How to Run a Mid-Year CMMC Readiness Review

How to Run a Mid-Year CMMC Readiness Review

For organizations working toward Cybersecurity Maturity Model Certification (CMMC) compliance, maintaining momentum throughout the year is critical. A mid-year CMMC readiness review allows organizations to assess their current status, correct course where necessary, and ensure progress toward certification goals. This strategic checkpoint reinforces ongoing compliance efforts and prepares teams for upcoming audits.

This guide outlines a step-by-step approach to conducting a comprehensive and effective mid-year CMMC readiness review.

1. Define the Review Objectives and Scope

Begin by clearly stating the goals of the review. Is the purpose to assess readiness for an upcoming audit, to measure progress on a Plan of Actions and Milestones (POA&M), or to validate internal controls?

Define the scope of the review. Will it cover all 17 CMMC domains or focus on specific areas where risk has increased? Include details about systems, Controlled Unclassified Information (CUI) environments, and personnel involved.

Establish a timeline with key milestones and outcomes. A well-structured timeline ensures the review remains on track and that identified deficiencies can be addressed promptly.

2. Assemble a Cross-Functional Team

A thorough readiness review requires input from a variety of departments. Assemble a team that includes:

• Compliance or Governance Lead

• IT and System Owners

• Security Engineers or Architects

• Human Resources and Training Personnel

• Legal or Policy Representatives

• Internal or External Auditors

Each member brings a unique perspective to the review, ensuring a holistic assessment of your CMMC preparedness.

3. Review and Update Documentation

Up-to-date documentation is a cornerstone of CMMC compliance. Evaluate and refresh the following artifacts:

• System Security Plan (SSP): Ensure it reflects current configurations, software inventories, network diagrams, and data flow mappings.

• Policies and Procedures: Confirm that documents are current, reviewed regularly, and align with operational practices.

• Risk Assessments: Update to reflect recent changes in threats, business processes, or systems.

• Training Records: Verify that all employees have completed necessary training, particularly regarding CUI handling.

• Incident Logs: Review logs to ensure all security incidents have been documented, analyzed, and remediated.

4. Conduct Control Walkthroughs

Conduct detailed walkthroughs of the controls within each CMMC domain. Focus particularly on those with higher risk exposure, such as:

• Access Control (AC): Review user provisioning, de-provisioning, privilege assignments, and multi-factor authentication implementations.

• Audit and Accountability (AU): Assess logging mechanisms, audit log reviews, and alerting procedures.

• Configuration Management (CM): Examine baseline configurations, change control processes, and unauthorized change detection.

• Incident Response (IR): Test the incident response plan through simulations or tabletop exercises.

• Media Protection (MP): Evaluate media sanitization, transport controls, and encryption protocols.

Use a structured approach for each control:

• Describe the control

• Demonstrate its implementation

• Present supporting evidence

• Rate its maturity level

5. Score and Prioritize Findings

After completing walkthroughs, compile the results into a findings matrix. Score each control based on implementation maturity and supporting evidence.

Highlight areas with partial or non-existent implementation. Identify high-risk deficiencies and prioritize remediation efforts. This scoring enables organizations to focus resources effectively and track improvement over time.

6. Develop a Remediation Roadmap

Turn findings into action by creating a remediation roadmap. Include:

• Priority Levels: Categorize issues as High, Medium, or Low based on impact.

• Assigned Owners: Designate responsible individuals or teams for each task.

• Due Dates: Establish realistic deadlines for remediation.

• Required Resources: Identify budget, tools, or personnel needed for completion.

• Dependencies: Document interdependencies that may affect timelines.

The roadmap should be integrated into project management or governance workflows to ensure ongoing visibility and accountability.

7. Integrate Results into Governance Structures

Ensure that readiness review outcomes inform organizational decision-making. Present findings and roadmaps to executive leadership, risk management committees, and IT steering groups.

Incorporate key metrics into performance dashboards:

• Percentage of fully implemented controls

• Number of high-risk gaps remaining

• Training completion rates

• Incident response effectiveness

This transparency drives executive engagement and aligns compliance efforts with business objectives.

8. Prepare for the Certification Audit

If your organization is nearing a formal CMMC assessment, use the mid-year review to:

• Finalize evidence packages, including SSPs, POA&Ms, policies, and control artifacts

• Schedule a mock audit to validate readiness

• Identify and resolve remaining documentation or implementation gaps

• Confirm availability of audit participants and their preparedness to respond to inquiries

This proactive approach builds confidence and minimizes surprises during the actual audit.

9. Promote a Culture of Compliance

Beyond technical controls, CMMC compliance requires cultural alignment. Use the review as an opportunity to:

• Reinforce the importance of cybersecurity throughout the organization

• Recognize teams and individuals contributing to compliance efforts

• Identify opportunities for additional training or awareness campaigns

• Solicit feedback on challenges and suggestions for improvement

A culture that values security and compliance fosters sustainable practices and enhances organizational resilience.

10. Plan for Continuous Improvement

Compliance is not a one-time event but an ongoing commitment. Conclude the review with a forward-looking plan:

• Schedule the next internal review or audit

• Update governance calendars to include compliance milestones

• Track performance metrics and adjust strategies as needed

• Stay informed of updates to CMMC requirements and best practices

By integrating continuous improvements into your compliance strategy, you ensure long-term success and adaptability.

A mid-year CMMC readiness review is a vital checkpoint on the road to certification. By assessing progress, addressing deficiencies, and reinforcing best practices, organizations can maintain momentum and achieve compliance with confidence.

Prescott specializes in helping organizations prepare for and maintain CMMC certification. From readiness assessments to mock audits and remediation planning, our experts deliver tailored support at every stage of the compliance journey.

Contact Prescott today to schedule your CMMC readiness review:
https://www.prescott.us/contact-us