When You’re a Little Late Starting Your CMMC Compliance Journey
And defense contracts are already including CMMC requirements
Many Defense Industrial Base manufacturers didn’t ignore CMMC — they prioritized production, delivery schedules, workforce challenges, and supply chain pressure while the program evolved. Now, as CMMC requirements begin appearing in contracts and solicitations, those same manufacturers are being asked a harder question:
How do we move forward without disrupting operations or blowing up scope and cost?
At this stage, the challenge isn’t understanding what CMMC is. It’s deciding where to start, what to fix first, and how to avoid missteps that make compliance harder than it needs to be.
Where CMMC Efforts Commonly Go Sideways
For manufacturers coming to CMMC later in the rollout, problems rarely start with policies or awareness. They start with infrastructure realities that were never designed with assessment boundaries in mind.
Common issues include:
- Flat or loosely segmented networks connecting office IT, engineering systems, and production equipment
- Cloud services adopted quickly without clear security baselines
- Legacy systems that can’t be patched or monitored traditionally
- Limited visibility into where CUI actually resides
- Shared credentials and inconsistent access controls
Once these conditions exist, compliance efforts tend to expand in scope, increase in cost, and slow production — especially when they’re discovered during formal compliance activities.
How CMMC Is Evaluated in Practice
CMMC assessments evaluate how effectively required cybersecurity controls are implemented across operational systems, not how well requirements are described on paper.
Assessors look for:
- Consistent, enforceable configurations
- Evidence that controls operate as intended
- Visibility into system activity
- Alignment between documentation and real-world behavior
Grading uses a point-based methodology that weights risk, which means infrastructure weaknesses in high-impact areas can have an outsized effect on assessment outcomes. Organizations must successfully meet the assessment requirements for the applicable CMMC level in order to remain eligible for contract award.
At this stage of the journey, infrastructure decisions matter more than documentation decisions.
Infrastructure Readiness: The Fastest Way to Regain Control
For manufacturers who are starting later than planned, infrastructure readiness is the most effective way to stabilize a CMMC effort.
Infrastructure readiness focuses on:
- How systems are connected
- How access is enforced
- How activity is logged and monitored
- How production, engineering, and business environments are separated
Addressing these elements early helps organizations:
- Control assessment scope
- Reduce remediation cycles
- Avoid last-minute architectural changes
- Protect production uptime
It also creates a technical foundation that compliance and assessment partners can actually work with.
Manufacturing Environments Require a Different Approach
Manufacturing environments are not clean, greenfield IT networks. They are a blend of:
- Office IT
- Engineering systems
- OT and production equipment
- Third-party integrations
- On-prem and cloud infrastructure
CMMC does not require ripping and replacing these systems — but it does require intentional design around how they interact. The earlier this design work happens, the less disruptive and costly it becomes.
How TotalCare IT Helps at This Stage
TotalCare IT works with Defense Industrial Base manufacturers who are already feeling time pressure from CMMC requirements and need to move forward without derailing operations.
We focus on infrastructure readiness, including:
- Secure configuration of workstations, servers, and network infrastructure
- Network segmentation between business, engineering, and production systems
- Secure design and management of on-prem and cloud environments
- Implementation and management of cybersecurity tools that support NIST SP 800-171 Revision 2
- Preparing systems to withstand real-world assessment scrutiny
- Our role is to ensure your environment is technically ready before formal compliance activities begin.
For gap assessments, documentation, and certification activities, TotalCare IT partners with trusted local compliance firms and Certified Third-Party Assessor Organizations (C3PAOs). This approach helps manufacturers avoid paying compliance teams to diagnose foundational infrastructure problems late in the process.
The Advantage of Acting Now — Even If You’re Late
Starting later than ideal does not mean starting behind — if the right work happens first.
Manufacturers that focus early effort on infrastructure readiness are better positioned to:
- Move efficiently through compliance phases
- Reduce assessment surprises
- Protect production schedules
- Maintain eligibility for future defense contracts
CMMC compliance is a journey, but the direction you choose at the start determines how hard the road ahead becomes.
→ Schedule a quick strategy call with our team to walk through your next steps.
FAQ for Manufacturers Entering CMMC Now
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Has anything changed with CMMC 2.0 now that the DoD is also using the name “Department of War”?
No. Nothing about CMMC requirements, assessments, or enforcement has changed.
CMMC remains a program of the U.S. Department of Defense (DoD). All binding regulations, contracts, and compliance requirements continue to reference the Department of Defense. For compliance, contracting, and assessment purposes, organizations should continue to use DoD terminology.
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Is CMMC 2.0 based on NIST SP 800-171 Revision 3?
No. CMMC 2.0 is currently based on NIST SP 800-171 Revision 2.
While NIST has released Revision 3, it has not been adopted by the Department of Defense for CMMC purposes. Current assessments, scoring methodologies, and contract requirements continue to reference Revision 2. Any transition to Revision 3 would require formal DoD rulemaking and updated DFARS language.
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Does a senior company official really have to affirm CMMC compliance?
Yes. For applicable CMMC levels, a senior company official must formally affirm that the organization meets the required cybersecurity requirements at the time of assessment.
This affirmation underscores that CMMC is not just a technical or IT initiative — it is an organizational responsibility. Leadership is attesting that required controls are implemented and operating as intended across the environment.
This is one reason infrastructure readiness is critical. Executives are far more comfortable affirming compliance when systems, networks, and security controls are consistently configured, visible, and defensible under assessment scrutiny.
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Does starting late mean we can’t succeed with CMMC?
No — but prioritization matters.
Organizations that start later often succeed by focusing first on infrastructure readiness, which helps control scope, reduce remediation cycles, and avoid costly surprises during assessments. Addressing foundational technical issues early allows compliance efforts to move faster and with less disruption.
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What typically causes delays or rework during a first CMMC assessment?
Most delays occur when infrastructure decisions made earlier expand assessment scope or expose gaps late in the process. Flat networks, unclear CUI boundaries, inconsistent access controls, and cloud misconfigurations are common drivers of rework.
Addressing infrastructure readiness early reduces these risks and helps assessments proceed more smoothly.
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Does TotalCare IT perform CMMC assessments or certifications?
No. TotalCare IT specializes in infrastructure readiness, including systems, networks, cloud environments, and cybersecurity tool implementation.
For formal compliance activities such as gap assessments, documentation, and certifications, we partner with trusted local compliance firms and Certified Third-Party Assessor Organizations (C3PAOs).