Top 15 Most Common CMMC Compliance Mistakes Series #9
This article is part of our expert-led series: The Top 15 Most Common CMMC Compliance Mistakes (and How to Solve Them). Throughout this series, we're dissecting the frequent errors, misunderstandings, and misconceptions organizations encounter on their path to CMMC certification, drawing insights from seasoned CCPs, CISOs, and CCAs.
Today’s focus: We discuss how many organizations approach CMMC compliance as an IT-centric initiative, focusing primarily on technical controls and system configurations. However, this perspective overlooks the broader organizational transformation required.
What You’ll Learn
- Why CMMC compliance extends beyond IT departments
- The organizational changes necessary for successful compliance
- Tips on securing buy-in from impacted departments
- Strategies to foster a culture of cybersecurity awareness
CMMC Compliance is Not an IT Project, It's a Company-Wide Change
While IT plays a significant role in implementing security controls, it's estimated that only about 33% to 40% of the CMMC requirements are purely technical. The remaining 60% to 67% involve organizational policies, personnel training, physical security measures, and leadership engagement.
For instance, DFARS Clause 252.204-7012 mandates that contractors implement NIST SP 800-171, which encompasses 110 security controls across 14 families, including:
- Access Control
- Awareness and Training
- Audit and Accountability
- Configuration Management
- Identification and Authentication
- Incident Response
- Maintenance
- Media Protection
- Personnel Security
- Physical Protection
- Risk Assessment
- Security Assessment
- System and Communications Protection
- System and Information Integrity
These controls require a comprehensive approach involving various departments and functions within an organization. For example, "Awareness and Training" necessitates regular employee education on security protocols, while "Personnel Security" involves background checks and access controls managed by HR and security teams.
Embracing Organizational Change
Achieving CMMC compliance isn't just about meeting technical standards; it's about fostering a culture of security throughout the organization. This cultural shift involves:
- Leadership Commitment: Senior management must prioritize cybersecurity and allocate necessary resources.
- Employee Engagement: All staff should understand their role in maintaining security and be encouraged to report potential issues.
- Process Integration: Security practices should be embedded into daily operations, not treated as separate or additional tasks.
Organizations that recognize and embrace this cultural change are better positioned to achieve and maintain CMMC compliance.
Departmental Impact: Who Is Involved in CMMC Compliance?
|
Department |
What’s Required |
|
Executive Leadership |
Drives organizational priorities, approves compliance budgets, and sets the tone for security culture. CMMC requires visible support and accountability from leadership. |
|
Information Technology (IT) |
Implements and manages technical controls including system security, access management, logging, and endpoint protection. Responsible for roughly one-third of CMMC control objectives. |
|
Human Resources (HR) |
Manages personnel security processes like background checks, onboarding/offboarding, and training compliance. Supports requirements under "Personnel Security" and "Awareness and Training." |
|
Legal / Contracts / Procurement |
Ensures suppliers and subcontractors meet flow-down and contractual compliance obligations. Also manages documentation and timelines related to incident reporting. |
|
Operations |
Embeds compliant handling of CUI into daily business processes, especially in departments where data is created or accessed outside IT systems. |
|
Facilities / Physical Security |
Maintains physical safeguards such as controlled access, surveillance, badge systems, and visitor protocols to protect CUI environments. |
|
Finance / Budgeting |
Allocates funding for compliance programs including technology, staffing, assessments, and continuous monitoring efforts. |
|
Security / Compliance Teams |
Oversees documentation such as SSPs and POA&Ms, monitors ongoing readiness activities, and coordinates with external assessors. |
|
End Users / General Staff |
Completes required training, follows data handling policies, and reports suspicious behavior or incidents. Plays a critical frontline role in everyday compliance. |
Expert Advice: Getting Company-Wide Buy-In for CMMC Compliance
Project leaders responsible for CMMC compliance often face a challenge: translating a highly technical, regulation-driven initiative into something that resonates with executives, staff, and departments that may not view cybersecurity as part of their role. The key to success is framing CMMC as a strategic, company-wide shift, not just a compliance checklist.
Here are practical steps to help gain buy-in across the organization:
Start with the Business Case
Link CMMC to clear business outcomes. This could include retaining or gaining Department of Defense (DoD) contracts, entering new markets, or building customer trust. When employees understand the "why," they’re more likely to engage with the "how."
Secure Visible Executive Sponsorship
Have a member of the leadership team publicly support the initiative, reinforcing that this isn’t just an IT project. Their support should include messaging in internal communications, alignment in budget discussions, and participation in early planning sessions.
Tailor Messaging to Each Department
Avoid one-size-fits-all communications. Explain to each group how compliance impacts their daily work, and where their specific responsibilities lie. Use plain language to avoid confusion or resistance.
Integrate Training Early
Don’t wait until the end of the project to introduce compliance training. Begin educating departments as soon as possible so they feel prepared and understand what success looks like.
Show Progress Visually
Use dashboards, internal updates, and visual metrics to demonstrate how the organization is progressing toward compliance. Small wins help maintain momentum.
Celebrate Milestones
Recognize when a team completes their portion of policy updates, remediation, or training. Highlighting success encourages others to stay engaged.
Make it Personal
Security culture starts with people. Remind teams that protecting sensitive data isn’t just about compliance , it’s about protecting the company, their jobs, and national security.
In Summary: Embracing CMMC as a Company-Wide Commitment
CMMC compliance requires more than technical solutions; it demands a holistic organizational transformation. By fostering a culture of cybersecurity awareness and integrating security practices into daily operations, organizations can not only achieve compliance but also enhance their overall security posture.
Key Takeaways
- CMMC compliance extends beyond IT, encompassing organizational policies and culture.
- Leadership commitment and employee engagement are critical for successful compliance.
- Integrating security practices into daily operations fosters a sustainable security culture.
Up Next In Our Top 15 Most Common CMMC Mistakes Series:
In our next article, we'll explore the misconception that creating an isolated IT environment, or enclave, is a comprehensive solution for CMMC compliance.