Getting Started with CMMC: Practical Steps for Defense Contractors

As a defense contractor, you may not know yet where to begin preparing for your CMMC certification assessment. Here are some initial steps to support you with identifying your company’s current CMMC compliance status and talking with management about your steps forward.

Understanding Your Starting Point

The Department of Defense has made it clear - cybersecurity is non-negotiable for defense contractors. Before diving into the assessment process, you need a clear picture of where you are today. Here are some steps to help you begin.

1. Access and Read Official Resources

Start by visiting and bookmarking the DOD CIO Resources webpage. This is your source for authoritative, up-to-date information about CMMC requirements. Download these essential documents:

Internal Resources:

• CMMC Scoping Guides
• Assessment Guides

External Resources:

• CMMC Assessment Process (CAP)
• NIST SP 800-171 Rev. 2: Protecting CUI in Nonfederal Systems
• NIST SP 800-171A Rev 2: Assessing Security Requirements for Controlled Unclassified Information

Treat these documents as your operations manual as you prepare for your CMMC Certification Assessment. Read the Scoping Guides first to identify your CMMC System boundaries for FCI and CUI. Then cross-reference with the Assessment Guides to understand what you must consider for each of the controls addressed within the CMMC Level to which you will certify. Finally, review the CAP to know exactly how a Certified Third-Party Assessment Organization (C3PAO) will assess you—and what documents you will need as you engage in Preliminary and Pre-Assessment Phase discussions.

2. Document Your Current Environment

Create a detailed inventory of your systems and processes. This includes:

• Network infrastructure
• Hardware assets
• Software applications
• Data storage locations
• Communication systems
• Security controls
• Employee access

Use simple spreadsheets or free network-mapping tools. This exercise reveals shadow IT, outdated devices, and possible gaps in procedures related to new PC configuration, resource onboarding and decommissioning, and encryption.

Photo by Kelly Sikkema on Unsplash

3. Map Your Sensitive Information

Identify how and where your organization handles Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). This critical step helps determine your certification level and assessment scope, as the data must be handled within system boundaries. Consider:

• Contract documents
• Technical specifications
• Manufacturing data
• Design documents
• Email communications
• Cloud storage

As you map this out, you’ll gain a clear understanding of where your CUI and FCI lives, how you are handling it, and what resources within your organization process, store, or transmit it. You’ll have the foundations for your Data Flow Diagrams, which are important for easily identifying when data isn’t where it should be during assessments and reviews. Be sure to include:

• Physical locations
• Digital storage
• Communication channels
• External sharing processes

Understanding your CUI and FCI footprint helps determine your assessment level, scope, and required security controls. If both types of information flow through the same boundary (your CMMC system), you will complete a single assessment for both, working off the Level 2 guide. However, if your system boundaries aren’t the same for both CUI and FCI, you will have to complete both a Level 1(self-assessment) and a Level 2 assessment (most likely with a C3PAO) separately.

4. Evaluate Existing Security Controls

While you can hire a consultant at this stage, if you have an internal CMMC resource assigned to your program, we recommend that you first do an internal review of your current security measures against CMMC requirements. Focus on:

• Access controls
• Network security
• Data protection
• Physical security
• Incident response procedures
• Security awareness training

During this step, you’ll use the Assessment Guide corresponding to your expected CMMC Level and read the appropriate NIST SP 800-171 Rev 2 security controls and related assessment objectives to ask yourself: “Do we fully or partially implement this, or not at all?” Document findings in a gap-analysis matrix.

This assessment gives you a prioritized action list. Controls tied to access management, incident response, and encryption often surface as immediate fixes. Tackling those first reduces your risk profile and supports you in preparing for your CMMC Certification Assessment.

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Moving Forward

After you’ve completed the above steps, you will have a more accurate view of where you stand. You’ll be better prepared to respond to the CCRA and other inquiries about your cybersecurity posture. It’s okay to realize at this point that you need more help than you have on staff currently. The steps above should prepare you to have those conversations with your management team so you can determine next steps.

You aren’t alone if you realize that a one or two-person team focused on serving your entire company’s IT and compliance needs isn’t enough. Many defense contractors find that preparing for CMMC certification requires more expertise than they have in-house. Cybersecurity compliance is complex with high stakes and sometimes confusing requirements that require discussion with others who understand the source material. We recommend if you decide to bring in external help that you interview at least 3 consultants to see which will be the best fit based upon your current standing, assessment date goals, and budget.

CMMC certification is about securing data, not just checking boxes. You’re preparing for an assessment of your current environment, not an audit. The assessors want to see that you’ve implemented sustainable cybersecurity practices that protect your business and your customers.