As organizations across the Defense Industrial Base (DIB) work toward CMMC certification, many struggle to keep compliance programs current without relying on tedious manual tracking and spreadsheets. 

MRIGlobal — a scientific research organization supporting U.S. Government defense and national security missions — faced similar challenges. While the organization could meet requirements, its existing approach made it harder to maintain visibility and confidence as expectations increased. 

That changed after adopting ASCERA. Time spent managing scattered documentation was reduced, and the team could focus more directly on control implementation and assessment readiness. 

This interview highlights how ASCERA’s centralized Cyber GRC platform simplified MRIGlobal’s CMMC efforts through structured evidence management, continuous controls monitoring (ConMon), enhanced visibility, and more. 

Background Overview 

What types of contracts or work does your organization handle within the Defense Industrial Base (DIB)?

MRIGlobal operates within the Defense Industrial Base primarily as a scientific research, development, test, and evaluation (RDT&E) organization supporting U.S. Government defense and national security missions.

Our work is largely focused on chemical, biological, radiological, nuclear, and explosive (CBRNE) defense, including threat detection, diagnostics, biosurveillance, and warfighter protection technologies. We support the Department of Defense and related agencies through applied research, independent laboratory testing, system evaluation, and advanced analytics that inform operational and acquisition decisions.

MRIGlobal also designs and supports deployable and mobile laboratory capabilities, provides unbiased scientific assessments, and executes mission-aligned research under established federal contract vehicles. Overall, our role in the DIB is that of a trusted, non-profit scientific partner delivering objective, high-consequence technical solutions in support of defense readiness and national security.

Before ASCERA, how were you managing your CMMC or cybersecurity compliance requirements?

Before ASCERA, our CMMC and broader cybersecurity compliance efforts were managed through a combination of internally developed processes, policy documents, spreadsheets, and shared repositories. We relied heavily on manual control tracking, narrative documentation, and point-in-time evidence collection to support assessments and audits.

While this approach allowed us to remain compliant, it required significant coordination and discipline to maintain consistency, version control, and visibility across control families, enclaves, and stakeholders. Preparing for CMMC Level 2 amplified those challenges, as the need for structured traceability, repeatability, and ongoing readiness increased substantially. We recognized that sustaining compliance at scale would require moving beyond ad-hoc tools toward a more centralized, purpose-built platform.

Challenges Before ASCERA 

What challenges or pain points were you facing prior to using ASCERA? 

Prior to using ASCERA, our primary challenges centered around scale, visibility, and sustainability. Managing CMMC-aligned controls across multiple environments required extensive manual effort to track implementation status, maintain supporting evidence, and ensure documentation remained current and consistent. In other words, spreadsheet nightmares!

Evidence collection and validation were largely point-in-time activities, which made it difficult to maintain continuous awareness of control effectiveness. Additionally, mapping controls to policies, procedures, and technical artifacts required careful coordination and introduced risk around version control and traceability.

As we prepared for CMMC Level 2, it became clear that relying on spreadsheets and distributed documentation increased the operational burden on the team and limited our ability to quickly assess gaps, demonstrate maturity, or pivot as requirements evolved.

How were these challenges impacting your organization’s ability to stay compliant or prepare for CMMC certification?

These challenges didn’t prevent us from meeting requirements, but they did introduce inefficiencies and risk as we moved toward CMMC Level 2. A manual, point-in-time approach to compliance made it harder to quickly assess our readiness posture, prioritize remediation efforts, or confidently demonstrate consistency across control families.

As expectations around evidence quality, traceability, and repeatability increased, more time was spent validating documentation and reconciling artifacts rather than focusing on risk reduction and control improvement. Preparing for certification required significant effort to ensure accuracy and alignment, and it became clear that sustaining compliance over time would be increasingly resource-intensive without a centralized system to support continuous readiness.

The challenge wasn’t achieving compliance — it was sustaining confidence and readiness as the rigor of CMMC Level 2 increased.

Why You Chose ASCERA

What stood out to you about ASCERA compared to other solutions you evaluated?

What stood out about ASCERA was that it was clearly built with the right functionality at its core. The platform isn’t surface-level or cosmetic — it’s designed to directly support the intent of NIST 800-171 and the realities of maintaining compliance over time.

Rather than focusing on static, point-in-time assessments that begin to age the moment they’re completed, ASCERA’s Cyber GRC is structured around continuous visibility and control alignment. Each control is mapped in a way that supports ongoing validation, evidence traceability, and day-to-day operational use, which is exactly what CMMC Level 2 demands.

That depth and intentionality set ASCERA apart. It was evident that the platform was purpose-built to help organizations sustain compliance in real time, not just prepare for an audit.

Your Experience Using ASCERA

How has ASCERA helped you simplify or accelerate your CMMC compliance efforts?

