In this nugget, we are delving into some common mistakes that organizations make which ultimately will cause them to fail a CMMC audit. Often organizations don’t fully understand the breadth of documentation and completeness required to properly meet the control. Improper documentation can lead to compliance failures in various areas. Here are some common pitfalls:

  1. Incomplete System Security Plans (SSPs): Organizations may fail to develop comprehensive SSPs. These plans are crucial for providing an overview of implemented security controls and the management of the entire system.
  2. Inadequate Security Assessment Reports (SARs): SARs are essential for demonstrating the effectiveness of security controls. Incomplete or inaccurate SARs can lead to audit failures.
  3. Failure to Document Continuous Monitoring Processes: Continuous monitoring is a critical aspect of maintaining security controls over time. Organizations may neglect to document and update their continuous monitoring processes, leading to gaps in compliance.
  4. Insufficient Configuration Management Documentation: Proper documentation of system configurations, changes, and baselines is crucial. Organizations may fail to maintain accurate records of configuration changes, making it difficult to assess compliance.
  5. Inadequate Incident Response Plans (IRPs): Organizations may lack comprehensive documentation for incident response plans, including procedures for detecting, reporting, and responding to security incidents.
  6. Poor Documentation of Access Controls: Documentation related to user access, permissions, and account management is vital. Inadequate documentation in this area can result in audit failures.
  7. Failure to Document Security Training and Awareness Programs: Employee training and awareness programs are essential for maintaining a secure environment. Organizations may fail to document the implementation and effectiveness of these programs.
  8. Incomplete Records of Security Reviews and Audits: Regular security reviews, assessments, and audits should be documented. Failure to maintain proper records of these activities can lead to compliance issues.
  9. Inaccurate or Outdated Documentation: Simply having documentation is not enough; it must be accurate and up-to-date. Organizations may struggle with keeping documentation current, especially in dynamic environments.
  10. Lack of Plan of Action and Milestones (POA&M): Organizations often overlook the need for a detailed POA&M to outline plans for addressing security weaknesses and deficiencies.

Remember, every organization is unique, and the specific challenges they face will vary. However, by addressing these common mistakes, organizations can increase their chances of successfully implementing NIST 800-171 practices and passing an audit.

For assistance with your CMMC efforts, contact DTC’s C3PAO team.