5 Common Gaps Contractors Face in CMMC Prep (and How to Fix Them)

As a consultant working with Defense Industrial Base contractors, I’ve seen one truth repeat itself: most companies don’t fail CMMC prep because of technology—they fail because of gaps they didn’t even know existed. These blind spots can derail an otherwise solid program. Let’s look at the five most common gaps and how to close them.

1. Incomplete or Outdated System Security Plans (SSPs)

The Gap: Many contractors treat the SSP as a one-time requirement, copying a template and never updating it. Auditors will quickly spot when the plan doesn’t reflect the real environment.
The Fix: Treat your SSP as a living document. Update it whenever your systems, users, or policies change. A GRC platform can help automate version control and keep everything aligned.

2. Weak Evidence Collection

The Gap: Contractors often claim compliance but struggle to prove it. Screenshots, logs, training records, and policy acknowledgments are either missing or scattered.
The Fix: Start building an “evidence locker” now. Attach proof directly to each control, so you’re not scrambling to find it when the auditor arrives.

3. Poor Scoping Decisions

The Gap: Companies either throw everything in scope (driving up costs) or under-scope and miss critical systems where CUI resides. Both approaches create risks.
The Fix: Carefully map where FCI and CUI are stored, processed, and transmitted. Document your scoping rationale and, if possible, isolate in-scope systems from the rest of your network.

4. Incident Response Plans That Don’t Work in Practice

The Gap: Policies may exist on paper, but when asked, staff don’t know what to do if an incident occurs.

The Fix: Build an actionable incident response plan. Run tabletop exercises at least annually, assign clear roles, and document test results. This shows auditors you don’t just have a plan—you use it.

5. Ignoring Vendor and Subcontractor Risk

The Gap: Contractors often forget their compliance depends on the security of their vendors and subcontractors. If a downstream partner mishandles CUI, you’re still responsible.
The Fix: Implement vendor risk management. Include security clauses in contracts, collect attestations from subs, and keep documentation of your due diligence.

Final Thoughts

CMMC preparation isn’t about perfection—it’s about discipline. By addressing these five gaps early, you’ll reduce audit costs, build confidence with your C3PAO, and most importantly, protect your eligibility to compete for DoD contracts.

Think of these fixes not as extra work, but as building blocks for a stronger, more resilient business.