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What CMMC 2.0 actually changes for the small business prime

By Mike DillardApril 8, 20267 min read

The framework is more practical than the original, but the operational implications are easy to miss until you are six months from a recompete.

CMMC 2.0 cleaned up most of what made the original framework expensive. The level structure is simpler, the requirements are explicitly aligned to NIST 800-171, and the assessment cadence is more proportionate to the risk.

What it did not change is the operational discipline required to maintain the controls between assessments. The most common mistake we see in small business primes is treating the third-party assessment as the goal. The control state on the day of the assessment is the goal. The third-party assessment is just the date you have to prove it.

Practically, this means three things. Continuous control monitoring needs to be running long before the assessment is scheduled. The evidence repository needs to be versioned and date-stamped, not assembled the week of. And the people who maintain the controls need to be on the contract with funded hours — not volunteered as overhead.

If you are inside six months of an assessment and any of those three things is unclear, that is the highest-leverage place to spend the next quarter.

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