CMMC has fundamentally transformed the landscape for defense contractors operating within the DIB. With mandatory compliance deadlines looming and contract requirements becoming increasingly stringent, organizations can no longer afford to treat cybersecurity as an afterthought.

Yet for many contractors, the path to CMMC Level 2 compliance remains fraught with challenges that extend far beyond simple technical implementation. Achieving CMMC Level 2 certification isn’t just about deploying the right security tools… It’s about having a deep understanding of your security and compliance posture.

The Source of Complexity: NIST SP 800-171 Rev. 3

At the heart of CMMC Level 2 lies NIST Special Publication 800-171, a framework containing 110 security requirements that form the requirements of the certification process. While these requirements encompass everything a stakeholder needs to know about compliance, they were also written for cybersecurity professionals rather than business owners or generalists.

This disconnect creates immediate barriers to implementation. Consider media sanitization. This seems like a clear directive: ensure that data storage devices are cleaned before being disposed of or reused.

But what does that all mean? What sort of sanitation will work here? Do you need to destroy the physical media or just erase it? What are the differences between disposal and repurposing?

For a small defense contractor without in-house cybersecurity expertise, these distinctions can mean the difference between compliant implementation and costly remediation during an assessment.

To address these challenges, the DoD has developed comprehensive assessment guides for each CMMC level. The Level 2 Assessment Guide represents a significant effort to bridge the gap between requirements and practice. The problem is that the Level 2 Assessment Guide exceeds 200 pages of dense, technical content filled with procedural requirements, assessment criteria, and implementation standards that require significant cybersecurity knowledge to interpret effectively. For many, these guides represent more complexity to navigate rather than a solution.

The Implementation Gap

Contractors have consistently identified a critical gap between the technical precision of CMMC requirements and the practical realities of implementation in diverse organizational contexts.

While the Cyber AB and the DoD have made concerted efforts to address this gap, several questions remain unaddressed. These governing bodies have held FAQ sessions, town halls, webinars, and supplied hundreds of pages of documentation. What’s missing, however, is clear direction for non-technical stakeholders who want to understand the process from a business perspective.

Strategies for Navigating Ambiguities

Successfully addressing the ambiguities and complexities inherent in CMMC Level 2 requirements calls for a strategic approach that incorporates the core documentation, some expert interpretation, and some deeper understanding of your security posture and (to be blunt) what your organization is capable of. Some of these strategies include:

Use Official Assessment Guides as the Baseline

The Level 2 Assessment Guide, despite its complexity, represents the most authoritative source for understanding specific implementation expectations and assessment criteria. Break the guide down into manageable, actionable sections and assign specific team members or external consultants to focus on particular requirement domains. Following that, translate each control from technical cybersecurity language into business-specific tasks broken down into steps that non-technical team members can understand.

Leverage Community and Industry Forums

The defense contractor community has developed numerous platforms dedicated to sharing practical insights, implementation experiences, and compliance strategies. There is some benefit to exploring these organizations and their forums to see what professionals are discussing, even if much of it is outside your skill set.

Invest in Expertise

Whether through external consultants or internal training programs, organizations must ensure that at least one team member develops a comprehensive understanding of NIST terminology, CMMC requirements, and cybersecurity best practices. An expert partner can fill several core roles:

A mediator between regulatory policy requirements and practical business implementation
A translator of complex technical concepts into actionable organizational practices
A decision-maker for ambiguous implementation questions
A point of contact during assessments

Validate with Real-World Testing

Conducting mock assessments or pre-assessments aligned with CMMC standards serves multiple critical functions in the compliance process. It helps identify implementation gaps, clarify misunderstandings about requirements, and provide experience with the assessment itself.

This type of testing is best conducted with a partner well-versed in CMMC, a firm that will not serve as your C3PAO but rather as a consulting RPO to guide you through this journey (without conducting actual assessments).

Document Everything, and Make Sure You Understand It

Comprehensive documentation represents one of the most critical success factors for CMMC compliance. Think of documentation as your insurance policy… it protects you during assessments and proves your commitment to cybersecurity.

Every implementation decision must be thoroughly documented:

When you choose specific security tools or methods, record why you made that choice.
When you interpret ambiguous requirements, document your reasoning and reference the guidance documents that supported your decision.
If you considered alternative approaches, explain why you rejected them.

These documents also serve the dual purpose of helping you understand why you made the decisions you did and ensuring that the reasoning behind those decisions is apparent to the organization.

If you’re not used to keeping documentation, there’s no time like the present to learn. Focus your documentation efforts on a few key areas. For policies and procedures, document when they were created and last updated, who approved them, and who is responsible for implementation. Also, specify how employees are trained on new procedures and provide evidence that these procedures are followed.

Security control decisions require detailed documentation of the specific technical implementations chosen, risk assessments that guided these decisions, cost-benefit analyses for security investments, and vendor evaluations and selection criteria.

Don’t Worry About the Technical Jargon. Trust Lazarus Alliance

Successfully navigating CMMC certification requires more than just checking off items on a checklist. It demands a culture of compliance, an understanding of controls and the “why” behind their use. While that could be a steep mountain to climb for some businesses, it’s also essential.

But, you don’t have to go at it alone.

To learn more about how Lazarus Alliance can help, contact us.

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Interpreting Requirements and Controls in CMMC