Without consistent, high-quality assessments, CMMC risks devolving into a procedural requirement rather than serving as a meaningful risk signal.
Advancing cybersecurity maturity in the defense industrial base relies on one principle: trust. While some organizations initially view CMMC as avoidable or unnecessary, experience has shown that it is neither. Over time, compliance becomes a practical requirement for protecting sensitive information and continuing to operate within the defense ecosystem. That trust must extend across the system — trust in contractors to safeguard controlled unclassified information (CUI) with robust guidelines, trust that certifications accurately reflect real security posture, and trust that the Defense Department can rely on assessment outcomes for mission and acquisition decisions.
That trust is central to Cybersecurity Maturity Model Certification 2.0 — and it depends on the integrity of the assessments that underpin certification. Without consistent, high-quality assessments, CMMC risks devolving into a procedural requirement rather than serving as a meaningful risk signal.
A recent DoD Office of Inspector General audit found the department did not consistently follow its procedures for authorizing Certified Third-Party Assessor Organizations (C3PAOs) to conduct CMMC Level 2 assessments. While the findings highlight process and oversight gaps, their implications extend beyond administration, directly affecting the credibility of CMMC as a cyber risk management tool.
CMMC is intended to be a risk signal
CMMC 2.0 was created to move beyond self-attestation and offer a more reliable indicator of cyber risk in the defense supply chain. This indicator is valuable only if assessment outcomes are consistent, defensible and reflect operational reality.
When assessment rigor varies, several risks emerge:
- Certification outcomes become uneven, diminishing their usefulness for decision-makers.
- Cyber risk assessments may be inaccurate, leading to poor acquisition and oversight decisions.
- Supply chain vulnerabilities may persist despite formal certification.
- Trust erodes between DoD, prime contractors and subcontractors.
As the force relies more on digital systems and distributed operations, these risks directly impact readiness and resilience.
Implications for DoD and the Joint Force
For government stakeholders, the audit underscores that CMMC certifications are inputs to broader cyber risk management, not guarantees. They should inform decisions, not substitute for judgment.
As the department enhances oversight and implements corrective actions, leaders should expect:
- Greater emphasis on assessment consistency and quality assurance.
- Increased scrutiny of how certification decisions are reached.
- Closer alignment between cyber maturity, acquisition confidence and mission readiness.
Assessment integrity, in this context, supports informed decision making rather than introducing uncertainty. This increased oversight by DoD places a corresponding imperative on defense contractors to ensure their security programs are not merely compliant on paper but robust in practice.
What defense contractors should take away from the audit
For defense contractors, the findings highlight the importance of building cybersecurity programs that withstand scrutiny beyond a single assessment event.
Organizations should prioritize:
- Operationalized controls, not documentation alone.
- Repeatable, well-governed processes that persist over time.
- Evidence that reflects day-to-day security practices.
- Continuous monitoring and internal validation between assessments.
As oversight matures, certifications that are not supported by durable practices may prove fragile during audits, recompetes or incident investigations.
Reinforcing trust as CMMC 2.0 scales
As CMMC 2.0 expands, the defense community can reinforce the framework’s purpose by providing credible assurance that sensitive defense information is protected by organizations that are genuinely prepared. CMMC is an operational discipline, not a checkbox exercise, and high-quality assessments reinforce this discipline by promoting accountability and consistency.
Trust remains the cornerstone of CMMC. However, trust must be earned through rigor, transparency and assessment integrity. Strengthening this foundation is not just a governance issue; it is mission critical.
Kevin Spease is president at ISSE Services.
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