After many months, perhaps even more than a year of work, you’re ready to get assessed by a certified third-party assessor organization (C3PAO) under the Cybersecurity Maturity Model Certification (CMMC).
With the CMMC 2.0 Final Rule, businesses within the Defense Industrial Base (DIB) must satisfy the required 110 NIST SP 800-171 security practices.
If you’re a business at CMMC Level 2, you’re required to get assessed by a C3PAO in order to prove you’re doing all you can to protect the sensitive federal contract information (FCI) and controlled unclassified information (CUI) you store, transmit, or process.
You also recognize that a failed audit could make put you in jeopardy of losing your current Department of Defense (DoD) contracts or become ineligible to bid on new contracts.
Given the high stakes involved, you understand the importance of passing your audit to obtain your CMMC certification and continue doing business with the DoD.
In this article, we’ll discuss how audit preparation can help you confirm your CMMC readiness. With this information, you’ll know the final steps to take ahead of your assessment so you can gain peace of mind and help ensure a successful audit outcome.
What Is CMMC Assessment Preparation And Why Does It Matter?
By now, you’ve scoped your CUI boundary, identified the security gaps within your identified boundary through a gap analysis, and implemented the necessary remediation measures to correct those security flaws.
Related Article: Step 1 For CMMC Certification: Understanding Your CUI & CMMC Level
You‘ve also drafted a comprehensive system security plan that spells out all of the policies, procedures, and other controls you’ve adopted to safeguard the sensitive federal information you handle. This is another compliance requirement.
You’ve scheduled your independent CMMC audit and the date is fast-approaching.
Related Article: How To Find An Approved C3PAO For Your CMMC Level 2 Assessment
But you’re not finished yet!
Although you may feel that you’ve done all you can to meet compliance, you may still be wondering, “Will I pass my official C3PAO audit?” Assessment day isn’t the day to find out if you’re CMMC ready.
That’s where audit preparation comes in.
CMMC audit prep offers a thorough, pre-audit review of the security measures and documentation you’ve put in place to ensure that they are sufficient to meet compliance and that there are no remaining cybersecurity deficiencies that were missed.
What Are The Key Components Of CMMC Audit Prep?
While the finish line may be in sight, make sure you finish the race!
Audit preparation helps confirm that your organization’s virtual and physical environment matches your SSP in demonstrating how you’re protecting FCI and CUI at your required CMMC level.
This pre-assessment readiness step includes three core components:
1. Mock CMMC Audit
The first component is a simulated audit that mirrors what the official assessment will look like.
It helps identify any areas within your environment that may still need attention.
It also gives your team a chance to practice how to respond to potential questions that your C3PAO auditor may ask during interviews with individual staff members so they know what to expect.
Although it’s easy to overlook, knowing the right way to respond to a CMMC auditor’s questions is a critical part of passing your assessment and getting certified.
2. Evidence Collection
This second component of your pre-audit prep involves reviewing your organized documentation such as policies, training records, system logs, and settings.
This step ensures you have everything needed to demonstrate compliance and that it’s accessible and well-documented.
Your documentation review will also double-check that your policies, procedures, and other documents are finalized; working drafts will not be accepted during your audit.
3. Control Validation
This third component verifies that each security control described in your SSP is implemented, functioning, and traceable.
It confirms that your environment aligns with your CMMC requirements to ensure the ongoing security and integrity of the FCI and CUI that you store, process, or transmit.
For instance, if the auditor asks a team member to physically demonstrate how a security control you’ve outlined is being used to meet a specific CMMC requirement, this will give you assurance ahead of time that it works.
How A Pre-Audit Review And Mock Assessment Can Help You Avoid A Failed CMMC Assessment
You’ve invested considerable time and money into beefing up your security defenses to mitigate cybersecurity threats and meet CMMC compliance.
Your CMMC assessment prep ensures that all of your hard work you put in over the course of your CMMC journey doesn’t end up being in vain.
You don’t want to get this far, only to fail your assessment because you didn’t have the foresight to evaluate your preparation.
Just as students are taught in grade school to check their test answers and essays before turning them in to be graded, your final score could also be significantly affected by the amount of time you spend reviewing your work.
Thorough audit preparation offers tangible benefits to verify your organization’s readiness for your upcoming CMMC assessment.
Related Article: How To Choose A C3PAO For Your CMMC Audit: 7 Factors To Consider
Some of those benefits include:
- Provide confirmation that the security controls you’ve implemented are performing as intended
- Help identify and iron out any last-minute compliance issues
- Verify that your supporting documents accurately reflect your organization’s cybersecurity strategy
- Strengthen your team’s readiness to interact with C3PAO assessors
- Increase the likelihood of a successful CMMC audit
What Are The Benefits Of Audit Preparation And Mock Audits?
While it may seem like an unnecessary step, thorough pre-audit preparation can give you a sizeable advantage over businesses that skip this critical step.
That’s because it eliminates any lingering uncertainty you may have about whether or not your company has done enough to satisfy the CMMC requirements for your level and obtain certification.
Here’s what comprehensive audit preparation will deliver:
Gain compliance confidence
For starters, at the end of the audit preparation phase, you’ll gain peace of mind knowing that you’ve met every CMMC requirement and you’re fully prepared for your audit.
Report of findings
In addition, you’ll receive a report detailing the results of your mock audit. This will give you actionable feedback on your compliance readiness to highlight any lingering issues.
Evidence compilation
Finally, the required documents you need for CMMC certification, including your SSP, will be organized so you can have it readily available during your audit. This will serve as your documented proof of compliance. It's a core component of your assessment.
Related Article: CMMC Step 4: SSP Documentation–What’s Your CMMC Compliance Evidence?
The Bottom Line With CMMC Audit Preparation
At this critical juncture, it’s important that you don't leave anything up to chance.
Doing so could result in getting an assessment score that falls below the 80 percent compliance threshold required to obtain certification.
If that happens, you’ll need to spend even more time and money implementing a plan of action & milestones (POAM) to correct those security defects. You would also incur the additional costs of getting a POAM closeout assessment completed by a C3PAO within 180 days to prove you’ve fixed the remaining compliance issues.
Keep in mind that not all requirements are weighted the same. This means that failing to satisfy certain security controls could result in an automatic failure of your CMMC assessment.
Additionally, some security controls must be fully implemented at the time of your initial assessment, making them ineligible to be included in a POAM.
For all of these reasons, it’s essential that you go in fully prepared for your assessment.
Remember, if you don’t attain final CMMC certification, you could be on the outside looking in when it comes to doing business with the DoD.
For many small and medium-sized businesses within the DIB, the loss of this crucial revenue source—for some, their only revenue source—could be disastrous for the future of their business.
After reading this article, you now understand why CMMC audit preparation is a key step in your CMMC compliance journey that should not be overlooked or taken lightly.
Keep in mind that your C3PAO assessor can't both perform your CMMC audit and prepare you for it. That's where a managed IT services provider (MSP) can step in to walk you through your compliance journey.
If you need support running a mock audit, validating your security controls, or reviewing your documentation, we’re here to help.
We’ll be there to guide you every step of the way to help ensure you have the right security resources and documentation in place to prove compliance so that you get certified, and most importantly, maintain your DoD relationship so you can keep your existing contracts or win others.
