10 Critical CMMC Pitfalls That Could Derail Your Certification (And How to Overcome Them)

1)       Misalignment with your CMMC Level

Pitfall: Many contractors either pursue inappropriate certification levels based on misunderstanding or fail to anticipate how their information handling requirements will evolve with future contracts.

In-Depth Solution: Begin with meticulous analysis of your contractual obligations. Review the Contract Data Requirements List (CDRL) and Data Item Descriptions (DIDs) to identify precisely what information types you’re handling. Pay particular attention to specific contract clauses like DFARS 252.204-7012 that signal CUI handling requirements.

For multi-division organizations with diverse DoD contracts, consider each business unit’s specific needs. The certification timeline must align with your business development pipeline:

• Level 1 certification typically requires 6-9 months of focused preparation

• Level 2 implementation generally demands 12-18 months of sustained effort

• Level 3 usually necessitates 24 to 36  months of comprehensive work

Organizations should factor these timelines into bid decisions, recognizing that waiting until you are awarded a contract will create a significant business risk.

2)       Defining your CUI Environment inaccurately

Pitfall: Imprecise boundary definition leads to either excessive implementation costs (protecting too much) or security gaps (protecting too little). Many organizations struggle to accurately identify their entire CUI footprint.

In-Depth Solution: Develop a multi-layered approach to CUI identification and management:

1. Contract analysis: Work with legal counsel to review contractual language, identifying specific CUI categories relevant to your work

2. Data flow mapping: Document how CUI enters your organization, where it’s processed and stored, and how it’s transmitted externally

3. Technical discovery: Deploy specialized tools like Varonis Data Classification Engine or Microsoft Purview to automatically identify potential CUI based on content patterns

4. Access pattern analysis: Examine which personnel access sensitive information as part of their regular duties

5. System categorization: Determine which systems touch CUI throughout its lifecycle

For organizations with complex environments, consider implementing CUI handling enclaves that isolate sensitive information processing from general business operations. Document your CUI scope with detailed network diagrams, data flow maps, and system inventories and boundaries. Develop formal processes for evaluating new systems or workflows that might affect your established boundary. This proactive boundary management prevents “scope creep” that can unexpectedly expand your compliance obligations.

3)       Documentation deficiencies

Pitfall: Assessment failures frequently stem from documentation deficiencies—either missing documentation or materials that don’t accurately reflect organizational practices. Many contractors underestimate the depth and breadth of documentation required and delay approaching a registered practitioner (RP) who can help them with their specific requirements. 

In-Depth Solution: Effective CMMC documentation requires a structured approach:

• System Security Plan (SSP): Develop a comprehensive SSP that clearly describes your environment architecture, security controls, and implementation details. For each practice, include specific implementation statements that detail exactly how your organization satisfies the requirement.

• Policy architecture: Create a hierarchical documentation structure with high-level policies, supporting procedures, and detailed work instructions that ensure consistency in security operations. We recommend developing the following:

  • An overarching Information Security Policy that establishes governance principles

  • Domain-specific policies addressing access control, incident response, configuration management, etc.

  • Detailed procedures for security-critical operations

  • Work instructions and checklists for front-line personnel

• CUI handling procedures: Document specific workflows for CUI throughout its lifecycle, from initial receipt through destruction or return. Include detailed marking, handling, storage, and transmission instructions tailored to your specific environment.

• Baseline configurations: Maintain detailed documentation of approved secure configurations for all system components within your CUI environment.

• Third-party management: Document supplier assessment processes, security requirements, and ongoing monitoring procedures.

For organizations with limited documentation experience, we recommend connecting with a Registered Practitioner Organization (RPO) that employs a Registered Practitioner (RP) and Advanced Registered Practitioner (RPA) to customize their evidence to accurately reflect your actual practices. Remember that documentation must be living and evolving, so you will also need to establish document control procedures with regular review cycles and version tracking.

4)       Insufficient Evidence Collection

Pitfall: CMMC assessments require demonstrating that practices have been consistently applied. Many organizations struggle to produce sufficient documentation proving control effectiveness.

In-Depth Solution: Implement a structured evidence management program:

1. Evidence mapping: Create a matrix identifying specific artifacts that demonstrate compliance with each CMMC practice

2. Collection automation: Deploy tools like Splunk or Elastic SIEM to automatically gather and retain security-relevant logs and events

3. Periodic sampling: Establish regular cadences for capturing evidence of manual processes like access reviews or training completion

4. Evidence repository: Create an organized system for storing and retrieving assessment artifacts, with clear labeling and version control

5. Quality verification: Regularly review collected evidence to ensure it adequately demonstrates control effectiveness

For critical controls with high assessment focus, implement dual evidence collection strategies. For example, if you are demonstrating access control effectiveness, collect both system-generated access logs and periodic access review documentation to provide multiple evidence streams for the same practice.

