Act Now or Lose DoD Work: What Contractors Must Do as CMMC Enforcement Accelerates

CMMC is no longer theoretical. Requirements are already appearing in Department of Defense solicitations, and eligibility is increasingly determined at award, not after performance begins. Once the CMMC clause is present, there is no grace period.

As CMMC adoption expands over the next several years, assessment backlogs and preparation gaps are becoming the real risk. Contractors that wait will not fail loudly. They will simply stop qualifying.

What You Must Do Now

1. Complete a Full System Inventory
Identify and map every in-scope asset. Categorize systems as CUI Assets, Security Protection Assets, Specialized Assets, or Contractor Risk Managed Assets (CRMA). Include all External Service Providers that store, process, or transmit CUI. Incorrect scoping is one of the fastest paths to assessment failure.

2. Build a Detailed System Security Plan (SSP)
Document how each NIST SP 800-171 requirement is implemented. Assessors evaluate implementation detail, not intent. A weak SSP will undermine even strong technical controls.

3. Understand the DoD Scoring Methodology
NIST SP 800-171 requirements are weighted. Some controls allow limited POA&Ms with defined remediation timelines. Others must be fully met at assessment. Misunderstanding which controls allow remediation causes failed certifications and delayed awards.

4. Define Roles and Accountability
Designate an Affirmation Official responsible for annual SPRS affirmations and a formal point of contact for assessors. These roles should be documented and understood before assessment begins.

5. Engage a C3PAO Early
If your contracts are likely to require third-party assessment, scheduling is already a constraint. Authorized C3PAOs are limited, and many assessment calendars extend months out. Waiting for a solicitation often means missing the bid.

6. Identify All Control Inheritances
If you rely on external providers, confirm whether controls can be inherited. For cloud services handling CUI, FedRAMP Moderate or higher is typically required. Be prepared to obtain full supporting evidence, not marketing summaries.

7. Run an Internal Control Assessment Now
Use the NIST SP 800-171A methodology to test controls internally. Fix gaps before an official assessment. Discovering deficiencies during an assessment leaves little room to recover.

8. Learn the CMMC Assessment Process
Understand assessment phases, evidence types, and expectations defined in the CMMC Assessment Process (CAP). Organizations fail when they do not know how controls are evaluated.

9. Allocate Real Resources for Documentation
Policies and procedures are not optional. Assign owners for writing, maintaining, and validating documentation. Confirm cryptographic tools meet applicable FIPS requirements where required.

10. Build a Realistic Certification Timeline
Confirm the required level for your work. Plan for self-assessment or third-party assessment based on contract designation. Align certification timelines to upcoming bids. Certifications are valid for three years, with required annual affirmations.

Why This Matters

CMMC does not eliminate contractors in bulk. It removes them one solicitation at a time. When a bid requires certification and you do not have it, the outcome is final.

No certification means no new DoD work.

Start now, while you still control the timeline.