Common CMMC Gaps and How to Fix Them

Comprehensive guide to identifying and remediating typical CMMC compliance gaps

Get Gap Analysis Help

About This Guide

This comprehensive guide identifies the most common CMMC compliance gaps found in defense contractor organizations and provides practical solutions for addressing them. Based on real-world assessments and industry experience, these gaps represent the most frequent challenges contractors face.

How to Use This Guide:

  • • Review each gap category to understand common issues
  • • Assess your organization against each gap
  • • Implement the recommended solutions
  • • Document your remediation efforts

Common CMMC Gap Categories

Access Control Gaps

Issues related to user access management, authentication, and authorization controls.

Gap: Weak Password Policies

Many organizations use weak password requirements that don't meet CMMC standards.

Common Issues:
  • • Passwords too short (less than 8 characters)
  • • No complexity requirements
  • • No password expiration
  • • Shared passwords across systems
Solutions:
  • • Implement strong password policies (8+ chars, complexity)
  • • Enable password expiration (90 days)
  • • Prohibit password reuse
  • • Use unique passwords for each system

Gap: Lack of Multi-Factor Authentication

Many organizations don't implement MFA, which is required for CMMC Level 2.

Common Issues:
  • • No MFA implementation
  • • MFA only on some systems
  • • Weak MFA methods (SMS only)
  • • No MFA for administrative accounts
Solutions:
  • • Implement MFA on all systems
  • • Use authenticator apps or hardware tokens
  • • Require MFA for all user accounts
  • • Especially for administrative access

Gap: Inadequate Access Reviews

Organizations often fail to regularly review and update user access permissions.

Common Issues:
  • • No regular access reviews
  • • Orphaned accounts remain active
  • • Excessive permissions granted
  • • No documentation of access decisions
Solutions:
  • • Implement quarterly access reviews
  • • Remove access for terminated employees
  • • Use principle of least privilege
  • • Document all access decisions

Documentation Gaps

Missing or inadequate security policies, procedures, and documentation.

Gap: Missing Security Policies

Many organizations lack comprehensive security policies required for CMMC compliance.

Common Issues:
  • • No written security policies
  • • Policies not updated regularly
  • • Policies not communicated to staff
  • • No policy approval process
Solutions:
  • • Develop comprehensive security policies
  • • Include all required CMMC elements
  • • Regular policy reviews and updates
  • • Employee training on policies

Gap: Inadequate Incident Response Procedures

Organizations often lack formal incident response procedures and documentation.

Common Issues:
  • • No incident response plan
  • • Unclear roles and responsibilities
  • • No communication procedures
  • • No post-incident review process
Solutions:
  • • Develop incident response plan
  • • Define roles and responsibilities
  • • Establish communication procedures
  • • Implement lessons learned process

Gap: Lack of Security Awareness Training

Many organizations don't provide adequate security awareness training to employees.

Common Issues:
  • • No security training program
  • • Training not role-specific
  • • No training documentation
  • • No regular refresher training
Solutions:
  • • Develop comprehensive training program
  • • Provide role-specific training
  • • Document all training activities
  • • Conduct regular refresher training

Technical Control Gaps

Missing or inadequate technical security controls and implementations.

Gap: Inadequate Network Security

Many organizations lack proper network segmentation and security controls.

Common Issues:
  • • No network segmentation
  • • Weak firewall configurations
  • • No intrusion detection systems
  • • Unsecured wireless networks
Solutions:
  • • Implement network segmentation
  • • Configure strong firewall rules
  • • Deploy intrusion detection systems
  • • Secure wireless networks

Gap: Insufficient Data Protection

Organizations often fail to properly protect sensitive data at rest and in transit.

Common Issues:
  • • No data encryption
  • • Unsecured data transmission
  • • No data classification
  • • Inadequate backup security
Solutions:
  • • Implement data encryption
  • • Use secure transmission protocols
  • • Develop data classification scheme
  • • Secure backup and recovery procedures

Gap: Inadequate Monitoring and Logging

Many organizations lack comprehensive security monitoring and logging capabilities.

Common Issues:
  • • No security monitoring
  • • Inadequate log collection
  • • No log analysis
  • • No security alerting
Solutions:
  • • Implement security monitoring
  • • Collect and analyze logs
  • • Deploy SIEM solutions
  • • Establish security alerting

Process Gaps

Missing or inadequate security processes and procedures.

Gap: No Risk Assessment Process

Many organizations don't conduct regular risk assessments as required by CMMC.

Common Issues:
  • • No formal risk assessment process
  • • Risk assessments not documented
  • • No risk treatment plans
  • • Risk assessments not updated regularly
Solutions:
  • • Develop risk assessment methodology
  • • Document all risk assessments
  • • Create risk treatment plans
  • • Conduct regular risk reviews

Gap: Inadequate Change Management

Organizations often lack formal change management processes for IT systems.

Common Issues:
  • • No change management process
  • • Changes not documented
  • • No change approval process
  • • No change testing procedures
Solutions:
  • • Implement change management process
  • • Document all changes
  • • Establish change approval process
  • • Implement change testing procedures

Gap: No Vulnerability Management

Many organizations don't have formal vulnerability management processes.

Common Issues:
  • • No vulnerability scanning
  • • No patch management process
  • • No vulnerability remediation
  • • No vulnerability tracking
Solutions:
  • • Implement vulnerability scanning
  • • Establish patch management process
  • • Create vulnerability remediation procedures
  • • Track vulnerability status

Gap Remediation Strategy

1

Identify Gaps

Conduct a comprehensive assessment to identify all CMMC compliance gaps in your organization.

2

Prioritize Remediation

Prioritize gaps based on risk level, implementation complexity, and business impact.

3

Develop Remediation Plans

Create detailed plans for addressing each gap, including timelines and resources.

4

Implement Solutions

Execute remediation plans and implement the necessary controls and processes.

5

Validate and Monitor

Validate that gaps have been addressed and implement ongoing monitoring.

Gap Remediation Best Practices

Planning Phase:

  • • Conduct thorough gap analysis
  • • Prioritize gaps by risk level
  • • Develop realistic timelines
  • • Allocate necessary resources

Implementation Phase:

  • • Start with high-impact, low-effort gaps
  • • Document all changes
  • • Test implementations thoroughly
  • • Train staff on new processes

Validation Phase:

  • • Verify gap closure
  • • Test control effectiveness
  • • Document evidence
  • • Update documentation

Ongoing Phase:

  • • Monitor control effectiveness
  • • Regular gap assessments
  • • Continuous improvement
  • • Staff training updates

Need Help Identifying and Fixing CMMC Gaps?

Get expert guidance on conducting gap analysis and implementing remediation strategies.

Schedule Free Consultation