ASCERA has simplified our CMMC compliance efforts by centralizing control management, documentation, and evidence into a single, structured Cyber GRC platform. Instead of coordinating across multiple tools and repositories, our team can quickly understand the status of each control, identify gaps, and see how policies, procedures, and technical evidence align.

From an acceleration standpoint, ASCERA reduces the time spent on manual tracking and reconciliation, allowing the team to focus on control implementation and risk reduction rather than administrative overhead. The platform enables us to move more efficiently from assessment to remediation, while maintaining confidence that documentation and evidence remain current and defensible.

Most importantly, ASCERA supports a continuous-readiness mindset. That shift has made preparation for CMMC Level 2 more predictable, repeatable, and sustainable over time.

ASCERA shifted us from managing compliance as an event to operating in a state of continuous readiness.

What specific features or capabilities have been the most valuable for your team? (e.g., Continuous Controls Monitoring (ConMon), POA&M tracking, automated evidence collection, policy mapping, reporting dashboard, etc.).

One of ASCERA’s most valuable features is its control matrix, which we often joke looks like a scientific periodic table of evidence. That visual structure makes it easy to understand the status of each NIST 800-171 control and easy to navigate about the platform, which is incredibly helpful for both day-to-day operations and assessment preparation.

ASCERA’s ability to catalog, identify, and manage evidence has also been a major strength. In some cases, the platform itself becomes part of the evidence simply by using it to support and document control implementation. Beyond that, the built-in evidence repository makes it easy to upload, organize, and maintain artifacts in a centralized and defensible way.

When it came time to submit our body of evidence to our C3PAO assessor, ASCERA’s custom export capability was a standout. The platform generated a structured export with evidence organized by control in a single package, which significantly streamlined the review process. In fact, our assessor specifically commented on how easy the body of evidence was to navigate.

How has ASCERA improved your visibility into compliance or risk posture?

ASCERA has significantly improved our visibility into compliance by providing a real-time, centralized view of control implementation, evidence status, and risk areas. Instead of relying on fragmented updates or manual rollups, we can quickly understand where we stand across NIST 800-171 control families at any given time through ConMon.

From a risk perspective, the platform allows us to identify gaps earlier, track remediation efforts through POA&Ms, and prioritize work based on impact and maturity. That level of visibility enables more informed decision-making and reduces uncertainty as we prepare for assessments.

Perhaps most importantly, ASCERA provides confidence. It allows us to move from reactive compliance management to proactive oversight, ensuring we maintain awareness of our posture rather than discovering issues late in the process.

Have you seen measurable results or improvements since implementing ASCERA? (Examples: reduced audit prep time, better documentation, faster gap closure, etc.).

Yes, we’ve seen clear and measurable improvements since implementing ASCERA, particularly in how efficiently we prepare for assessments and manage documentation. The time and effort required to validate evidence, confirm control alignment, and assess readiness has been significantly reduced.

Documentation quality and consistency have improved as well. With controls, policies, and evidence managed in a centralized platform, we spend less time reconciling artifacts and more time closing gaps and strengthening implementations.

ASCERA has reduced the overall friction associated with audit preparation. Readiness activities are more predictable, progress is easier to track, and the team can approach assessments with greater confidence and less last-minute effort.

Partnership and Support Experience

How would you describe your experience working with the ASCERA team?

Working with the ASCERA team has been an extremely positive experience. They bring a deep level of expertise around CUI and CMMC requirements, but they communicate it in a way that is patient, practical, and approachable. At times, the experience feels less like working with a vendor and more like collaborating with professors who genuinely want to teach, mentor, and see you succeed.

What’s been especially valuable is their continued engagement even after certification. The team remains invested in helping us maintain our posture, refine our processes, and ensure that compliance is sustained over time rather than treated as a one-time achievement. That ongoing partnership has reinforced confidence and kept us moving forward in the right direction.

How responsive or helpful has our customer support been when you’ve had questions or requests?

ASCERA’s customer support has been consistently responsive and highly effective. Questions are addressed promptly, and when deeper discussion is needed, the team takes the time to ensure we fully understand both the issue and the solution.

Support interactions feel collaborative rather than transactional, and the guidance provided is always grounded in a strong understanding of CMMC and CUI requirements. We’ve had zero concerns regarding responsiveness or helpfulness, which has made a meaningful difference throughout the compliance process.

How do you feel about the way ASCERA listens to customers and evolves the product?

ASCERA does an excellent job of actively listening to its customers and incorporating real-world feedback into the platform. We have recurring meetings with the ASCERA team where we can openly discuss user experience, functionality, and feature ideas, and those conversations routinely translate into meaningful product improvements.

That collaborative approach reinforces confidence that ASCERA is evolving alongside its customers and staying aligned with the needs of organizations operating within the Defense Industrial Base.

Impact and Outcomes

What impact has ASCERA had on your overall compliance process or confidence heading into CMMC certification?

