If someone claims they have a "guaranteed, all-in-one" fix for CMMC, they are trying to pull a fast one on you. If they insist, they can, have your lawyer put it as part of the contract and see them scramble to get "guaranteed" removed. The CMMC is a comprehensive move by the U.S. Department of Defense (DoD) that involves many moving parts and can take months to years to implement fully.
CMMC is no longer a future requirement, it's now a formal DoD program with contract enforcement underway. The CMMC Program Rule (32 CFR Part 170) became effective December 16, 2024, and the DFARS CMMC Rule adding CMMC requirements to contracts became effective November 10, 2025. If your organization handles Controlled Unclassified Information (CUI), preparing for CMMC Level 2 certification is no longer optional.
Even before CMMC appears in your contract, contractors must comply with DFARS 252.204-7012, 7019, and 7020, maintain a defensible NIST SP 800-171 score, and report that score to SPRS. Missing or inaccurate SPRS scores can block new awards and expose your company to False Claims Act liability.
Why CMMC Matters Now
CMMC 2.0 introduces tiered cybersecurity requirements for DoD contractors, including:
- Level 1: Annual self-assessments for contractors handling only FCI
- Level 2: Third-party assessments (C3PAO) for contractors handling CUI
- Minimum passing scores and POA&M limitations
- More rigorous evidence requirements for every NIST SP 800-171 control
CMMC is built on the 110 NIST 800-171 controls already required under DFARS. If you're not compliant today, you're already behind.
What Is Required Right Now (DFARS Requirements Still Active)
Before contract-level CMMC enforcement, contractors must already:
- Implement NIST SP 800-171
- Perform a valid DoD self-assessment
- Upload their SPRS score
- Maintain a System Security Plan (SSP)
- Maintain a Plan of Action & Milestones (POA&M)
- Be prepared for DCMA/DIBCAC validation assessments
If your SPRS score is inaccurate or over-inflated, your organization may face serious compliance and legal consequences.
Key Steps to Get Ready for CMMC Certification
1. Build an Evidence-Based SSP
Your SSP must document system boundaries, policies, procedures, CUI flows, inherited controls, and evidence for each of the 110 NIST SP 800-171 requirements. Templates and generic statements no longer pass assessments.
2. Identify and Scope Your CUI Environment
Accurate boundary definition determines whether you need CMMC Level 1 or Level 2 and how much your CMMC compliance will cost.
3. Conduct a Real NIST SP 800-171 Self-Assessment
Use the official DoD Assessment Methodology—not vendor checklists. A defensible SPRS score requires proof for each claimed control.
4. Build a POA&M and Budget for Remediation
Plan owners, timelines, tooling, and budgets must be clearly documented. POA&Ms must be actively managed, especially under CMMC certification. Our Virtual Chief Security Officer program provides ongoing oversight to keep your POA&M on track.
5. Upload Your Score to SPRS
If your SPRS score is missing or outdated, you're not eligible for new DoD contracts at https://www.sprs.csd.disa.mil/.
6. Document Everything
Documentation is the backbone of both DFARS and CMMC. Assessors will review evidence for policies, procedures, logs, configurations, diagrams, and system changes.
Why Work With a C3PAO for CMMC Readiness
Preparing for CMMC Level 2 is complex. Working with an authorized C3PAO such as BomberJacket Networks ensures your organization receives expert guidance on:
- CMMC readiness assessments
- SSP and POA&M development
- CUI scoping and boundary definition
- Evidence collection
- Pre-assessment and remediation strategies
- NIST SP 800-171 implementation support
- CMMC Level 2 assessment preparation
Final Takeaway
If you cannot defend your NIST SP 800-171 implementation today, you will not pass a CMMC Level 2 assessment tomorrow.
CMMC is now official, active, and enforced. Organizations that prepare early protect revenue, reduce compliance risk, and stay competitive in the DoD marketplace.
BomberJacket Networks — an authorized C3PAO — is ready to help you achieve and maintain CMMC compliance.
Contact us today to get started with your CMMC readiness assessment.
Need Help with CMMC Compliance?
BomberJacket Networks is Minnesota's only C3PAO-authorized MSP with 25 years of expertise. Get a free consultation to assess your CMMC compliance readiness.