Avoiding a CMMC False Start: Why Preparation Matters More Than Ever
The critical issue of a CMMC false start was the main topic of conversation in this episode of Climbing Mount CMMC. Kaleigh Floyd and Bobby Guerra offered their insights on the complexities of CMMC compliance and provided us with an essential message: don’t underestimate Phase 1.
What Exactly is a False Start?
A “false start” is what companies get when they launch into a CMMC assessment before they’re ready; often because their documentation is incomplete or inconsistent. This designation is a common and costly mistake. In Phase 1, as stated in CAP, “the C3PAO will evaluate if the OSC has adequately prepared for the assessment of its implementation of CMMC Level 2 security requirements” (13). Just because it’s the first phase, doesn’t at all mean it is going to be a simple pass. Organizations may believe they are ready enough, only to discover during Phase 1 that their records don’t align with their implementation. And without complete, consistent documentation, the process is guaranteed to stall.
Documentation and Implementation
A central theme of this episode was the tight relationship between documentation and actual implementation. With CMMC, it’s not enough to just have good cybersecurity practices in place. You must also be able to prove them. Auditors don’t assess your assumptions; they assess your evidence. Policies, procedures, and controls need to be both written out and in use. Mock assessments are invaluable and are a good way to test these processes. These simulations help you understand how the real process works. They highlight weaknesses, documentation gaps, and misalign expectations before they become audit failures. As Bobby stresses, mock assessments are one of the most effective ways to boost readiness without risking your actual assessment.
Know Your Scope, Know Your MSP
Many false starts occur because organizations don’t fully understand their scope. What’s in scope? What’s out of scope? Who is managing what? This gets even more complicated when External Service Providers (ESPs) are involved. As noted in this episode, not all MSPs are created equal. Some understand CMMC requirements and prepare accordingly. Some do not. If your MSP isn’t aligned with your compliance strategy, it could sabotage your entire assessment. Open and early communication with your providers is key.
Avoid A False Start with Axiom
Investing in expert support may seem expensive, but a failed assessment costs more. It costs time, money, and resources. At Axiom, we set ourselves apart from many other industry providers. We not only walk you through the before of your assessment, but we also help you during the assessment and remain by your side afterwards for continued monitored support. We also provide customized documentation, CMMC templates, and we communicate with the assessor throughout your assessment, so you don’t have to take it all on by yourself.
CMMC false starts are avoidable. The key is preparation. Whether through consulting, mock assessments, or simply asking the right questions, taking action early can save time, money, and credibility.
For more information on how Axiom can help you on your climb towards CMMC compliance, visit our website.