Lessons Learned from Early CMMC Gap Assessments

Even before CMMC certification requirements take full effect, many Defense Industrial Base contractors have begun conducting gap assessments to see how close they are to compliance. These early efforts reveal valuable lessons that can help your organization avoid pitfalls and accelerate readiness.

1. Policies Don’t Equal Practice

One of the most common findings is the gap between what’s written on paper and what happens in daily operations. Many contractors have policies in place but can’t show proof that they’re being followed. Auditors want evidence of action, not just words.

Lesson: Build compliance into daily workflows and collect artifacts that prove policies are active.

2. Evidence Collection Takes Longer Than Expected

Contractors often underestimate the time it takes to gather screenshots, logs, training records, and contracts. Scrambling during the audit is a recipe for stress and mistakes.

Lesson: Start collecting evidence now. Create an organized repository (an “evidence locker”) tied directly to each CMMC control.

3. Scoping Drives Everything

Companies that skipped a careful scoping exercise either overspent by including too much or failed assessments by leaving critical systems out.

Lesson: Invest the time to map where CUI actually resides. Scoping defines your workload, costs, and audit boundaries.

4. Culture Matters

The most successful contractors treat CMMC as a company-wide responsibility, not just an IT project. Organizations that silo compliance under IT alone consistently struggle.

Lesson: Make compliance cross-functional. HR, operations, and leadership should all play a role.

5. POA&Ms Are Useful But Limited

Plans of Action & Milestones (POA&Ms) help contractors address shortfalls, but they’re not a free pass. CMMC only allows limited use of POA&Ms, and they must be closed within strict timelines.

Lesson: Use POA&Ms strategically but aim to remediate gaps before your C3PAO audit.

Final Thoughts

The biggest takeaway from early gap assessments is clear: start early and treat compliance as a living program, not a one-time project. Contractors who wait until the last minute face higher costs, more stress, and a greater risk of failure.

CMMC isn’t just about passing an audit it’s about building trust with the DoD and protecting sensitive information. If you use gap assessments as learning opportunities, you’ll not only prepare for certification but also strengthen your overall security posture.