Evidence should demonstrate both the existence of controls and their consistent operation over time. For example, don’t just document that you have an incident response plan—provide evidence of regular training, tabletop exercises, and actual incident handling that shows the plan is operational and effective.

5) Misinterpreting security requirements

Pitfall: Misinterpreting security requirements leads to implementation gaps that emerge during assessment. For instance, many organizations implement basic account management (AC.2.007) without the comprehensive account lifecycle processes actually required.

In-Depth Solution: Develop a nuanced understanding of CMMC requirements:

• Study both the practice language and the assessment objectives, which often contain critical clarifying details.

• Review available implementation guidance from authoritative sources like NIST and the CMMC Accreditation Body, including NIST 800-171A

• Analyze each practice from multiple perspectives: technical controls, policies, procedures, and human factors.

• Consider control interdependencies—identify where one practice depends on the effective implementation of others.

For complex controls, conduct tabletop exercises where security team members talk through exactly how the organization satisfies specific requirements. These exercises often reveal interpretation gaps before they become assessment findings.

We recommend developing detailed control statements that translate CMMC practices into organization-specific implementation requirements. For example, rather than simply restating CMMC practice AC.2.007, create detailed statements describing exactly how your organization:

• Establishes account creation criteria and approval workflows

• Implements technical account enforcement mechanisms

• Conducts periodic access reviews

• Manages account modifications

• Executes timely account terminations

This translation process ensures your implementation fully addresses all aspects of each requirement.

6)       Operational misalignment

Pitfall: Organizations frequently have well-documented policies that bear little resemblance to actual operations. This disconnect creates significant assessment vulnerability.

In-Depth Solution: Create effective connections between documentation and practice:

• Policy practicality: Ensure policies reflect what the organization can realistically implement rather than aspirational ideals

• Procedural clarity: Develop step-by-step procedures that leave minimal room for interpretation or variation

• Automation where possible: Implement technical controls that enforce policy requirements, reducing reliance on manual compliance

• Regular conformance checks: Establish monitoring mechanisms to detect deviations from documented procedures

• Feedback loops: Create channels for operational personnel to highlight impractical policies requiring revision

Make policy documents genuinely useful operational tools rather than compliance artifacts. For example, your incident response plan should serve as an actual playbook during security events, not just documentation that satisfies a requirement.

When practices deviate from documentation, make deliberate decisions about which ones need adjustment. Sometimes, operational reality reveals a better approach than what was initially documented; in these cases, update your documentation rather than forcing conformance to suboptimal procedures.

7)       Lack of Supply Chain Security

Pitfall: CMMC Levels 2 and 3 require robust supplier security management. Many contractors lack effective mechanisms for assessing, monitoring, and enforcing security requirements across their supplier ecosystem.

In-Depth Solution: Establish a comprehensive supply chain security program:

1. Supplier inventory: Create a complete catalog of suppliers with access to your FCI/CUI, including their specific roles and information exposure

2. Tiered assessment: Develop assessment protocols of varying depth based on supplier criticality and CUI access

3. Contractual controls: Implement appropriate flow-down clauses that clearly articulate security expectations and requirements

4. Technical enforcement: Deploy technical controls that limit supplier access to only necessary information through mechanisms like secure file-sharing platforms, VDI environments, or partner portals

5. Ongoing monitoring: Establish continuous or periodic evaluation of supplier security posture through attestations, security questionnaires, or direct assessment

6. Incident coordination: Develop procedures for managing security incidents that involve supplier systems or personnel

For critical suppliers, consider requiring relevant certifications (CMMC, FedRAMP, ISO 27001) as verification of security capability. Establish clear consequences for non-compliance, including potential relationship termination in cases of significant security deficiencies.

Remember that suppliers often have their own complex supply chains. Your assessment process should include questions about how your direct suppliers manage their own third-party security risks when those parties may have transitive access to your sensitive information.

8) Insufficient Resource Allocation

Pitfall: Organizations frequently underestimate the resources required for effective CMMC implementation, leading to understaffed initiatives, inadequate tooling, and implementation gaps.

In-Depth Solution: Develop comprehensive resource planning across multiple dimensions:

Personnel Resources:

• Designate a qualified CMMC Program Manager with appropriate authority and organizational support

• Ensure representation from key functional areas (IT, security, contracts, legal, operations)

• Consider specialized expertise requirements in areas like documentation development or technical control implementation

• Account for ongoing operational support beyond initial certification

Financial Resources:

• Budget realistically for potential technology investments required to address compliance gaps

• Account for consulting or specialized services needed to supplement internal capabilities

• Include costs for training and certification of key personnel

• Plan for assessment costs, including pre-assessment readiness reviews

• Consider potential business impact during implementation phases that may affect operations

Technological Resources:

• Identify specific tools needed to support security requirements (SIEM, vulnerability management, access control systems, etc.)

