10 CMMC Documentation Best Practices for DoD Contractors
Best Practices Checklist
Manufacturing companies pursuing CMMC Level 2 certification face unique documentation challenges that standard IT approaches cannot address. The following best practices provide actionable steps that manufacturing organizations can immediately implement to improve their CMMC documentation quality and assessment success rates.
1. Conduct Manufacturing-Specific Gap Assessment First
Begin with a comprehensive gap analysis that addresses both IT and OT environments, focusing on network segmentation between production systems and corporate networks, supply chain vulnerabilities, and technical data protection gaps specific to manufacturing operations.
2. Prioritize High-Impact Controls Using the 60% Rule
Allocate 60% of initial documentation effort to Access Control (AC.L2-3.1.1), System & Communications Protection (SC.L2-3.13.1), and System and Information Integrity (SI.L2-3.14.1) controls, as these address the most common manufacturing assessment failures.
3. Implement Layered Documentation Validation
Use a three-tier validation approach: internal testing with production staff, peer review by manufacturing and IT teams, and external validation by CMMC experts, e.g., a registered provider organization (RPO) before formal assessment with a third party assessor organization (C3PAOs) to ensure 95%+ documentation accuracy.
4. Adopt a Hybrid Expertise Model
Combine internal manufacturing process knowledge with external CMMC expertise through structured phases: consultant-led assessment and planning, joint framework development, internal execution with oversight, and external pre-assessment validation.
5. Address OT/IT Integration Throughout Documentation
Ensure all documentation explicitly covers operational technology systems, network segmentation implementation, production continuity considerations, and the unique security challenges of converged manufacturing environments.
6. Establish Continuous Change Management Procedures
Create formal processes for updating documentation within 5 days of production system modifications, equipment upgrades, supply chain partner changes, and personnel modifications to maintain assessment readiness.
7. Use Manufacturing-Appropriate Documentation Tools
Select tools that support OT system integration, supply chain risk management, production impact assessment, and multi-facility documentation management rather than generic IT-focused solutions.
8. Implement Structured Evidence Collection
Gather comprehensive proof including configuration screenshots from both IT and OT systems, network diagrams showing segmentation, process workflows integrating security with production, and audit logs demonstrating control effectiveness in manufacturing environments.
9. Plan Realistic Manufacturing-Specific Timelines
Allocate 8-12 months for mid-size manufacturers, accounting for OT system complexity, production schedule constraints, vendor coordination requirements, and the 40% longer timeline manufacturing environments typically require compared to pure IT environments.
10. Maintain Assessment-Ready Documentation Standards
Ensure all documentation includes control implementation specificity to manufacturing processes, clear responsibility assignments including production personnel, measurable evidence with timestamps, and regular quarterly validation testing that considers operational impact.
Learn More About CMMC Documentation
To learn more about CMMC documentation, including proven strategies, tools, templates, and timelines, visit: CMMC Documentation Best Practices Guide.
And to learn more about Kiteworks for CMMC compliance, be sure to check out Achieve CMMC Compliance With Complete Protection of CUI and FCI.