CMMC Compliance Consultant & Virtual CISO for Defense Contractors
Facing CMMC Level 2 or CMMC Level 3 certification? Your DoD contracts depend on passing — not trying. As your virtual CISO for CMMC compliance, I deliver the cybersecurity risk assessment, NIST 800-171 gap analysis, SSP authoring, POA&M management, and C3PAO audit preparation required to certify on time. 100% audit success rate across CMMC, NIST 800-171, ITAR, and CUI engagements.
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CMMC Is Not Optional — It's Contract-Ending
DFARS 252.204-7021 makes CMMC certification a contract requirement for DoD work involving CUI
No Certification, No Contract
Prime contractors are already flowing CMMC requirements down to subcontractors. Without certification at the required level, you cannot bid, cannot be awarded, and risk termination of existing contracts.
SPRS Score Visibility
Your NIST 800-171 self-assessment score is visible to DoD contracting officers in the Supplier Performance Risk System (SPRS). A low score is a disqualifier before a single bid is reviewed.
False Claims Act Exposure
Under recent DOJ Civil Cyber-Fraud Initiative enforcement, misrepresenting NIST 800-171 compliance to DoD can trigger False Claims Act liability — with treble damages and whistleblower incentives.
The Timeline Is Real
CMMC rollout is phased, but the clock is running. Contractors who start certification preparation now position themselves ahead of bid cycles. Those who wait get locked out.
Prime Contractor Pressure
Primes are requiring subcontractors to certify ahead of CMMC mandates to de-risk their own contracts. If you're in the supply chain, the pressure arrives before the regulation does.
C3PAO Capacity Is Limited
The pool of authorized C3PAO assessors is finite and booking months out. Contractors who wait to schedule assessments face real delays — and risk missing contract award windows.
Our CMMC Compliance Approach
A structured path to CMMC certification — not a consulting report that gathers dust.
Scoping & Cybersecurity Risk Assessment
Define your CMMC boundary — which systems process, store, or transmit CUI. Conduct a full cybersecurity risk assessment mapped to the 110 NIST 800-171 controls. Output: SPRS-ready scoring with a prioritized gap register.
SSP Authoring & POA&M Development
Write or rebuild your System Security Plan to withstand C3PAO scrutiny. Develop a POA&M that addresses every unmet control with realistic milestones and owners.
Remediation & Evidence Collection
Lead the hands-on remediation — access control, audit logging, incident response, configuration management, media protection, physical security, and more. Collect evidence continuously so the audit is a formality.
C3PAO Audit Preparation & SPRS Reporting
Run a pre-assessment against CMMC assessment procedures. Coordinate with your chosen C3PAO. Sit alongside you during the assessment. Manage SPRS score reporting and post-audit sustainment.
The Three CMMC Levels — Which Applies to You?
Your required level depends on the type of DoD information you handle
CMMC Level 1 — Foundational
Who: Contractors handling Federal Contract Information (FCI) only.
Requirements: 17 basic cyber hygiene practices aligned to FAR 52.204-21.
Assessment: Annual self-assessment with executive affirmation.
CMMC Level 2 — Advanced
Who: Contractors handling Controlled Unclassified Information (CUI).
Requirements: All 110 NIST SP 800-171 controls.
Assessment: Self-assessment for some contracts; C3PAO third-party assessment every 3 years for prioritized acquisitions.
CMMC Level 3 — Expert
Who: Contractors supporting DoD's highest-priority programs.
Requirements: All Level 2 controls plus a subset of NIST SP 800-172.
Assessment: Government-led DIBCAC assessment every 3 years.
What Your CMMC vCISO Engagement Includes
Full NIST 800-171 gap analysis with SPRS scoring.
Audit-defensible System Security Plan aligned to your scoped CUI boundary.
Tracked remediation plans with realistic milestones and weighted scoring.
The 20+ policies required to pass CMMC — written, not templated.
Clear documentation of how CUI enters, flows through, and exits your environment.
Vetted C3PAO recommendations, scheduling support, and assessment-day advocacy.
Accurate, defensible SPRS submissions — no False Claims Act exposure.
Not just advice — active management of your remediation backlog.
Typical CMMC Certification Timeline
From engagement start to C3PAO certification — a realistic path
Scope, Assess, Score
- CUI boundary definition and asset inventory
- Full cybersecurity risk assessment against NIST 800-171
- Initial SPRS score calculation
- Gap register with weighted prioritization
- Quick-win remediations identified and scheduled
Close Gaps, Build Evidence
- SSP authored and maintained as a living document
- POA&M managed with defensible milestones
- Technical controls implemented (MFA, logging, encryption, access control)
- Administrative controls formalized (policies, training, IR plan)
- Evidence collection automated where possible
Pre-Assessment & C3PAO Certification
- Internal pre-assessment against CMMC assessment procedures
- C3PAO engagement and assessment scheduling
- On-site audit support and evidence walkthrough
- SPRS score update and certification issuance
- Sustainment program for the 3-year certification window
CMMC Compliance FAQ
What is CMMC and who has to comply?
+CMMC (Cybersecurity Maturity Model Certification) is the DoD's cybersecurity framework for the Defense Industrial Base. Any contractor or subcontractor handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) must comply. Level 1 covers FCI handlers and requires self-assessment. Level 2 covers CUI handlers and requires third-party C3PAO assessment for prioritized acquisitions. Level 3 covers programs with the highest-value CUI and is assessed by DIBCAC.
What's the difference between NIST 800-171 and CMMC Level 2?
+CMMC Level 2 is built directly on NIST SP 800-171's 110 security controls. The key difference is verification: NIST 800-171 has historically relied on self-attestation via SPRS scores, while CMMC Level 2 adds a third-party assessment requirement (C3PAO) for prioritized acquisitions. Organizations already strong on NIST 800-171 are partway to CMMC Level 2 certification.
How long does CMMC certification take?
+For most defense contractors, the path from engagement start to CMMC Level 2 certification takes 6 to 12 months. The timeline includes: 30 days for scoping and cybersecurity risk assessment, 60 to 180 days for remediation and POA&M closure depending on starting maturity, 30 to 60 days for pre-assessment and evidence collection, and 60 to 90 days for C3PAO audit scheduling and execution.
What is an SSP and do I need one for CMMC?
+An SSP (System Security Plan) is a required document for CMMC and NIST 800-171. It describes your in-scope systems, the boundary of CUI handling, how each of the 110 NIST 800-171 controls is implemented, and references supporting policies and evidence. A weak or missing SSP is one of the most common reasons contractors fail CMMC assessments. Your CMMC vCISO engagement includes SSP authoring and maintenance.
What is a POA&M and how does it affect CMMC certification?
+A POA&M (Plan of Actions and Milestones) is the formal tracking document for unmet NIST 800-171 controls and remediation plans. Under CMMC Level 2, only a limited number of low-weighted controls can remain on the POA&M at assessment time — higher-weighted controls must be fully met. Managing the POA&M strategically is critical to passing your C3PAO audit on the first attempt.
What happens if we fail CMMC certification?
+A failed C3PAO assessment means you cannot bid on or execute contracts requiring CMMC certification at that level. Existing contracts may be at risk of suspension or termination. You can remediate and re-assess, but the process costs additional time and money and typically delays contract awards by 6 to 9 months. Working with a virtual CISO who has a 100% CMMC audit success rate dramatically reduces this risk.
Ready to Start Your CMMC Certification?
Schedule a free 30-minute consultation. We'll review your current SPRS score, your contract CMMC requirements, and build a realistic path to certification. Explore our virtual CISO pricing tiers or read about ITAR cybersecurity if you also handle export-controlled technical data.
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