5 CMMC Compliance Insights from a Successful  JSVA (110/110)

5 CMMC Compliance Insights from a Successful JSVA (110/110)

What does it take to achieve 110/110 in a CMMC JSVA? It’s not luck.

It requires hundreds (if not thousands) of hours of preparation, strategic thinking, careful documentation, and flawless execution.

Recently, I had the privilege of guiding a client to this milestone, revealing five key insights that separate CMMC compliance success from failure.

What is a JSVA?

The JSVA (Joint Surveillance Voluntary Assessment) is not just another audit—it’s a collaborative pre-assessment conducted by the Department of Defense’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) and a Certified Third-Party Assessment Organization (C3PAO).

It is a crucial trial run, helping DoD suppliers and vendors evaluate their readiness for full CMMC certification. It’s the moment when your preparation is truly tested, revealing what works—and what doesn’t—and whether every control requirement is “Met” or "Not Met."

If you’re ready to turn your CMMC compliance journey into a success story, here are five takeaways that can transform your approach and help you achieve the same outcome.

1. Don’t Go It Alone

CMMC compliance is complex—tackling it alone is like navigating a maze blindfolded. That’s why partnering with Certified CMMC Professional is a game-changer.

In the JSVA, understanding the 110 requirements wasn't enough; translating them into assessor-friendly language and demonstrating the right outcomes was also crucial.

The right partners can bridge communication gaps, turning your efforts into clear, assessable actions. In this recent JSVA, we found that having experienced CMMC professionals on board was crucial. Working together, we ensured that every control was accurately interpreted, documented, and explained in great detail, making confusion a non-issue.

Lesson: Build a team of experts who can simplify compliance, communicate clearly, and act as your guide. It’s the difference between confusion and a perfect score.

2. Say What You Do, Do What You Say

In compliance, consistency is king. Your System Security Plans (SSP), policies, and procedures must be more than just paperwork—they must accurately mirror what’s happening on the ground. During the recent JSVA, we encountered a familiar problem: minor discrepancies between documented processes in the SSP and actual practices.

These gaps can quickly turn “Met” controls into “Not Met” controls.

For example, one control specified weekly checks, but the logs showed monthly reviews. Auditors’ questions—like, "It says you check this weekly; looks like the log shows a monthly check?"—can quickly deflate progress.

By tightening the SSP to match actual actions and clarifying the intent of what was being described, we moved those controls back to “Met,” demonstrating compliance by integrating people, processes, and technology with the evidence to match.

Lesson: Your documentation should be a living, breathing reflection of your practices. Alignment isn’t just a technical requirement—it’s how you prove you’re serious about compliance. Check closely, and remember: say what you do, and do what you say.

3. Understand all the 'Wiring Diagrams'

Think of CMMC compliance as a series of “wiring diagrams.” These aren’t literal diagrams but represent the connections between processes, configurations, and keystrokes that secure Controlled Unclassified Information (CUI).

During the JSVA, understanding these connections was critical. While technical leads often know the systems inside out, they may need help explaining how everything fits together to an assessor.

This is why it's called an information system.

We worked closely with the Managed Service Provider (MSP) and the client to clearly articulate these connections, demonstrating how each element supported broader compliance goals and integrated with system performance and compliance posture.

Lesson: It’s not just about what you’re doing—it’s about how every piece connects to the bigger compliance picture. When assessors see the complete strategy, they understand how each control fits together to deliver the desired outcome - safe, secure CUI.

4. Right Focus, Right Thinking, Right Results

CMMC compliance isn’t a sprint—it’s a marathon requiring consistent effort, clear priorities, and strategic thinking. In the recent JSVA, success wasn’t the result of last-minute fixes or a technology solution; it was the product of over a year of focused preparation. This meant refining configurations, updating documentation, and conducting regular assessments.

The key to achieving 110/110 wasn’t working harder but working smarter. We prioritized high-impact areas, addressed gaps methodically, and aligned the team around common goals.

This disciplined, step-by-step approach turned complexity into clarity, setting the stage for a perfect score.

Lesson: CMMC compliance demands steady, strategic action. Keep your team focused, your thinking aligned, and your processes clear. Compliance isn’t static; it’s dynamic and continuous, requiring the right mindset to maintain momentum.

5. It’s Happening Now

The urgency of CMMC compliance is real. The tone and professionalism of the DIBCAC and C3PAO teams evidenced this. Their mission was clear: assess 110 controls and 320 objectives.

It wasn't friendly or adversarial but intense, fair, accurate, and very, very thorough!

With the final rule fast approaching, organizations can’t afford to wait. In the recent JSVA, our client’s proactive approach and commitment made all the difference—they weren’t just reacting to requirements but building a compliance culture.

By prioritizing compliance now, they secured certification confidence and built a more substantial reputation, trust, and a competitive edge.

Organizations that act today will be the ones leading the way tomorrow.

This shows up on the DoD acquisition side, too, when you get to the sport that 110 High level of confidence in meeting your DFARS requirements in their supplier system.

This makes it easy for the DoD to do business with you!

Lesson: Don’t wait. Don’t wait. Don’t wait. Embrace CMMC as a strategic opportunity, not just a regulatory hurdle. Those who act now will be prepared, credible, and ahead of the curve.

The Bottom Line

When the final results came in, the client's reaction during the outbrief said it all: “OMG!!!!!!"

Three letters, six exclamation points—it’s hard to say which was better to see!

But what also mattered was the sense of gratitude and commitment that followed. It wasn’t just about hitting a perfect score; it was about achieving a milestone reinforcing trust, resilience, and a culture of compliance.

The CEO, visibly proud during the outbrief call, knew it was more than a success—it was a turning point, and he articulated that much. We shall bid with confidence and pride!

CMMC is more than a checklist—it’s a strategic journey that transforms your organization from the inside out, and the right insights can make all the difference, whether you’re just getting started or fine-tuning your approach.

If you’d like to discuss any part of your CMMC journey and ensure you’re on the right path, let’s chat.

You can book a Free CMMC Strategic Review to help you identify gaps, create a clear plan, and work toward your own “OMG” moment. Together, we can and will secure the defense supply chain.

It’s happening.

Marcel Velica

Senior Security Program Manager | Leading Cybersecurity Initiatives | Driving Strategic Security Solutions | Cybersecurity Excellence | Cloud Security

4 个月

Michael Brooks CISSP, PMP, MBA Congrats on the achievement! What was the biggest challenge you faced while guiding the DoD supplier? I’d love to hear more about your insights!

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