• Evaluate current infrastructure against CMMC requirements to identify upgrade requirements.

• Consider monitoring and evidence-collection capabilities necessary for demonstrating compliance.

Our experience shows that successful programs typically allocate an adequate percentage of the contract value toward CMMC compliance initiatives. We recommend developing comprehensive project plans that align resource allocation with specific implementation phases, ensuring appropriate support throughout the certification journey.

9)       Limitations of your POA&M

Pitfall: Organizations misunderstand the purpose and limitations of Plans of Action and Milestones (POA&Ms) in the CMMC context and attempt to use them as permanent alternatives to control implementation. 

Context: In the CMMC compliance journey, POA&Ms serve as essential markers for controls that don’t fully meet requirements and they include implementation that can be deferred. Organizations can get conditional CMMC approval with a POA&M. They are helpful when evaluating vendors for your supply chain and during CMMC Self Assessments. The DIBCAC or C3PAO may also give you a POA&M. Hence, while some gaps can be documented this way, several critical controls require 100% implementation and cannot be deferred through the POA&M process. You need to understand which controls can and cannot be included in a POA&M. If you do not fully meet the requirement of a critical control, you need to undergo the certification process or assessment again. 

In-Depth Solution: Develop a structured approach to POA&M management:

• Clear criteria: Establish internal guidelines defining when a POA&M is appropriate versus when controls must be fully implemented before certification

• Risk-based prioritization: Rank POA&M items based on security impact, addressing highest-risk items first

• Detailed planning: For each item, document specific remediation steps, resource requirements, and milestone dates

• Executive visibility: Ensure leadership has regular visibility into POA&M status and progress

• Regular reassessment: Review POA&Ms periodically to ensure timelines remain realistic and appropriate

• Contingency planning: Develop alternative approaches for high-risk items in case primary remediation plans encounter obstacles

Remember that POA&Ms are not appropriate for all compliance gaps. CMMC Assessment Guides clearly indicate which practices must be fully implemented versus those that can be addressed through POA&Ms. For critical security controls, develop interim risk mitigation strategies while working toward full implementation rather than relying on POA&Ms alone. POA&Ms should demonstrate organizational commitment to addressing identified gaps with realistic timelines that reflect both security priorities and practical constraints.

10)  Absence of a Culture of Security

Pitfall: Technical controls alone cannot secure sensitive information without a workforce that understands and embraces its security responsibilities. Many organizations implement robust technical measures but neglect the cultural aspects of security.

In-Depth Solution: Build a comprehensive security culture program:

1. Role-based training: Develop tailored security training that addresses specific responsibilities by job function

2. CUI handling specifics: Ensure personnel understand the unique requirements for working with controlled information

3. Leadership modeling: Engage executives in visibly supporting and participating in security initiatives

4. Performance Integration: Include security responsibilities in job descriptions and performance evaluations

5. Awareness campaigns: Implement ongoing security awareness activities that reinforce key behaviors

6. Positive reinforcement: Recognize and reward security-conscious behaviors

7. Psychological safety: Create environments where security concerns can be raised without fear of reprisal

Security awareness shouldn’t be limited to annual training. Develop a year-round program of touchpoints, including phishing simulations, newsletter content, desk drops, digital signage, and team discussions that keep security top-of-mind.

We’ve observed that organizations with strong security cultures typically experience 60-70% fewer security incidents than those focusing exclusively on technical controls. This cultural foundation pays dividends beyond CMMC compliance by creating resilience against a broad spectrum of security threats.

The Future of CMMC Compliance 

As CMMC continues to evolve in the defense industrial base (DIB) ecosystem, organizations must balance immediate certification needs with strategic preparation for future requirements. There is a strong possibility that NIST SP 800-171 Rev 3 may be integrated into the CMMC framework in the future. While some organizations may want to future-proof their position in the DIB and begin planning to implement these controls, we believe that contractors should focus on achieving peak operational efficiency with existing controls at their required maturity level and establish a robust foundation that can readily adapt to regulatory changes.

The most resilient CMMC compliance posture comes not from rushing to implement every potential future control but from developing mature, well-documented processes around current requirements. Organizations that achieve genuine security effectiveness—rather than mere checkbox compliance—will find themselves better positioned when new requirements emerge. By prioritizing depth over breadth in your security program, identifying process optimizations, and ensuring consistent implementation of current controls, you’ll create the operational agility you need to absorb future changes without overwhelming your security teams or budget.