What Does A Gap Analysis Tell You About Your CMMC 2.0 Readiness?
Cybersecurity | Compliance | CMMC 2.0
A gap analysis is critical for contractors and subcontractors within the Defense Industrial Base (DIB) who need to become compliant with the Cybersecurity Maturity Model Certification 2.0 regulation.
That’s because a gap analysis gives organizations a snapshot of their CMMC preparation by weighing their current security defenses against the standards set within the cybersecurity regulation. So, they’re able to accurately gauge where they stand in the compliance process.
If you skip this step in the compliance process, you won’t be able to get certified. Without certification, you risk losing your existing DoD contracts and possibly become ineligible to bid on new ones.
In this article, we’ll explain what a gap analysis is, what businesses can learn from it, and why it’s critical to becoming CMMC compliant.
After reading this article, you’ll understand why a gap analysis is so crucial and what exactly it tells you about your CMMC readiness.
What Is A CMMC Gap Analysis?
Although you may have heard of a gap analysis, are you aware that not all gap analyses are the same? As we’ve mentioned above, a gap analysis is an essential part of becoming CMMC compliant.
The CMMC 2.0 Final Rule, which went into effect in December 2024, establishes a three-leveled system of compliance and assessment standards for organizations doing business with the Department of Defense (DoD) that handle federal contract information (FCI) and controlled unclassified information (CUI).
A CMMC gap analysis is intended to allow businesses to check their CMMC audit readiness before their official audit.
Related Article: CMMC Step 2: How A Gap Analysis Can Help You Find Your Security Risks
By highlighting both known and hidden cybersecurity vulnerabilities, a gap analysis is an effective evaluation tool to assess an organization’s current cybersecurity posture against the regulatory requirements of CMMC 2.0.
Since CMMC 2.0 draws heavily from NIST SP 800-171 (National Institute of Standards & Technology Special Publication), most contractors and subcontractors should already have security controls in place.
That said, CMMC 2.0 adds the assessment provision, which requires organizations with the DoD supply chain to prove that they’ve implemented the proper security controls to maintain the security and integrity of the sensitive federal data they store, process, or share.
These assessments were added to CMMC 2.0 as a way to add teeth to previous cybersecurity requirements of the NIST and DFARS (Defense Federal Acquisition Regulation Supplement) frameworks.
That’s where a gap analysis come in.
Essentially, your gap analysis is your starting point or baseline to determine where you are in your compliance journey and how far you still have to go to satisfy the 110 NIST SP 800-171 security requirements outlined in the regulation (for Levels 2 and 3).
Does The CMMC Readiness Process Start With A Gap Analysis?
While a gap analysis is one of the most important first steps in the process, it’s not the first step.
Before a gap analysis can be performed, it’s critical that businesses determine their required CMMC level and understand the type of FCI and CUI they handle.
Related Article: 5 Questions To Pinpoint Your Required CMMC Level
Organizations must also create a flow chart to pinpoint where such data lives in their environment—including which databases, physical files, applications, systems, processes, and company staff it touches.
This allows businesses to scope their environment to create a boundary identifying where the FCI or CUI data is stored, accessed, or transmitted.
In this way, organizations are able to narrow the focus of their gap analysis and subsequent remediation efforts. This can substantially reduce valuable time and money that would otherwise be wasted implementing security controls for out-of-scope areas.
Why Is A Gap Analysis Key To Proactive Cybersecurity & CMMC Compliance?
Performing a CMMC gap analysis not only provides vital information to help businesses find and fix security defects within their infrastructure, but it’s also mandatory. Without a gap analysis, you can’t get assessed or certified.
Beyond the regulatory requirement of a gap analysis, there are a number of other reasons why it is such a critical part of the compliance process.
Those reasons include:
- Without a thorough gap analysis, there is no way to verify what your current cybersecurity posture is and which corrective measures need to be implemented to close any remaining security gaps.
- When entering the results of your gap analysis to the government through the DoD’s online portal, you must also update your Supplier Performance Risk System (SPRS) score. This will show you where your current cybersecurity measures fall short compared to the CMMC standards.
Related Article: What’s The Difference Between An SPRS Score & A CMMC Score?
- At the time the results of your gap analysis are submitted into the SPRS portal, you must also submit a plan of action and milestones (POAM) to spell out exactly which security controls you plan to put in place to correct security flaws. Your POAM is another core CMMC assessment requirement.
- Besides identifying security defects, a gap analysis is also important to help you learn where exactly you can and cannot have FCI and CUI data within your environment.
- A gap analysis helps you save valuable time and money by focusing remediation efforts only on targeted parts of your environment.
- When using a trusted external IT services provider to perform the gap analysis, you can also get an estimated timeline for completing the CMMC preparation steps ahead of your official audit.
- Your managed IT service provider (MSP) can also provide a cost estimate for becoming fully compliant.
Related Article: How to Cut CMMC Compliance & C3PAO Audit Costs: Grants, MSPs & More
What’s Included In A Gap Analysis For CMMC Compliance?
Many organizations partner with an MSP to conduct their gap analysis as a way to get thorough, unbiased analysis. Not all providers offer the same services or present compliance findings the same way, however.
So, the value you gain from your gap analysis will largely depend on the provider you choose to perform it.
This means that you’ll have to do your research to ensure that you select a provider with the regulatory knowledge, technical skillset, and available resources to perform a gap analysis.
At Kelser, we deliver several key services as part of our comprehensive CMMC gap analysis. We will:
- Work with the client to establish the CMMC boundary (for FCI and CUI)
- Determine a calculated SPRS score
- Perform a comprehensive gap analysis of your scoped environment
- Deliver a thorough gap analysis report that presents the security vulnerabilities using clear, accessible language
- Collaborate with your internal stakeholders to develop a detailed remediation plan (POAM) that outlines exactly how and when the security flaws will be corrected
The Bottom Line: Meeting CMMC Compliance With A Gap Analysis
After reading this article, you now know what a CMMC gap analysis is, what information organizations learn from it, and why it’s critical to becoming CMMC-ready and getting certified.
CMMC compliance is not just a catchphrase in cybersecurity. The revamped regulation makes becoming compliant and getting assessed, whether through a self-assessment or certified third-party assessor organization (C3PAO), unavoidable.
Failing to put in place the necessary remediation devices, systems, policies, procedures, and personnel to protect the sensitive federal data you handle could have serious consequences.
For starters, a failed assessment and lack of follow-up measures to correct defects through a POAM could result in the loss of your existing DoD contracts. It could also disqualify you from being eligible for new contracts. For many small and medium-sized enterprises, the loss of this core revenue source could be financially crippling.
What’s more, your organization could potentially face substantial fines, penalties, or lawsuits brought by the government for cybersecurity noncompliance.
If you don’t already have an IT services partner to lead your CMMC readiness journey, reach out now by clicking the button. We’re here to help.
