You could be doing everything right. Keeping your systems patched, reviewing logs, training your team—but still fail a CMMC assessment.
Why?
Because if you can’t prove it, it doesn’t count.
It’s fitting that this year’s CEIC West was held in Las Vegas because trying to pass a CMMC assessment without proper documentation is like bluffing at the poker table without the cards to back it up.
The best gamblers don’t rely on luck. They stack the odds in their favor. They know when to bet big, when to fold, and most importantly when they’re holding a strong hand.
In CMMC, your documentation is your hand.
It doesn’t need to be a royal flush—but it better be a full house. A clear policy, a solid procedure, and real evidence? That’s a strong play. It gives your assessor confidence, and it gives you control.
At CEIC West, one of the most eye-opening sessions was the mock CMMC assessment panel. Real assessors walked us through how they evaluate companies and what separates a clean, efficient assessment from a chaotic mess.
Their message was crystal clear:
“We’re not just here to read your policies. We want to see the receipts.”
What Assessors Are Actually Looking For
I’ll be honest. I was surprised by how straightforward the assessment process is, at least in principle.
That’s not to say it’s easy. It’s expensive, high-stakes, and yes, the inspection can feel a bit intimate. You’re showing strangers how your business really runs. But once you get past the nerves, the process itself is refreshingly logical.
If you’ve actually been doing what you say you do and you’ve interpreted the objectives correctly, then proving it is more procedural than painful.
Assessors aren’t trying to trip you up. They’re not looking for excuses to fail you. They’re trying to confirm that your environment is defensible, your controls are real, and your documentation reflects reality.
They don’t just want to know what you do.
They want to see how, where, and when you do it.
In plain terms:
- Your policy says what should happen.
- Your procedure shows how it happens.
- Your evidence proves that it did happen.
And all three have to line up.
For example:
If your policy says you review logs weekly—but there are no dated log reviews, tickets, or screenshots to prove it—guess what? That control fails. Even if your team did the work.
That’s the disconnect that trips up a lot of good companies. It’s not that they’re not doing the work. It’s that they’re not proving it in the way an assessor needs to see.
Common Pitfalls That Derail Assessments
This part of the conversation reminded me of that old adage: “Know your audience.”
In this case, your audience is the CMMC assessor.
If you can put yourself in their shoes, if you can see your environment the way they will, you’ll spot weaknesses faster. You’ll also understand how to close gaps before they turn into assessment failures.
That’s my hope with this article: to give you the lens that assessors use. Because if you can proactively eliminate these common red flags, two good things happen. First, your organization actually becomes more compliant. And second, you’re able to walk into that assessment with confidence, knowing you can market and demonstrate your readiness.
Here are the pitfalls assessors say they see over and over:
- Old Policies: Documents last updated years ago, with no version control or sign-offs. They’re either out of date or clearly recycled.
- No Evidence Trail: Teams claim they perform backups, monitor logs, or review accounts—but can’t produce logs, screenshots, timestamps, or reports to prove it.
- Template Blindness: Relying on pre-built templates that sound good but don’t reflect your actual tools, workflows, or responsibilities.
- Overreliance on Verbal Explanations: Team members try to explain how things work without producing artifacts. In an assessment, talk isn’t enough. Proof is everything.
If your plan is to "just explain it in the assessment," you're gambling with your contract.
And like we said earlier, Vegas is the wrong place to bluff.
Give your assessor what they’re trained to look for: documentation that shows intent, execution, and results. Do that, and the process becomes less overwhelming, less expensive, and a whole lot smoother.
One Thing to Do This Week: Assessment-Proof a Control
Real progress doesn’t come from cramming for an assessment—it starts with taking an honest look at just one control.
And no, I’m not talking about the kind of “self-assessment” that happens when you’re rushing to complete your SPRS score and just need to get it submitted. I mean taking one control. Just one — and really sitting with it.
Start small. Don’t try to eat the whole elephant. Pick a control that you’re already confident about, or one that feels manageable. Then walk it through like an assessor would.
Ask yourself:
- Do we have a clear, current policy that describes this control?
- Do we have a documented procedure that shows how we implement it?
- Can we pull up evidence—screenshots, logs, ticket history, change records—from the last 30 to 90 days to prove it?
If any part of that chain is missing or unclear, congratulations. You just found an opportunity to get better.
This isn’t about passing a test. It’s about building operational discipline that earns trust and wins contracts. And the best way to do that? Start now. Start small. Start with one control.
By this time next week, you’ll already be more prepared than most.
Bottom Line
We started this article with a poker analogy, and it fits. But here’s the truth:
Your odds of passing a CMMC assessment are way better than winning at cards.
Why? Because unlike a poker game, the deck isn’t stacked against you.
You’ve already been given the rules. The framework is laid out in black and white. The CAP tells you how you’ll be assessed, and the controls are spelled out in NIST SP 800-171. You’re not guessing, you’re following a recipe.
Yes, CMMC is expensive. Yes, it is complex.
But for those of us who like to count our blessings, here’s one:
At least you know the mandate.
Do what the framework asks. Align your policies, procedures, and proof. And you’ll walk into that assessment holding a strong hand.
You don’t need to be perfect.
But you do need to be consistent and defensible.
In a CMMC assessment, confidence doesn’t come from what you say.
It comes from what you can show.
So the next time you think, “We’re probably good,” ask yourself:
Could I prove it to an assessor, the person who decides whether we pass or fail, using only what’s documented and verifiable?
Because when it comes to CMMC, documentation isn’t optional— it’s the only hand that wins.
