CMMC Remediation Roadmap: 30/60/90 Days After the Gap

Purpose

After status mapping and a gap process, ops needs a plan people can run on Monday morning.

This roadmap assumes:

• A status register exists
• High-weight open items are visible
• Leadership agrees not to sign fiction (FCA framing)

Prioritization formula (simple and good enough)

For each open/partial row:

Priority score ≈ weight (1/3/5) × residual risk (1–5) × dependency factor

Dependency factor examples:

• 3 = blocks many other controls (identity, boundary, logging foundation)
• 2 = normal
• 1 = isolated

Sort descending. Break ties toward identity, boundary, and evidence platforms.

RACI essentials

Role	Responsibility
Executive sponsor	Risk acceptance, signature gate, budget
Ops / compliance lead	Register integrity, cadence, reporting
Control owners	Implementation + evidence
MSP / cloud	Agreed technical controls only (documented)
Independent reviewer	Sample challenge before any SPRS affirmation

Use the shared-responsibility matrix for vendor rows.

30 / 60 / 90 day model

Days 0–30 — Stabilize and stop the bleeding

Theme	Actions
Scope	Freeze boundary; kill shadow IT CUI paths you can find
Identity	MFA for remote/privileged access plans in motion
Logging	Ensure you can collect what you will later prove
Register	100% of rows have status + owner
Signature	Explicit go/no-go: usually no if high-weight Not

Exit: Top 15 open items listed with owners and dates; no silent blanks.

Days 31–60 — High-weight burn-down

Theme	Actions
Tech	Close weight-5 / weight-3 technical gaps in priority order
Evidence	For each newly Satisfied, file evidence location
Policies	Draft/update family policies that match reality
MSP	Written confirmation of shared controls
POA&M	Open formal POA&M rows where rules allow

Exit: Material drop in weighted open points; evidence pack for closed items.

Days 61–90 — Document and decide

Theme	Actions
SSP	Narrative matches register (Is SSP CUI?)
POA&M	Living plan with milestones
Re-score	Only with challenged marks (scoring guide)
Sign-off	Can you sign this? checklist
Path	Self-assessment posture vs prepare for C3PAO later

Exit: Leadership brief: residual risk, score if any, and sustainment plan (cadence).

Weekly ops rhythm (during the 90 days)

1. 30-minute register standup (blockers only)
2. Evidence checklist for anything moved to Satisfied
3. Escalation of slipped weight-5 items to sponsor
4. No “status upgrades” without artifact location

Artifacts to maintain

Artifact	Owner	Tooling options
Status register	Ops lead	CSV template / Pack / GRC
POA&M	Ops + owners	Pack tracker / paid Readiness
Evidence index	Owners	Ticketing + secure file store
SSP draft	Author + reviewer	Pack SSP template
Risk decisions	Sponsor	Meeting notes

DIY vs help

Situation	Move
Team can execute	Pro Pack POA&M + SSP templates
Need prioritization challenge first	Defensibility Review
Need full 110 gap report	Gap Analysis
Need structured SSP/POA&M support	Readiness Package

Anti-patterns

• Closing easy weight-1 rows to “feel progress” while MFA is open
• Marking Satisfied from a vendor slide deck
• POA&M as a junk drawer for permanent gaps
• Re-scoring weekly to manage a dashboard for primes

Next

1. Sort your open register by weight × risk
2. Publish the 30/60/90 owners
3. Run weekly rhythm
4. Shift to program cadence so the 90-day heroics become boring operations