ASCERA has fundamentally changed how we approach compliance and readiness. The evolution it has enabled in our compliance capabilities is comparable to the shift from pen and paper to modern, intelligent tooling. It’s not just faster, but categorically more effective.

Heading into CMMC certification, ASCERA provided a level of confidence that came from knowing our controls, evidence, and documentation were aligned, current, and defensible. Compliance stopped being something we prepared for and became something we actively maintained.

 

Looking Ahead

How do you see ASCERA fitting into your long-term compliance and cybersecurity strategy?

ASCERA is now a foundational component of our long-term compliance and cybersecurity strategy. We have leveled up our cybersecurity capabilities for the organization with ASCERA and it supports how we continuously manage, monitor, and mature our security posture over time.

From a strategic standpoint, ASCERA helps ensure that compliance scales with the organization and remains aligned with mission delivery. It allows us to move forward with confidence, knowing that our approach to CMMC and cybersecurity is durable, defensible, and built for the long term.

Can you share a short story or example of a time ASCERA made a big difference for your team? 

 

The technology itself is excellent, and ASCERA has proven to be one of the best investments I’ve made as Director of Cybersecurity at MRIGlobal. But for me and my team, that’s not the biggest difference.

 

The real difference has been the people behind the platform. The ASCERA team has consistently shown up as true partners — working alongside us, ensuring expectations were met, and helping us prepare thoroughly for our assessment. They were willing to comb through large volumes of evidence with us, validate that every detail was addressed, and take the time to walk through controls repeatedly until everything was clearly understood.

 

That level of commitment, patience, and shared ownership is what ultimately made the difference. It wasn’t just about using a tool — it was about having experienced professionals on our side who were genuinely invested in our success.

 

If you had to describe ASCERA in one sentence to another organization, what would you say? 

ASCERA turns CMMC compliance from a point-in-time exercise into a sustainable, continuously managed discipline.

Choosing the right CMMC software can be a challenge.

With compliance needs varying from one organization to the next, it’s easy to end up with a tool that’s either too lightweight or far more complex than you actually need. What works for a small organization preparing for CMMC, for instance, looks very different from what a larger DIB organization needs to maintain ongoing compliance with multiple security frameworks. 

ASCERA was built to scale with you. From organizations focused solely on CMMC to teams managing multiple frameworks and continuous monitoring, each ASCERA tier is designed to meet your organization where it’s at. 

To help you quickly identify the best fit, we put together a short quiz below. Answer a few questions about your organization, your environment, and your compliance goals, and we’ll point you to the ASCERA tier that aligns best with where you are today. 

Every GRC tool is now boasting AI functionality, but what exactly does this mean? And how can you evaluate one tool against another? 

This checklist gives you the key questions to ask when evaluating an AI tool for CMMC, so you can separate hype from software that will actually help you pass your C3PAO assessment. 

 

What is AI for CMMC? 

 

AI for CMMC can include any artificial intelligence feature that uses machine learning, natural language processing, or other automated intelligence to help with compliance tasks. 

One of the most common forms of AI for CMMC is a chat-based AI assistant that lets you type a question and get an instant answer. In a compliance context, that might mean asking for a plain-language explanation of a control, drafting an implementation statement, or clarifying which evidence to submit. 

But not all of these tools are created equal. Some are built on generic internet data and offer advice that’s outdated or inaccurate. Others don’t protect your CUI or integrate with your existing workflows, which can create new risks instead of reducing them. 

Keep reading for a closer look at how to evaluate AI tools for CMMC so you can reduce risk  and get the best return on your investment.

How to Evaluate an AI Tool for CMMC: 7 Key Factors

 

1. Data Security

 

Question to ask: How does the tool handle sensitive information? 

CMMC involves Controlled Unclassified Information (CUI), which must be protected at all times. Uploading parts of your SSP, logs, or evidence into a public AI model is a compliance risk in itself. A trustworthy tool will have a layered defense strategy, combining multiple security measures — such as access control, encryption, monitoring, and user training — to ensure the confidentiality, integrity, and availability of your data. The tool’s website should clearly spell out how your data is stored and processed.

Look for: 

• Assurances that data is never sent to public AI models or used for training 
• Encryption in transit and at rest 
• Hosting options that meet government security standards, like AWS GovCloud 
• Clear documentation on how prompts and outputs are handled

 

2. CMMC Training

 

Question to ask: Is the AI trained specifically on CMMC/NIST data? 

Generic AI tools are trained on broad internet data, which means they can pull in outdated or unverified information. They can also “hallucinate,” giving responses that sound plausible but aren’t accurate. A reliable CMMC AI tool should be built on expert-vetted content and clearly disclose its sources. 

Look for: 

• AI models trained specifically on CMMC and NIST 800-171 content 
• Disclosure of what sources the model draws from 
• Assurance that the materials used for training were chosen by CMMC experts 

3. Seamless Integration & Grounding

 

Question to ask: Does the AI tool integrate with your compliance data and ground into your environment?

