The Hidden Gaps in CMMC Compliance Frameworks
In the evolving landscape of cybersecurity, compliance frameworks like CMMC are essential roadmaps for protecting sensitive data and ensuring operational readiness throughout the Defense Industrial Base (DIB). In our most recent episode of Climbing Mount CMMC, we got to talk again with authorized C3PAO, Kyle Lai. Kyle offered a wealth of insight into the current challenges and lessons learned working among C3PAOs and navigating the CMMC ecosystem. Here’s some of the takeaways:
Avoid the False Start and Prepare for Your Assessments Early
Organizations that jump into CMMC without thorough preparation often face certain setbacks. From incomplete documentation to misaligned internal processes, a “false start” can cost you a lot of money and time you may not have.
IT and Software Development is the Frontline of Compliance Frameworks
Too often, software development is treated as a separate track from cybersecurity. But in reality, many elements of software architecture all directly impact an organization’s compliance posture. Compliance is no longer just an IT concern. It’s become a shared responsibility, which is why IT and software teams must collaborate. This idea was one of the strongest themes throughout this episode because many organizations don’t realize how interconnected these two teams are. Compliance frameworks touch every corner of an organization, and teams that don’t communicate can create friction and gaps within the systems. Kyle notes that because of this lack of communication, many businesses fall into “echo chambers,” where a lack of diverse perspectives leads to blind spots, especially in vulnerability assessments. Diverse teams and cross-functional collaboration help surface unseen risks.
Documentation is Never Optional
As stated in 32 CFR final rule, “If an OSA’s risk-based security policies’, procedures, and practice documentation or other findings raise questions, the assessor can conduct a limited check to identify deficiencies” (83232). This furthers the notion that when auditors come in, they need to see more than just your working system. They need to see documented evidence of your secure and repeatable processes. And if they don’t see them laid out right in front of them, they will ask for them. That’s why your teams must document their procedures with the same efficiency they apply to other operational functions.
A Holistic Approach to Vulnerability Management
Effective vulnerability management requires a wide lens, because it’s not just your servers that are at risk. Although open-source tools can accelerate development, they also introduce new layers of complexity and risk. Organizations must work to track these dependencies, monitor for updates, and assess the security-posture of their third-party components. A holistic approach ensures that nothing can slip through the cracks.
Your Next Step Toward Compliance Starts with Collaboration
Kyle’s insights make one thing abundantly clear: achieving CMMC compliance isn’t just about passing your audit. It’s about building the right habits across your organization. Teams need to communicate, document their processes, and make sure they are taking a proactive approach to their systems security.
If your team is working toward CMMC certification, now is the time to get aligned and stay ahead. For more information, visit our website or check out our podcast.