How to Avoid Costly Mistakes by Sequencing CMMC Assessments Correctly

Introduction to Sequencing CMMC Assessments

If you’re preparing to meet the requirements of the Cybersecurity Maturity Model Certification (CMMC), you’ve likely come across two key types of assessments-Gap Assessments and Readiness Assessments. They may sound similar, but each one plays a distinct role in your overall compliance journey.

One essential point is that many organizations mistakenly swap the order of these steps. In reality, a Gap Assessment should come first, followed by a Readiness Assessment as a final check before your formal CMMC evaluation.

Below, we’ll clarify these differences, explore why sequence matters, and outline how you can strategically approach both assessments to optimize your CMMC efforts.

Understanding the Evolving CMMC Landscape

In an environment shaped by new federal regulations—most notably 32 CFR Part 170 for the CMMC 2.0 Program and updated DFARS clauses—contractors and subcontractors need precise, actionable information. Recent rulemaking highlights the importance of having a clear roadmap to meet NIST SP 800-171 controls (110 in total) and to ensure continuous compliance.

Overlooking critical steps in the assessment process can delay your contract eligibility and potentially jeopardize your business with the Department of Defense (DoD).

Remember that CMMC Level 2 self-assessments now apply to only a small subset of contractors, and those self-assessments must be expressly permitted by the DoD in the solicitation. Most companies seeking Level 2 certification will need to engage with a Certified Third-Party Assessor Organization (C3PAO).

This underscores the strategic importance of having your Gap Assessment and Readiness Assessment in proper order so you can avoid costly rework down the line.

CMMC Gap Assessment Is Your First Diagnostic

A CMMC Gap Assessment is designed to pinpoint the current gaps in your cybersecurity environment. Think of it as an early diagnostic stage, laying the foundation for a well-structured remediation plan.

• Purpose: Identify and document areas where you’re falling short of specific CMMC Level requirements. This can include missing policies, incomplete procedures, unimplemented controls, or insufficient documentation.
• Conducted By: Internal teams with deep knowledge of your systems, external consultants familiar with CMMC, or both.
• Timing: Performed before a Readiness Assessment so you have ample time to remediate issues before your formal evaluation.
• Outcome: You’ll come away with a detailed roadmap for remediation, plus a Plan of Actions and Milestones (POA&M) to track progress and address critical deficiencies.

CMMC Readiness Assessment Is Your Final Rehearsal

A CMMC Readiness Assessment is more of a “dry run” to confirm you’ve actually implemented the required controls and are prepared to undergo an official C3PAO audit (for Level 2) or self-assessment (for the small subset that qualifies).

• Purpose: Validate that all relevant controls—particularly the 110 in NIST SP 800-171—are fully implemented and that any weaknesses discovered in the Gap Assessment have been addressed.
• Conducted By: Internal cybersecurity teams, third-party consultants, or specialized pre-audit assessors who can simulate a formal review.
• Timing: Occurs after the Gap Assessment and remediation steps. This ensures you’re not performing a readiness check on systems that still have structural weaknesses.
• Outcome: Confirmation that you’re prepared for the official assessment process and capable of uploading accurate scores into the Supplier Performance Risk System (SPRS). This step can also help confirm you meet the threshold for any conditional certification timelines allowed by DoD (e.g., 180-day windows to close out POA&Ms).

Sequencing Your Assessments the right way

Achieving CMMC compliance involves more than checking a box. Below is a structured plan to help you integrate both the Gap and Readiness Assessments effectively:

1. Start with a Formal Gap Analysis
   Start with a formal gap analysis by thoroughly reviewing your current System Security Plan (SSP), policies, and existing Supplier Performance Risk System (SPRS) scores, if previously submitted. Map each requirement from NIST SP 800-171 to your current environment, carefully noting any areas of partial implementation or gaps. Capture these findings in a Plan of Action & Milestones (POA&M), prioritizing deficiencies, especially those control shortfalls not permissible in final certification.
2. Remediate and Strengthen Your Security Posture
   Remediate and strengthen your security posture by addressing identified procedural and technical shortfalls based on your gap assessment findings. Ensure that you compile robust documentation, including policies, procedures, logs, and configurations, to substantiate compliance effectively.
3. Conduct a Mock Readiness Assessment
   Conduct a mock readiness assessment as a final rehearsal, confirming boundary definitions, thoroughly testing your procedures for evidence collection, and verifying the effective functioning of your security controls. Address any remaining discrepancies promptly and validate your compliance score to confirm that you meet or surpass the CMMC Level 2 certification threshold.
4. Plan for Conditional Certification (If Applicable)
   Plan for conditional certification, recognizing that CMMC 2.0 allows a potential 180-day window for resolving remaining POA&Ms, provided your score meets a predetermined threshold, typically around 80%. Utilize the findings from your readiness assessment to determine your eligibility and develop a clear, actionable plan to close any outstanding issues within this grace period.
5. Validate Subcontractor and Supplier Readiness
   Validate the readiness of your subcontractors and suppliers, as compliance requirements cascade down to all parties handling Controlled Unclassified Information (CUI). Confirm each subcontractor’s required CMMC level and proactively ensure they are advancing their compliance processes in parallel with your own.
6. Maintain Continuous Compliance
   Maintain continuous compliance, understanding the Department of Defense’s expectation of ongoing vigilance. After achieving certification, annually affirm your compliance status, continuously update your policies and systems, perform periodic self-assessments, and respond swiftly to any updates or changes in DoD directives.

The Importance of Getting the CMMC Compliance Journey Right

Misstating the order of these assessments or oversimplifying their roles can lead to premature readiness checks that miss fundamental security gaps. That often translates into avoidable delays and higher costs if you fail an official assessment. By sequencing your Gap Assessment before your Readiness Assessment, you ensure structural deficiencies are corrected early. Then your final readiness check simply validates that you’re prepared to submit accurate scores and pass a formal evaluation, whether that’s a self-assessment (for the rare few who qualify) or a C3PAO-led assessment (required for most Level 2 certifications).

Strengthen Your Defense Contracts with a Strategic CMMC Approach

Ensuring you understand the difference between a CMMC Gap Assessment and a CMMC Readiness Assessment—and the importance of conducting them in the right order—can streamline your path to full compliance. A properly executed Gap Assessment lays the groundwork for targeted remediation, while a subsequent Readiness Assessment acts as a final dress rehearsal before you face official scrutiny. Done correctly, these steps set the stage for a smoother certification process, helping safeguard your eligibility for critical defense contracts.

Take the time to structure your assessment plan carefully, invest in knowledgeable resources, and follow a well-documented roadmap. This strategic approach not only strengthens your cybersecurity posture but also demonstrates to the DoD that you are prepared to protect Controlled Unclassified Information effectively. With CMMC requirements evolving, staying proactive and accurate in your assessments is vital to long-term success in the defense supply chain.