An AI assistant isn’t useful if you have to constantly copy and paste material into a chat box or if it sits outside your everyday processes. The best tools allow you to workshop your own SSPs, POA&Ms, and implementation statements in real time — securely, without leaving your environment — while presenting an intuitive interface your team will actually want to use. 

An AI tool should be grounded in context. This means that when users ask a question, the tool uses techniques like Retrieval Augmented Generation (RAG) to automatically retrieve the relevant policies, parameters, and live operational data to return an answer tailored to the user’s environment. Here’s a deeper look at RAG in CMMC AI tools.

Look for: 

• Ability to interact directly with your existing compliance documentation 
• Secure, private processing of your data without exposing CUI externally 
• A user-friendly interface that minimizes training and speeds adoption 
• Integration with your existing compliance workflows  

4. Practical Value

 

 

Question to ask: What tasks does the AI actually make easier? 

AI should do more than rephrase definitions. The best tools help you move compliance work forward in concrete ways. 

Look for: 

• Drafting implementation statements 
• Identifying the right evidence for each control 
• Clarifying overlapping requirements 
• Breaking down complex controls into plain English 
• Highlighting gaps in existing documentation 

5. Vendor Credibility

 

Question to ask: Was the AI tool created by people who actually know CMMC? 

A vendor’s credibility matters. Tools built by general software teams with no CMMC experience can miss key requirements or misinterpret controls. Look for a product team with assessor credentials, a history of working with DoD contractors, and a proven track record in compliance. 

Look for: 

• Clear involvement of Certified CMMC Assessors or other recognized experts 
• Published credentials or partnerships that show domain expertise 
• References or case studies from organizations like yours 

6. Vendor Transparency

 

Question to ask: Does the vendor explain how their AI works? 

You don’t need a technical whitepaper, but you do need enough clarity to know the AI is built responsibly. Be cautious of vendors that market “black box” AI without explaining what sources it relies on. 

Look for: 

• Clear explanation of data sources (preferably assessor-vetted) 
• Details on where your data goes 
• Commitment that customer prompts won’t be used to train public models 

7. Ability to Try a Demo

 

Question to ask: Can you request a demo or trial? 

A reputable vendor should be confident enough to let you see the tool in action with your own use cases. Demos or trial access give you a chance to test features, see how your data is handled, and evaluate the user experience before committing. 

Look for: 

• The ability to book a live demo with product experts 
• Trial environments or sandbox access 
• Opportunities to test real CMMC scenarios 

Conclusion 

AI can be a game-changer for CMMC, but only if it’s secure, framework-aware, and built for assessment readiness. By asking the right questions up front, you can avoid the risks of public or generic AI tools and choose a platform that actually helps your team succeed. 

With ASCERA’s ComplyAI, you get an AI assistant designed exclusively for CMMC — secure by design, assessor-created, and practical for the real tasks contractors face every day. Try it for free to see if ComplyAI is right for you.

As organizations across the Defense Industrial Base (DIB) work toward CMMC certification, many face the same challenge: keeping their compliance programs accurate and up to date without drowning in spreadsheets and manual tracking.

One ASCERA customer — a cybersecurity and technology contractor supporting the Army, Air Force, SOCOM, and DIA — was no exception. The company faced a number of challenges that prevented them from confidently preparing for their C3PAO assessment.

After adopting ASCERA, however, the game changed. Less time was spent managing scattered documentation and outdated templates and instead actual progress toward control implementation was made.

This interview with the company’s CTO/CISO gives insight into how ASCERA’s automated evidence collection and continuous monitoring streamlined the company’s CMMC process.

Background Overview 

What types of contracts or work does your organization handle within the Defense Industrial Base (DIB)?

Our company operates in three value segments – Defense/Civilian, Health, and Clean Energy. Most of the DoD work is performed by the Defense/Civilian value segment but there is cross-over in the other two segments with DoD contracts.

Most of our DIB contracts are with the Army, Air Force, U.S. Special Operations Command (SOCOM), and Defense Intelligence Agency (DIA), where we provide unclassified and classified support specializing in enterprise IT modernization, cybersecurity, health IT, systems integration, and digital engineering. 

Before ASCERA, how were you managing your CMMC or cybersecurity compliance requirements?

I inherited an environment previously assessed against CMMC v1 by a consulting firm that produced an unrealistic SPRS score and relied on incomplete and inaccurate templates. We had separate ISO 27001 and CMMC documentation sets, an SSP lacking detail, and no continuous monitoring plan to sustain compliance. 

Challenges Before ASCERA 

What challenges or pain points were you facing prior to using ASCERA? 

Our challenges and pain points were:

• Having separate documentation sets for ISO and CMMC compliance
• Using a spreadsheet to track control compliance
• An outdated SSP template in Word format
• Cumbersome linking of evidence to assessment objectives
• No executable continuous monitoring plan.

