What CMMC Consultants Actually Do During the Certification Process

Defense contractors understand they need to obtain CMMC certification to continue working with the DoD. Still, many fail to recognize that it involves more than merely signing up for certification and receiving an official certificate afterward. There are many more steps along the way, even before assessors come in, check a few boxes, and boom, get you approved.

CMMC consultants are the ones who do the heavy-lifting in between; without them, the potential to fail certification on day one, and at great cost, is much higher. Yet many organizations misunderstand what a consultant does and fail to do during the CMMC process. Some believe they merely fill out paperwork. 

Others think they’re essentially expensive cheerleaders. While there is some kernel of truth in each assessment, the reality is that these consultants serve as interim translators, project managers, documentation fillers, and, when necessary, give hard realities to organizations that need to align with government security requirements.

The Assessment That Everything Else Bridges From

When a consultant first comes on-site, they first assess where an organization stands. This isn’t a two-hour walkthrough of the building. This is an in-depth exploration of every technical and administrative system, process, and policy that touches Controlled Unclassified Information (CUI). This includes network architecture, access controls, incident response plans, and dozens upon dozens of technical and administrative areas that will be nuanced later on in the process.

However, here’s an interesting tidbit: most organizations think they’re in better shape than they are. Thus, a consultant’s job is to be honest and forthright, and to document every gap between what CMMC requires and what the organization currently has in place. Thus, a consultant will not blow smoke up an organization; they will ensure every gap analysis is complete and detailed to yield maximum remediation effectiveness – even if it means bruising some egos. This gap analysis typically takes anywhere from a few days to a few weeks, depending on organizational size and complexity, and provides a path forward for everything else.

Consultants also determine what level of certification a given organization actually needs. Not all organizations need CMMC level 2 certification; for example, pursuing a higher level of certification than required is a waste of time. On the same token, attempting to get accredited for a less intensive certification than needed may pose a future risk. Thus, assessing needs from the onset creates a better bridge moving forward.

Building Documentation Requirements

The next step involves compiling documentation prerequisites that auditors will evaluate over time. Where documentation requirements exist for many avenues during CMMC, the documentation provided must be substantiated and accurate.

Moreover, documentation isn’t just about having the right papers in a folder; everything must align with what an organization actually does, not what it hopes to do one day or anticipates doing soon. This takes a team effort, as consultants need to assess gaps across multiple departments to document real-life workflows, actual security controls, and genuine processes. When consultants come from experienced teams as CMMC compliance experts, they provide assessments that create the documentation required to meet auditor evidence standards and that accurately align with the organization’s security posture.

The gap analysis and necessary implementation occur at the right time. Documentation happens in tandem with implementation efforts so as new controls go into place, they can be documented. As policies change, the gaps are filled through approved resolutions and consultant engagement. The last thing anyone wants is to implement great controls but not report them properly, or, conversely, to have excellent documentation for controls that exist nowhere.

Implementing Security Controls

Documentation doesn’t automatically certify someone; security controls need to be implemented, and that’s easier said than done.

While CMMC compliance consultants don’t necessarily undertake technical implementations themselves, especially if other third-party vendors are already involved, they guide the process along, recommending priorities that start from day one, ensuring there’s adequate time for budget and risk mitigation. The last thing someone wants is to reach day five of reconciliation only to realize something critical started two weeks earlier; there’s no avoiding failure here.

Some security controls are simple implementations: install multi-factor authentication or adjust password settings. Others require considerable time and investment; implementing proper network segmentation or establishing inventory for asset management systems can take months.

That’s why having an experienced partner who makes suggestions and explains areas of concern over time is key. They know which gaps present the largest risk for certification success – and which can be remediated down the line after more pressing issues arise.

Wherein this realm fails, however, is when companies think that they know best how to implement their requirements. Too often, gaps play out during implementation when basic mistakes aren’t caught early. For example, password policies may have been created and left on a shelf without educating staff on requirements, and if staff are still using passwords without MFA-like checks in place, there’s a major failing.

Running Mock Assessments/Readiness Reviews

Long before the C3PAO assessment, critical inputs come from consultants who run mock assessments and practice versions of what’s to come.

The goal? Ensure everything possible is in order before an unfortunate incident occurs – and best ridership reviews validate this.

During mock assessments, generally at least two practice runs are recommended; one might identify several issues; a second completion documents whether or not everything worked as intended, consultants essentially become auditors themselves asking auditor-type questions and seeking evidence requests (in addition to technical testing) that might unveil findings before it becomes too late.

Thus, mock assessments identify issues that don’t necessarily surface during implementation. Perhaps there is a policy, but employees fail to follow through. Possibly security controls work, but configuration flaws undermine their benefits. Maybe the documentation states one thing, but reality shows subtle differences in the other direction.

Consultants coach companies through this process and remediate; they empower them with solutions before it becomes certification denial fodder.

All organizations must pass at least two mock assessments before they’re truly ready for the official one, from initial mishaps to final assessment bliss; all organizations should strive for at least two chances to get their ducks in a row.

Managing the Official Assessment Process

All too often, when it’s time for the real C3PAO assessment, many companies think consultants aren’t by their side anymore, but that’s not true.

Consultants coordinate all aspects of assessment from planning days/times through auditor sessions with employees. They unify all assessments under one timeline, while, where necessary, advocating for additional time or review.

During the assessment itself, additional questions are asked that dig deeper into specifics; having someone there who understands both sides, the security implemented, and the required commentary for CMMC, makes the process go smoothly with fewer pitfalls along the way.

If an auditor sees a potential finding without the consultant on-site providing context, who knows what’s going on, that potential deficiency might literally tank certification success.

An assessment usually lasts several days; it’s like taking midterms all over again after two years of preparation, and everyone knows how stressful it is when life is on the line. A consultant helps mitigate those tensions and contextualizes answers/further preventing auditors from taking no for an answer.

After Certification – Maintaining Compliance

Getting certified shouldn’t be where relationships end, especially if a company wants continued compliance with CMMC rather than just a one-time nod to achievement.

Instead, support exists post-certification for new policies expected (requiring recertification), annual audits, continuous connection with CMMC requirements over time, while helping substantiate changes as needed.

Many consultants act as fractional CISOs for regular check-ins or connect with companies that want third-party involvement on an ad hoc basis for periodic assessments (to ensure continued compliance).

Why?

Because when companies get busy, backsliding occurs, the recommendations take a backseat to ongoing operations – instead of maintaining compliance efforts, this isn’t the best course of action after spending money on consulting services pre-certification, thinking it’s easy post-hoc

But it’s not, and consultants help ensure small problems don’t become big problems before they tank compliance approaches moving forward.

The Value Beyond Just Passing an Audit

Ultimately, good consultants do more than provide compliance check-box efforts; they elevate the overall security posture beyond risk-mitigation standards, making sustainable practices achievable for any organization looking to succeed.

The controls required for CMMC are meant to protect sensitive information; they’re not just bureaucratic requirements without substance; instead, compliance is only one part of playing the game here.

Companies that view CMMC as merely compliance fail to understand how to bolster their foundations. In contrast, those who offer nuanced compliance options alongside extensive security knowledge succeed by delivering value beyond the certificate itself.

In a world where cyber insecurity plays havoc against all businesses, not just defense contractors, anyone with increased security-minded efforts must be certified experts to help level expectations for resiliency benefits down the line.