMC Gap Assessments with focus on clarity, speed, and actionable results. Our assessment process delivers the evidence and roadmap contractors need to achieve CMMC certification on aggressive timelines.
Customized Scoping: We define scope with you based on CUI location, contract requirements, and business operations. Clear scoping keeps projects manageable and prevents assessment drift.
Experienced Assessors: Our team has deep expertise in CMMC, NIST frameworks, and DoD cybersecurity regulations. We know what C3PAOs check and how they score findings.
Comprehensive Evaluation: We analyze policies, technical controls, and organizational processes to identify gaps. We test controls, review artifacts, and interview staff to confirm implementation.
Clear Reporting: Our gap assessment reports prioritize findings by risk and impact. We recommend practical remediation steps with time estimates and budget considerations.
Remediation Support: We build POA&Ms with owners, milestones, and deadlines. We integrate gap assessment results into broader risk management strategies and track closure with evidence.
Ongoing Compliance Services: Beyond gap assessments, Neutral Partners offers managed compliance services to maintain readiness after certification. We schedule control tests, update documentation, and keep evidence audit-ready year-round.
Our approach prepares organizations for first-pass CMMC certification success. We structure evidence the way assessors expect, which compresses assessment time and reduces findings. Most clients complete gap assessments in 2-4 weeks and close high-priority gaps within 90 days.
Use authoritative sources while conducting your CMMC gap analysis and building remediation plans:
The official CMMC Resources and Documentation page maintained by the DoD
The Cyber AB Marketplace for certified CMMC assessment organizations
NIST Special Publication 800-171a for detailed assessment procedures: NIST SP 800-171a
The DoD's Procurement Integrated Enterprise Environment (PIEE) for compliance management tools
For a deeper understanding of the CMMC framework and certification requirements, visit Neutral Partners' dedicated page on CMMC and our Gap Assessment service.
Neutral Partners conducts gap assessments that prepare defense contractors for first-pass certification success. We identify gaps, build prioritized POA&Ms, and structure evidence the way C3PAOs expect. Schedule a consultation with Neutral Partners to identify and close your CMMC compliance gaps efficiently.