Our asset list was not accurate, assets were not categorized in accordance with the CMMC scoping guide, we hadn’t performed a scoping exercise to find our CUI data flows and were attempting to achieve compliance at the enterprise level at CMMC Level 1 where CMMC Level 2 made more sense with a separate enclave for the limited personnel handling CUI. 

How were these challenges impacting your organization’s ability to stay compliant or prepare for CMMC certification?

The SSP was not defendable, I had no confidence in our SPRS score, and we had limited activities planned to demonstrate the ability to sustain compliance. 

Why You Chose ASCERA

What stood out to you about ASCERA compared to other solutions you evaluated?

Many things stood out. When I evaluate solutions, I cast a wide net and schedule meetings and demonstrations with several vendors and follow the decision analysis and resolution process we developed through our CMMI compliance program.

ASCERA stood out because it focuses on solving one problem exceptionally well—automated evidence collection and continuous control monitoring. Unlike most tools that only evaluate configuration data, ASCERA analyzes log data to validate whether controls are truly met. That cross-check gave me confidence that when I marked a control ‘met,’ ASCERA would confirm it with real data. 

Your Experience Using ASCERA

How has ASCERA helped you simplify or accelerate your CMMC compliance efforts?

I spent much less time formatting my SSP and organizing evidence.

As my approach to writing policy, plan, and procedure documentation was to answer control implementation questions, I was able to very easily cut/paste content from my documents into ASCERA. I found it very intuitive to manage evidence by dragging/dropping files into the repository and tag them to a control family, control(s), or assessment objective(s). And when my C3PAO assessment was complete, I simply exported all the evidence from ASCERA, ran the hashing scripts, and provided the results to the assessors. 

What specific features or capabilities have been the most valuable for your team? (e.g., Continuous Controls Monitoring, POA&M tracking, automated evidence collection, policy mapping, reporting dashboard, etc.).

Both the ACE and CCM were the most valuable as these functions were continuously running while I worked on control implementation and I could see things go from red to green as compliant configurations were put in place and reflected in the logs analyzed by ASCERA.  

How has ASCERA improved your visibility into compliance or risk posture?

We incorporated viewing of the ASCERA “periodic table of controls” (the compliance view) into our weekly information security management system technical review meetings. ASCERA has become an integral part of our continuous monitoring solution supporting the RA (Risk Assessment) and CA (Security Assessment) control families. 

Have you seen measurable results or improvements since implementing ASCERA? (Examples: reduced audit prep time, better documentation, faster gap closure, etc.).

Using ASCERA to manage our SSP, POA&Ms, and evidence management reduced our audit preparation time and simplified our engagement with the C3PAO. ASCERA allowed us to simply enter our control implementation statements, attach evidence, and create POA&M items without having to deal with templates, document management, or any formatting issues.

By providing our C3PAO access to ASCERA, it freed us from having to send any documents to them and ensured they were always seeing the most up-to-date information.  

Partnership and Support Experience

How would you describe your experience working with the ASCERA team?

The ASCERA team has been a pleasure to work with. Everyone on the ASCERA team has been enthusiastic, responsive, and very collaborative in responding to any issues we reported and incorporating our feedback and feature requests.

I really enjoyed and appreciated the deeper technical discussions with the development team and compliance experts around the interpretation of control and assessment objective requirements and how ACE and CCM are implemented to evaluate criteria to ensure we can confidently say they are met or not met. 

How responsive or helpful has our customer support been when you’ve had questions or requests?

The customer support team has been very responsive. We had very few issues, but when reported they were corrected quickly. We submitted several feature requests, most of which were received positively and promptly implemented. 

How do you feel about the way ASCERA listens to customers and evolves the product?

We had very productive weekly sessions with the ASCERA team which not only helped us fully realize the benefit of the product but also helped everyone more thoroughly understand CMMC requirements and compliant control implementations. For anyone new to CMMC or not well-versed in compliance, I recommend engagement with the ASCERA professional services team for guidance. 

Impact and Outcomes

What impact has ASCERA had on your overall compliance process or confidence heading into CMMC certification?

As our assessment date approached, seeing a full set of green controls and a 110 score in ASCERA gave me complete confidence that our integrated ISO 27001:2022 and CMMC Level 2 ISMS would pass—and, more importantly, that it was sustainable through continuous monitoring. 

 

Looking Ahead

How do you see ASCERA fitting into your long-term compliance and cybersecurity strategy?

Now that we have a CMMC Level 2 compliant enclave, I’d like to use ASCERA to perform a CMMC Level 1 self-assessment of our enterprise environment. And if ASCERA continues to evolve to support other compliance frameworks, I’d like to use it for our next ISO 27001 assessment and internal audits. 

What Is a POAM?

