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Document where CUI lives in your environment. Start with contracts and follow flows through your organization.
Identify and document CUI, SPA, CRMA, SA and out of scope assets.
Use an understanding of CUI dataflows and assets to consider ways to reduce the footprint.
Identify tools/methods and stakeholders necessary to track and manage compliance with controls.
Review contracts and agreements with 3rd party vendors to ensure their control environments are compliant.
Ensure internal stakeholder has the authority to manage the cultural change.
Quickly check compliance for each of the 110 controls and 320 assessment objectives against your identified CUI boundary.
Create plans of actions and milestones (POAMs) for anything not compliant.
Assign authoritative stakeholders to remediate the easiest gaps with timelines.
Develop timelines and budgets for addressing more complex gaps such as replacing non-compliant 3rd party vendors.
Track and manage progress on POAMs until ready for assessment. Organizations delaying compliance may encounter obstacles due to the limited availability of Certified CMMC Assessors (CCAs). We advise proactively scheduling assessments to ensure timely compliance.
