CMMC Compliance Tracking: Should You Invest in a GRC Tool?

“Should I implement a GRC tool to help me track CMMC” is a popular question in the ecosystem among those who understand that getting to the assessment is only one part of CMMC success. Once the assessment is complete, you have to ensure your company remains compliant and completes its affirmation in SPRS yearly between official CMMC assessments with a C3PAO. While there are many benefits to using compliance management platforms, the decision to do so isn't one-size-fits-all.

Understanding GRC Tools in the CMMC Context

GRC tools are integrated software platforms designed to help organizations manage their compliance obligations, assess risks, and maintain governance frameworks.

In the context of CMMC, these tools typically offer:

• Compliance Project Management: Tracking CMMC control implementation status, with workflows for evidence collection and validation, as well as project management features to maintain accountability for POAM entry completion.
• Risk Assessment: Risk analysis capabilities that help identify vulnerabilities and prioritize remediation efforts based on CMMC requirements.
• Documentation Management: Centralized repositories for policies, procedures, and evidence artifacts required for CMMC assessments.
• Continuous Controls Monitoring: Real-time dashboards and reporting capabilities that provide compliance posture visibility and highlight areas requiring attention.
• Audit Trail Management: Comprehensive logging and reporting features that create detailed records of compliance activities for assessor review.
• System Security Plan Updating: Many GRC tools provide automated SSP creation based upon your input for each control.

Key Questions for Decision-Making

Before investing in a GRC tool, organizations should honestly assess their specific needs and circumstances by asking critical questions:

• What is the scope of your CMMC obligations? Organizations pursuing CMMC Level 1 compliance have significantly different requirements than those targeting Levels 2 or 3 certification. The complexity and volume of controls you need to manage directly impacts whether a dedicated tool provides value or creates unnecessary overhead.
• How many contracts and customers require CMMC compliance? If you're managing compliance for multiple contracts with varying requirements, or serving customers across different CMMC levels, the coordination challenges may justify a sophisticated tracking system.
• Do you have regulatory obligations beyond CMMC? If CMMC is not the only regulatory obligation you’re tracking compliance with, you may want a more robust tool that addresses multiple frameworks.
• What is your team's technical expertise? GRC tools often require dedicated personnel for configuration, maintenance, and operation. Consider whether you have staff with the necessary skills or budget for training and ongoing support. As you assess this, consider their skills with the current software as well as when learning new software. You may have individuals who are great with Excel and program management software because they’ve been using it for decades, not because they are technically apt and learn new software easily.
• How mature are your current processes? Organizations with well-established security and compliance processes may benefit more from GRC tools than those still developing foundational capabilities. Sometimes, implementing basic processes manually is more appropriate before investing in automation. This will help you see the technical aptitude of your team members and understand what information you want to track with your GRC tool.

Critical Considerations Beyond Initial Cost

While the upfront cost of GRC tools often receives the most attention, several other factors significantly impact the total cost of ownership and long-term value:

• Implementation Complexity: Most GRC tools require substantial customization to align with CMMC requirements and your organization's specific environment. This process often involves mapping existing controls, configuring workflows, and integrating with current systems. You’ll want to budget for possible professional services and internal staff time during implementation. At a minimum, you will need to budget for learning time for your CMMC Program Owner and anyone who will be responsible for updating and maintaining the system for progress on controls and documentation updates.
• Switching Costs: Once you've invested in a particular platform, migrating to a different solution becomes expensive and time-consuming. Consider the long-term commitment you're making and evaluate whether the vendor's roadmap aligns with your organization's growth plans and evolving compliance needs. If your team is well trained on your current system and it will grow with them over the years, now may not be the time to invest. However, if your team is concerned with the time it takes to update various tools, now may be a perfect time.
• Ongoing Maintenance: GRC tools require regular updates to maintain alignment with changing requirements, security controls, and regulatory guidance. Factor in the cost of maintaining current configurations, training staff on new features, and ensuring continued integration with your IT environment.
• Vendor Lock-in: Some platforms make it difficult to extract your data and configurations if you decide to change solutions. Evaluate data portability and ensure you maintain control over your compliance artifacts and documentation.
• Documentation Formatting. While many GRC Tools offer a live document feature, many of them strip out all but basic formatting. If formatting matters to your organization and you don’t have a separate document management system, be sure to test this feature before making your selection.
• Scalability Requirements: Consider whether the tool can accommodate your organization's growth, additional compliance frameworks beyond CMMC (when applicable to your organization), and evolving business needs without requiring complete reconfiguration or platform changes.

Factors Influencing the Right Choice

Several organizational characteristics significantly influence whether GRC tools provide value:

• Team Size and Structure: Organizations with dedicated compliance teams of 3+ people often benefit from GRC tools' workflow management and collaboration features. Smaller teams may find the overhead of managing a complex platform outweighs the benefits.
• Customer Base Complexity: Companies serving multiple customers with different compliance requirements, or managing numerous contracts with varying security specifications, often require the coordination capabilities that GRC tools provide.
• Regulatory Environment: Organizations subject to multiple compliance frameworks (CMMC, SOC 2, ISO, NIST, HIPAA, PCI) typically find GRC tools valuable for managing overlapping requirements and reducing duplicated effort.
• Assessment Frequency: Companies undergoing frequent assessments or maintaining continuous compliance monitoring benefit from automated evidence collection and real-time reporting capabilities.
• Geographic Distribution: Organizations with distributed teams or multiple locations often require centralized platforms to coordinate compliance activities effectively.

Making the Decision

Success with GRC and other compliance management tools depends on your team's ability to use them effectively. Start with your current processes and identify specific challenges. Would a GRC platform solve these issues, or do you need to address fundamental process gaps first?

Many organizations find success starting with basic tools like spreadsheets or project management software. These simpler solutions help teams understand their requirements before considering enterprise platforms. The key is selecting a tool that:

• Fits your operational workflow.
• Your team will consistently use.
• Provides clear value for your compliance efforts.

The most effective compliance tool is one that becomes part of your daily operations, regardless of whether it's a sophisticated GRC platform or a well-maintained spreadsheet. Choose based on what works for your organization.