A Plan of Action and Milestones (POAM, or POA&M) is a formal corrective action plan created when a security requirement in NIST SP 800-171, NIST SP 800-53, or CMMC is not fully satisfied and cannot be marked as “Met.”

This should not be confused with an Organizational Plan of Action (OPA). OPAs track vulnerabilities or deficiencies that need remediation, but they do not change the status of a control from “Met” to “Not Met.” POAMs, on the other hand, specifically address non-met requirements.

The Purpose of a POAM

The goal of a POAM is to provide a structured and auditable approach to remediating compliance gaps. If a control is assessed as “Not Met,” an organization must:

• Document why it is not satisfied
• Identify corrective actions to resolve the deficiency
• Track progress toward remediation

Done well, this enables:

• Risk-informed decision-making
• Progress tracking for implementation
• Accountability across teams
• Transparency during audits and assessments

What Should a POAM Contain?

A well-structured POAM should provide a clear roadmap for addressing security gaps and serve as both a project management and accountability tool. At a minimum, it should include:

• Title – Clear enough to quickly reference the intent of the POAM
• Status – Open, Pending, In Progress, Delayed/Overdue, Missed, or Closed
• Assigned Controls/Objectives – The requirement(s) this POAM addresses
• Responsible Party/Owner – Who owns the control and tracks progress/completes the POAM
• Due Date – Realistic timeline for resolution (must be closed within 180 days of an official assessment unless otherwise noted)
• Weakness/Gap Description – A detailed explanation of the issue, not just the control ID
• Remediation Plan – Step-by-step actions to close the gap

Additional helpful, but not required, fields include:

• POAM ID for tracking
• Risk Assessment to gauge exposure
• Planned Milestones as checkpoints
• Resource Estimates for cost or staffing impact
• Impact notes describing how the change affects users or systems

When Should a POAM Be Created?

POAMs should be created any time a “Not Met” item is discovered outside of formal assessments, such as during self-assessments. This early documentation ensures proactive remediation and better readiness for any upcoming assessments.

In a formal CMMC assessment, once Conditional Status is awarded, all POAM items must be created and remediated within 180 days. Once closed, a POAM must be verified by a qualified assessor (C3PAO or DIBCAC, depending on level) before final certification is awarded.

How to Create a POAM

Building a POAM is straightforward if you follow the framework:

• Identify the “Not Met” control or objective.
• Verify related controls/objectives and group them if needed.
• Create a POAM ID and title that captures the purpose.
• Assign a status (usually Open or Pending at creation).
• Add a Responsible Party and Due Date (within 180 days).
• Write a detailed gap description.
• Develop the remediation plan with detailed steps to close the gap.

The more detail you provide, the easier it will be for assigned personnel to execute and for assessors to verify progress.

Why Managing POAMs Is Hard

For many organizations, POAMs live in scattered spreadsheets or Word docs. Ownership isn’t clear, milestones get missed, and progress tracking is minimal. By the time an assessor looks at your documentation, it can appear as if nothing has moved forward.

This kind of manual tracking creates unnecessary risk and can derail certification.

How CUIComply Simplifies POAM Management

CUIComply eliminates the chaos by centralizing all POAMs in one platform and tying them directly to CMMC requirements. Within CUIComply, you can:

• Link POAMs to specific NIST 800-171 controls
• Assign tasks and track ownership across your team
• Upload evidence to show remediation progress
• Provide real-time visibility to leadership and assessors

Instead of wrestling with disconnected spreadsheets, you can demonstrate that your POAMs are structured and actively moving toward closure.

The Bottom Line

POAMs are powerful compliance management tools that provide accountability and transparency, helping your organization close gaps and build toward certification.

With CUIComply, POAMs become part of a seamless compliance workflow, ensuring that remediation is tracked, validated, and completed on time.

 

If you’re working toward CMMC (Cybersecurity Maturity Model Certification), you already know that evidence is the backbone of a successful assessment.   

Unfortunately, many organizations underestimate this part of the process. They scramble to pull evidence last minute, turning the process into a painful, time-consuming grind that pulls engineers off critical projects, forces them into repetitive admin work, and almost always leads to frustration on both the technical and compliance sides.

In this blog, we’ll break down everything you need to know about preparing evidence for CMMC so that you can prove your compliance without the last-minute chaos. 

Understanding CMMC Evidence Requirements 

At its core, evidence is the proof that your organization is meeting CMMC requirements. CMMC assessors expect clear, objective proof that each control is in place and tools are operating as intended. 

Sufficiency and Adequacy 

Assessors judge evidence on two criteria: 

• Sufficiency: Do you have enough evidence to prove the requirement is met? 
• Adequacy: Is the evidence relevant and accurate for the requirement in question? 

If your evidence isn’t both sufficient and adequate, the control will be marked as NOT MET. 

Why This Matters 

It isn’t enough to simply have lots of evidence or a few strong pieces — you need both to achieve a MET status. 

