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What You Might Be Overlooking About CMMC 2.0

What You Might Be Overlooking About CMMC 2.0

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A Contractor’s Guide to Staying Eligible, Prepared and Out of Trouble

For government contractors and subcontractors, the rules of engagement have changed. Cybersecurity Maturity Model Certification (CMMC) 2.0 isn’t just another update, it’s quietly but rapidly becoming a gatekeeper to federal contracts.

While the headlines focus on cybersecurity, the real impact is systemic: your eligibility to bid, your ability to pass audits and your long-term reputation with agencies and teaming partners all now hinge on whether your operations can stand up to scrutiny under NIST SP 800-171, which provides the foundational security controls that CMMC builds upon.

And yet, many contractors are approaching CMMC the way they’ve handled prior compliance shifts—waiting to act until a solicitation forces the issue. That delay could be costly.

What’s Different This Time

Earlier versions of cybersecurity guidance allowed for self-attestation, and many companies got by with informal policies and limited documentation. CMMC 2.0 changes the game.

If your contracts involve Controlled Unclassified Information (CUI), you’ll likely need Level 2 certification, verified by a third-party assessment. That process doesn’t just evaluate your technology—it looks across your systems, your governance and your evidence of ongoing control.

Key requirements include:

  • Documented policies and procedures that align with day-to-day practices
  • System security plans (SSPs) and plans of action (POA&Ms) to demonstrate how requirements are met and gaps are managed
  • Incident response plans that are tested, with clear roles, responsibilities and evidence of execution
  • Technical safeguards such as monitoring, encryption, patch management and multi-factor authentication
  • Vendor and supply chain oversight to ensure third parties handling CUI also follow security requirement

A well-written policy is no longer enough. Reviewers will want to see how it’s applied, tracked and audited—and how it integrates with your business operations.

The Risks You May Not Be Calculating

Non-compliance isn’t just a future problem. Agencies are already embedding CMMC requirements in their RFP language. Even if your firm has a strong technical capability, lack of certification or poor documentation can take you out of contention.

Beyond disqualification, contractors face:

  • Heightened scrutiny in post-award audits
  • Reduced teaming opportunities as primes vet partners
  • Brand reputation risks that outlast contract cycles

There’s also the hidden cost of reactive compliance. Waiting until a proposal is due or a corrective action request arrives typically means rushed fixes, expensive remediation and lost productivity.

How Contractors Are Quietly Preparing

The most successful companies aren’t simply updating their firewalls—they’re evolving how they operate.

They’re:

  • Performing or outsourcing gap assessments
  • Building out System Security Plans used to define scope and how controls are implemented
  • Creating Plans of Action and Milestones (POA&Ms)
  • Evaluating their supply chain risks and service provider responsibilities

These contractors aren’t necessarily investing more—they’re investing earlier, and with more strategic intent.

What You Should Do Today

Even if you’re not pursuing defense contracts, cybersecurity requirements are increasingly surfacing in civilian solicitations. Readiness isn’t just for DoD contractors—it’s becoming table stakes for federal work overall.

Here’s what you can do now:

  • Define your scope—identify what data you handle, where it resides and the boundaries of your environment
  • Familiarize yourself with the 110 NIST SP 800-171 requirements and how they map to your operations
  • Develop documentation that accurately reflects your policies and day-to-day practices
  • Partner with an RPO to perform a readiness assessment, identify gaps and build a clear roadmap for compliance.

There’s no single playbook—but clarity, preparedness and measured action are what separate contractors who win confidently from those stuck responding under pressure.

Contributors

Andrew Hicks, Partner & National HITRUST Practice Leader,
Frazier & Deeter Advisory, LLC

Jessie Sandell, Director, Frazier & Deeter Advisory, LLC

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