The CMMC Assessment Gamble: Why "Assess First, Fix Later" Is a Risky Strategy

Interested in learning how Virtru can help your organization meet 27 of the 110 CMMC controls? Connect with our team at two upcoming events:
CMMC Day - May 5th - Schedule a meeting | CEIC West - May 21-23rd - Schedule a meeting

In the defense industrial base, we're seeing a concerning trend: organizations planning to "just get through" their CMMC 2.0 (Cybersecurity Maturity Model Certification) assessment and figure the rest out afterward. This approach might seem cost-effective in the short term, but it's creating significant business risks and cyber threats that many leadership teams aren't fully considering.

Understanding the Stakes of CMMC 2.0

The introduction of the final rule of CMMC 2.0 represented a fundamental shift in how the Department of Defense ensures its contractors are protecting sensitive information, or CUI (controlled unclassified information). Unlike previous self-attestation models, subsets of CMMC level 2 and CMMC level 3 require third-party verification of your cybersecurity practices across 110 specific security controls.

Recommended Reading: Compliance Theater vs. Security Reality: Moving Beyond CMMC Checkboxes

Why "Assess First, Fix Later" Is a Dangerous Game

Assessments Are Rigorous, Not Forgiving

CMMC assessors conduct detailed reviews of how your organization implements each required control. They're looking for evidence of not just security policies on paper, but actual implementation, governance, and consistent practice. This isn't a situation where you can talk your way through problems or promise future fixes.

Failed Assessments Create Contract Vulnerabilities

We're increasingly seeing prime contractors conducting their own security audits of subcontractors. Many are now requiring passed CMMC audits and assessments before awarding new contracts or even continuing existing relationships. A failed assessment doesn't just mean regulatory non-compliance—it can immediately threaten your revenue pipeline.

Reassessment Timelines Are Longer Than You Think

The math simply doesn't add up: there are over 76,000 suppliers in the defense industrial base that need CMMC 2.0 assessment, but roughly 65 authorized C3PAOs (CMMC Third-Party Assessment Organizations) to perform these evaluations. This staggering imbalance means assessment slots are extremely limited and valuable.

Organizations that fail their initial assessment are discovering they may wait months—potentially even a year or more—for a reassessment opportunity. Sure, if you fail by a hair, you can submit a POAM (Plan of Action and Milestones). But if you’ve failed the assessment by a large margin with a painful gap analysis, it won’t be enough. During this time, your ability to bid on new contracts or maintain existing ones could be severely compromised.

Not All C3PAOs are Created Equal

January 2025 DOD audit findings reveal a concerning gap in the CMMC compliance process: multiple C3PAOs were authorized despite lacking proper qualifications and documentation. With some assessors operating without verified team certifications or signed agreements, contractors may face inconsistent evaluation standards during their assessments.

The CMMC framework remains essential for defense industrial base security, but these findings show the authorization system itself is still maturing. Don't make the mistake of waiting for a C3PAO to determine your security approach—establish your NIST 800-171 fundamentals now. A robust security program built on proven standards will serve you better than relying on guidance from assessment organizations whose own qualifications may be in question.

The Hidden Costs of Remediation Under Pressure

CMMC assessments are already expensive. In a recent CMMC Compass Webinar, Joe Devine, President of Axiotrop, said, "I haven't had a quote for any size organization below $50,000. Assessments typically range from $50,000 to $80,000+ depending on organization size.” If you fail your first assessment, you may be in the position of paying for evaluation a second time — or even more if those services must be expedited.

When organizations fail assessments, they often find themselves implementing cybersecurity solutions in crisis mode—paying premium prices for expedited services, disrupting operations with rushed implementations, and making hasty tech stack decisions that won’t be optimal for a long-term cybersecurity posture.

The DOD's Uncompromising Position: The Clock Has Run Out

If you're hoping the Department of Defense might soften its stance on CMMC or extend timelines, recent statements from leadership should quickly dispel that notion. Katie Arrington, DOD's acting chief information officer, has made the Pentagon's position crystal clear: the time for excuses is over.

"If you go on LinkedIn one more time and tell me how hard CMMC is, I'm going to beat you," Arrington bluntly stated at a recent AFCEA DC luncheon. "That ship sailed in 2014."

Arrington, who previously led the initial CMMC rollout during the first Trump administration, pointedly reminded contractors that they've had over 11 years to implement NIST 800-171 controls. The only thing that's changed is that self-attestation is no longer sufficient—now there's verification.

Even more concerning for procrastinators: complaining publicly about CMMC requirements may actually increase your risk of being targeted for audit. "Do you think the government isn't watching?" Arrington warned, noting that vocal complainers are putting themselves in the crosshairs of the Defense Contract Management Agency.

The DOD is actively monitoring industry discussions and has little patience for organizations that haven't prepared during the lengthy runway they've been given. The message is unmistakable: CMMC isn't a negotiable framework or a future consideration—it's a present requirement with real consequences for non-compliance.

With Arrington's declared intention to overhaul the risk management assessment framework and accelerate software security processes, it's clear the Pentagon is moving toward more rigorous security enforcement, not less. Organizations hoping to wait out CMMC are playing a dangerous game with their business future in the defense industrial base.

A Better Approach: Preparation With Purpose

Smart organizations are taking a different path:

1. Conduct an honest gap assessment before your official assessment
2. Prioritize high-impact controls that protect the most sensitive information
3. Implement foundational solutions that address multiple control requirements at once
4. Document your implementation thoroughly as you go

Recommended Reading: CMMC 2.0 Quick-Start Guide for Defense Contractors

Start With Protecting CUI—It's The Heart of CMMC

One of the most critical areas for CMMC 2.0 compliance is properly safeguarding Controlled Unclassified Information (CUI). Many organizations mistakenly believe their standard Microsoft 365 encryption is sufficient, but this approach often falls short of CMMC requirements.

Virtru is FedRAMP authorized at the moderate level, addressing  27 CMMC security controls across multiple CMMC domains, including Access Control, Audit and Accountability, Identification and Authentication, Media Protection, and Systems and Communications Protection. It also provides a relatively quick implementation (days not weeks) that can significantly advance your compliance posture while you align on more complex requirements. Organizations like Master Electronics have implemented such solutions in weeks rather than months, giving them a substantial head start on their compliance journey.

Recommended Reading: Virtru Shared Responsibility Matrix for CMMC 2.0

Bottom Line: Preparation Pays Dividends

While preparing properly for CMMC certification requires investment, it's far less expensive than the combined costs of:

• Failed assessments (and repeated assessments)
• Lost contract opportunities
• Rushed remediation
• Reputational damage
• Business disruption

With a limited number of assessment organizations trying to certify 76,000+ contractors, failing your CMMC assessment process could mean being pushed to the back of a very long line while your competitors move forward with DoD contracts.

The most successful DIB contractors aren't viewing CMMC as an inspection to survive—they're treating it as a business enabler that demonstrates their commitment to protecting our nation's sensitive information. At the end of the day, checking the box for compliance is not the same as true security for the asset that matters most: Sensitive data.

Is your organization ready for CMMC assessment, or are you taking unnecessary risks? A proper pre-assessment review and strategic implementation plan could make all the difference between certification success and costly failure.

Interested in learning how Virtru can help your organization meet 27 of the 110 CMMC controls? Connect with our team at two upcoming events:

CMMC Day - May 5th - Schedule a meeting
CEIC West - May 21-23rd - Schedule a meeting

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