Your CMMC Compliance Checklist for DOD Contracts

If you're in construction and bidding on Department of Defense (DoD) projects, you've likely heard about Cybersecurity Maturity Model Certification (CMMC). It can seem overwhelming, but it doesn't have to be. Let’s simplify this process together and put your construction business on track for compliance.  

What is CMMC?  

Cybersecurity Maturity Model Certification (CMMC) is a unified cybersecurity standard created to protect sensitive information related to DoD contracts, specifically Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).   

For construction companies bidding on DoD contracts, CMMC represents more than just another compliance hurdle. It's a crucial security requirement that affects your eligibility for DoD work and shows your commitment to protecting national security information. The certification verifies that contractors have implemented appropriate cybersecurity measures based on the sensitivity of the information they handle.  

Understanding CMMC Levels for Construction: What's Required?  

The CMMC has three certification levels, each requiring different levels of cybersecurity measures.  

While some may find Level 1 (essentially cybersecurity hygiene) is enough for them, most construction contractors aiming for larger or more sensitive projects will need to target Level 2 compliance.  Level 3 usually applies to contractors involved in highly sensitive DoD projects.  

More importantly though, the need for Level 2 compliance is great. As of this writing, the list of Level 2 authorized organizations remains small creating a sense of urgency as the auditing queue backs up.  

CMMC Compliance Checklist for Construction Contractors  

Navigating CMMC compliance for construction can feel like managing a complex job site. There are moving parts everywhere, tight deadlines, and zero room for error. To help, we've mapped out each critical step to guide you smoothly through the compliance process. Let’s break it down together. 

 Step 1: Designate a CMMC Compliance Lead  

Your journey to CMMC compliance starts with appointing a dedicated compliance lead. This person becomes your organization's cybersecurity expert, taking ownership of the certification process and coordinating efforts across departments. 

Your compliance lead should:  

Executive support is crucial here. When leadership shows a commitment to cybersecurity, employees across the organization follow suit.   

Step 2: Determine Your CMMC Level and Scope  

Identify your required CMMC level based on your existing or targeted contracts. Clearly define the scope by pinpointing precisely where your company stores, processes, or transmits FCI or CUI.   

Once you know your required level, define your compliance scope by asking:  

Doing this early on saves time and resources, making compliance easier and more cost-effective. 

Step 3: Conduct a Thorough Gap Analysis  

With your scope defined, assess your current security practices against CMMC requirements. For Level 2 compliance, compare your controls to all 110 NIST SP 800-171 requirements.  

Your gap analysis should:  

This assessment provides a realistic picture of your compliance status and forms the foundation for your remediation plan.   

Step 4: Develop a System Security Plan (SSP)  

An SSP documents exactly how your construction business meets each NIST SP 800-171 control. Think of this as your cybersecurity blueprint. It's foundational for your compliance efforts and essential for any assessments you'll undergo.  

Step 5: Implement Necessary Security Controls  

Now it's time to put your plan into action. Implement the necessary security controls as outlined by NIST SP 800-171, such as:  

Step 6: Document Policies and Procedures  

Document clear cybersecurity policies and standard operating procedures. These records not only show how you maintain compliance but also serve as auditable proof during assessments. 

Consider creating documentation for areas such as:  

Step 7: Select and Implement Secure Technology Solutions  

Choose secure software and solutions specifically designed to protect sensitive DoD information. Examples include secure file sharing systems, encrypted communication tools, and robust data storage solutions built for security compliance.  

When selecting your tools, prioritize solutions designed with security in mind. Your software should make compliance more achievable and strengthen cybersecurity, not introduce additional risks. 

Step 8: Train Employees on Cybersecurity Best Practices  

Your employees play a critical role in protecting information. Provide ongoing, comprehensive training on topics such as recognizing phishing attempts, safe data handling, secure password management, and procedures for incident reporting.  

Step 9: Conduct a Self-Assessment and Calculate Your SPRS Score  

Before going through an official assessment, conduct a thorough self-assessment using NIST SP 800-171 as your guide. This reveals any remaining gaps and helps determine your readiness for certification. 

 During self-assessment:  

You’ll need to report your SPRS score to the DoD, as it shows your compliance level with NIST SP 800-171. A higher score reflects stronger security controls and can positively influence your ability to win contracts.  

Step 10: Develop and Implement a Plan of Action and Milestones (POA&M)  

Use your assessment results to create a POA&M, a structured plan detailing how you’ll close gaps in compliance. Clearly outline tasks, assign responsibility, set achievable timelines, and allocate necessary resources.  

Your POA&M should include:  

Prioritize high-risk deficiencies while creating a realistic schedule that accounts for your construction company's operational demands and resource constraints.  

Step 11: Remediate Vulnerabilities and Update Documentation  

Follow your POA&M closely to address identified vulnerabilities. Once you've fixed the issues, update your SSP, policies, and procedures accordingly. Regular updates ensure your compliance documentation remains accurate and audit-ready.  

Step 12: Schedule and Undergo a CMMC Third-Party Assessment  

Finally, you’ll need to schedule your official assessment with a Certified Third-Party Assessment Organization (C3PAO). During this assessment, the C3PAO will review your documentation, processes, and systems to confirm compliance.