During an assessment, CMMC assessors rely on three validation methods: Examine, Interview, and Test. The more your evidence speaks for itself, the less probing they’ll need to do, and the smoother your assessment will go. 

Think of it like a court case. You wouldn’t want to defend yourself with vague claims; instead, you’d want hard facts that prove your case beyond a reasonable doubt. Evidence collection for CMMC works the same way. 

Types of CMMC Evidence  

Evidence for CMMC can take many forms. Here are the most common types: 

• Screenshots: Capture configurations or settings to show that requirements are in place at a given point in time. 
• Logs: Provide ongoing, timestamped proof that requirements are consistently being met. Logs help demonstrate not just if something happened, but when and how often. They can also demonstrate continuous compliance. 
• Documents: Policies, procedures, and System Security Plans show intent to abide by a requirement. They demonstrate that a process has been approved on the operational end to ensure compliance with a requirement. 
• Testimonials/Interviews: Personnel responsible for certain requirements may be interviewed by assessors to verify their role in maintaining compliance. 

The Three Assessor Methods 

All evidence must be strong enough to stand up to the three methods of validation: 

• Examine: To review/analyze evidence presented for compliance (e.g. reviewing logs, documents, screenshots, etc.) 
• Interview: To talk with individuals to validate compliance with a requirement (e.g. holding a discussion with a system administrator about a configuration presented) 
• Test: To perform the requirement’s function to see if it performs as claimed (e.g. demonstrating a mechanism for access control is in fact performing its access control duty) 

Pitfalls of Traditional Evidence Collection and Why Logs Are More Effective 

Historically, many contractors have relied on screenshots and manually compiled documents to prove compliance. While this may work in the short term, it comes with major drawbacks. 

Time-Consuming   

Chasing down screenshots, coordinating across teams, and emailing files back and forth eats up valuable time. IT and compliance teams end up buried in administrative tasks that detract from actual security work.  

Error-Prone  

Mistakes are easy to make when you’re juggling various folders, file versions, and manual entries. Trying to fix errors during an assessment creates stress and increases the risk of a failed control.  

Lack of Traceability  

Spreadsheets and static folders don’t offer the audit trail assessors need. It’s often unclear who last touched a file, when it was updated, or whether it’s still valid. Without a way to verify evidence history, assessors may view it as unreliable.  

Difficult to Present  

When evidence is scattered across email threads and siloed folders, building a clear, mapped compliance story becomes nearly impossible. This leads to last-minute scrambles, missing artifacts, and avoidable findings — any of which can put your certification (and DoD contracts) at risk.  

Logs, on the other hand, provide a more reliable and scalable solution. They create an objective digital trail that can be reviewed by assessors to demonstrate continuous compliance. Instead of pulling together evidence once a year before an audit, logs make it possible to show compliance at any moment. 

How to Modernize Evidence Collection with Logs 

The future of CMMC evidence collection is automation and log-based validation. While screenshots capture a single moment in time, logs tell the full story of what happened, when it happened, and who made it happen. That traceability is what makes logs so valuable to assessors. 

How Logs Work 

At a technical level, logs are machine-generated records of system activity. They capture events in real time and store them with important metadata like user IDs, timestamps, IP addresses, and system actions. Because they’re continuously generated, logs create a chain of custody that shows compliance is ongoing. 

For example: 

• Access logs can show every successful and failed login attempt, proving that only authorized users are accessing systems and that failed attempts are being monitored. 
• Patch management logs record when updates were applied, demonstrating that vulnerabilities are being remediated in a timely manner. 
• Audit logs track who made changes to configurations, providing accountability and evidence of proper change management. 
• Firewall and intrusion detection logs prove that monitoring mechanisms are in place and actively recording malicious attempts or suspicious traffic. 

These logs act as objective, timestamped proof. Instead of telling an assessor “we enforce multi-factor authentication,” you can show them a log of MFA challenges being applied across your user base. 

Moving to Automation 

All organizations have logs — the challenge is knowing how to collect them, correlate them with CMMC requirements, and present them in a way that makes sense to assessors. That’s where automation comes in. 

Automated evidence collection tools can: 

• Ingest logs from multiple systems without manual effort 
• Normalize and tag logs so they align directly with CMMC controls 
• Highlight gaps when expected logs are missing, which helps you remediate before the assessor points it out 
• Generate assessor-ready reports that tie each log directly to the requirement it supports. 

How ASCERA Helps 

This is exactly where ASCERA stands out. ASCERA automates the entire evidence collection process by continuously gathering logs, mapping them to CMMC controls, and storing them in an assessor-ready format. Instead of scrambling for screenshots, organizations can log in and immediately see where they stand. 

Automation with ASCERA ensures that evidence is: 

• Sufficient (enough to prove compliance) 
• Adequate (relevant and tied directly to the control) 
• Continuous (ready for validation at any point in time) 

In short: logs provide depth, automation makes them usable, and ASCERA makes them actionable. 

Conclusion 

Evidence collection is often the most overlooked part of CMMC preparation, but it’s also the most critical. Screenshots and static documents are no longer enough — logs and automation provide the clarity, traceability, and reliability assessors expect. 

By modernizing your approach, you can reduce stress at assessment time and build a culture of continuous compliance that benefits your organization long-term. 

For many organizations, the hardest part of CMMC isn’t implementing security controls — it’s figuring out what exactly the security controls are asking for. 

The language of NIST 800-171 can be dense and confusing, and organizations are often left guessing what’s required of them. This is why many turn to external consultants, but this is a costly investment that might not always be possible. 

Understanding NIST 800-171 without hiring costly consultants is possible, though, with GRC tools that have built-in guidance (the right kind) embedded into them. 

Understanding the Problem 

At first glance, CMMC controls might seem straightforward enough. 

For instance, “limit unsuccessful logon attempts.” Simple, right? 

But how strict does that limitation need to be? Is locking an account after 10 failed attempts enough? What if the system doesn’t technically “lock,” but delays access? Does that meet the requirement? What qualifies as evidence? Do you need a configuration setting, a policy document, or both? 

This lack of clarity, unfortunately, is the case for many of CMMC’s 110 controls and 320 objectives. Without clear direction, most organizations are forced to interpret requirements based on whatever context they can find. Sometimes that comes from previous experience, and sometimes from forums, outdated articles, or half-answered Reddit threads. 

And while consultants or internal staff who have assessor-level experience can help answer these questions, not every organization has those resources available. So then what happens? 

In most cases, CMMC turns into a guessing game. You don’t realize where you fall short until you’re already being assessed, which leads to a scramble to remediate findings and generate POA&Ms. This reactive approach introduces stress, delays, and risk — especially for companies with DoD contracts that can’t afford last-minute surprises. 

Finding Guidance Online 

You might think you can solve this with a quick Google search. But most online resources are high-level, outdated, or inconsistent. You’ll often find recycled summaries of NIST 800-171 that simply restate the control language without interpreting it. Other times, you’ll find one-off examples from community forums that don’t apply to your environment. 

There’s also no easy way to verify that the information is accurate. Guidance from a random blog post might sound good in theory, but if it doesn’t align with how certified assessors are trained to evaluate the control, it won’t help you during your actual assessment. 

The Solution: a GRC Tool with Built-in Guidance 

Governance, Risk, and Compliance (GRC) tools are typically used to manage cybersecurity frameworks like CMMC. They help you centralize documentation, track control implementation, and collect evidence. But what if a GRC tool could also walk you through every control with the same level of detail you’d expect from a consultant? 

That’s exactly what ASCERA is designed to do. 

For each of the 110 NIST 800-171 controls, ASCERA provides a detailed walkthrough — created by Certified CMMC Assessors — that includes: 

• A breakdown of the overall meaning and intent of the control 
• Insights into how assessors interpret the control 
• A list of implementation examples of ways to meet the control  
• Specific evidence/artifacts to prepare for assessors 
• Connections to related or overlapping controls 

Unlike most resources out there, ASCERA’s guidance isn’t just repackaged NIST language. Instead, it’s real-world guidance from assessors who have evaluated dozens of environments and know what separates a passing implementation from a failing one. 

An additional advantage to CUIComply’s built-in guidance is that it’s embedded directly into your workflow on the platform, so your team doesn’t have to leave the tool or search externally for answers. 

And because it’s baked into the workflow, it supports consistency across the organization. You don’t have to rely on tribal knowledge or try to keep track of one-off answers someone found in a Slack thread six months ago. 

Why it Matters 

ASCERA’s built-in guidance cuts through the gray area of CMMC. 

With a step-by-step walkthrough for every control, ASCERA enables you to spend less time guessing and more time making real progress. Whether your team lacks internal expertise or simply wants clearer answers, ASCERA helps level the playing field by putting expert support directly at your fingertips.  

Here are some of the ways organizations benefit from ASCERA’s guidance: 

• Spend less time guessing and more time executing  
• Avoid over- or under-interpreting the requirements  
• Prepare faster and with more confidence  
• Build shared understanding across technical and non-technical teams 

What the Guidance Looks Like 

Here’s an example of what you can expect for control CM.L2-3.4.1. Through a video tutorial as well as written breakdown, you’ll learn how assessors interpret the control, how to implement it in your environment, what evidence you need to collect, and more. 

Get Started 

If you’re tired of guessing what controls mean or wondering whether your approach is satisfactory, it’s time to get support. Try ASCERA for free to see how the platform and its built-in guidance works. 

\For Defense Industrial Base (DIB) organizations preparing for CMMC, AI offers several possibilities: faster answers, streamlined documentation, and reduced...