The Card Catalog: Why Your System Security Plan (SSP) Is the Key to CMMC Success
Picture walking into an old library. You need a specific book, but there are thousands of volumes spread across multiple floors.
Without the card catalog, you’d spend hours — maybe days — searching.
Now imagine a CMMC assessor walking into your organization without a properly structured system security plan (SSP). The result? A lengthy, painful assessment that could have been avoided.
Your SSP isn’t just another compliance document gathering dust on a shelf. It’s the card catalog for your entire security program — and according to industry experts, it’s the single most critical factor determining whether your CMMC assessment succeeds or fails.
What an Assessor Really Wants To See
During a recent DataSure24 webinar, Lead Assessor Mike Turpin revealed a fundamental truth about CMMC assessments: “Point my eyes where you want them to go.”
This simple statement contains profound wisdom. Assessors aren’t looking to fail organizations. They’re not hunting for problems or trying to make your life difficult. They’re following a structured process with 320 assessment objectives for CMMC Level 2 — and they need your help to navigate efficiently through your evidence.
As Mark Musone, DataSure24’s CTO, explains, “As an assessor, I go to that SSP first and foremost, not necessarily finding the answer… but I’m reading the SSP to give me the guidance of where to look for evidence so I can mark it as met.”
The difference between a smooth assessment and a disaster often comes down to how well your SSP functions as that navigational tool.
When assessors can quickly locate the evidence they need, they spend more time analyzing your actual security controls and less time playing detective.
Common SSP Failures That Doom Assessments
The statistics are sobering: Approximately 40%-45% of CMMC assessments don’t even make it past phase one. Another 25% fail during the actual assessment. Many of these failures trace directly back to SSP problems.
Being Too Generic
The most common mistake? SSPs that simply regurgitate CMMC requirements without explaining how the organization actually meets them.
“I have seen more often than I want to admit organizations with policies that simply regurgitate the requirement,” Turpin notes.
Presenting a PowerPoint Instead of a Real Plan
One assessor shared a cringe-worthy example: “I had someone come to my desk not long ago and give me what was literally a 20-slide PowerPoint. And he said, ‘Here’s my SSP. This tells you about my entire environment.’”
A PowerPoint presentation isn’t an SSP. It lacks the detail, structure, and evidence mapping that assessors need to validate your compliance.
Failing To Link to Actual Evidence
Your SSP must connect directly to supporting documentation. If you claim employees must complete five requirements for system access, you’d better have evidence for all five —not just one. Assessors will ask for proof of everything you document.
Including Irrelevant or Outdated Content
Here’s a counterintuitive truth: Saying too much can be as damaging as saying too little.
Musone shared an example where an organization claimed no mobile devices were in scope, then spent two paragraphs describing their mobile device management program. “If you’re gonna say there’s nothing in scope, that’s all you need to say,” he emphasizes.
The “Don’t Make Me Dig” Principle
Turpin uses a powerful analogy: “The last thing you want during any kind of assessment is an assessor to start digging. You want to set it up very, very simply so that you direct that assessor’s eyes where you want them to go to see what you want them to see.”
Why? Because when assessors dig, they find things. Things you might not want them to find. Inconsistencies. Outdated procedures. Gaps you didn’t know existed.
Consider this practical example from the field: An SSP should tell assessors exactly where to find evidence for each control.
“Within the access control policy, AC level one 3.1.1 is covered on page seven, paragraph three, line seven through nine,” Turpin suggests. This level of precision transforms an eight-week assessment from an excavation project into a verification exercise.
The math is compelling. With roughly seven minutes per practice for assessment, do you want assessors spending six minutes hunting for evidence and one minute analyzing it?
Or would you prefer they spend one minute locating evidence and six minutes giving your controls the thorough review they deserve?
Building Your CMMC Success Foundation
Your SSP should be “a consolidation, iteration, and itemization of your entire security program,” according to Musone.
Everything in it should already exist somewhere else — user lists, network diagrams, policies, procedures. The SSP simply consolidates these elements into one cohesive document that tells your security story.
Here’s what makes an effective SSP:
- Clear Navigation: Like that library card catalog, it should point to exactly where evidence lives
- Comprehensive Coverage: Address all 320 assessment objectives, not just the 110 practices
- Appropriate Detail: Answer the requirement fully without overwhelming with irrelevant information
- Current and Accurate: Ensure documented controls match actual implementation
- Evidence Mapping: Link every claim to verifiable proof
Remember, you’re not being assessed on just 110 practices — you’re being assessed on 320 objectives. Organizations that prepare only at the practice level find themselves “woefully unprepared,” as the experts warn.
Version Control and Maintenance
An often-overlooked aspect of SSP management is proper version control. Your SSP isn’t a one-time document — it’s a living record that must evolve with your security program.
Implement a formal change management process that tracks every modification, who made it, and why. This discipline becomes critical during assessments when questions arise about control implementation timelines.
The External Provider Trap
Many organizations fall into what experts call the “external provider trap.” They assume that using a FedRAMP-certified cloud provider automatically satisfies their CMMC obligations.
The reality? You remain responsible for understanding and documenting the shared responsibility model. Your SSP must clearly delineate which controls your provider handles and — crucially — which ones remain your responsibility.
Consistency Across Environments
One of the most common assessment failures occurs when organizations document controls for only part of their environment.
If your SSP describes BitLocker encryption for Windows systems, what about your Linux machines?
If you’ve documented account lockout policies for Office 365, have you addressed on-premises systems? Assessors will examine every system in scope — your SSP must account for all of them.
Your Next Steps
The message from the field is clear: Your SSP makes or breaks your CMMC assessment. It’s not just another document — it’s your road map to certification success.
Don’t wait until an assessor arrives to discover your SSP isn’t up to standard. Take action now:
This comprehensive checklist helps you evaluate your current SSP against assessor expectations. You’ll discover:
- Critical elements your SSP might be missing
- Common pitfalls to avoid
- Best practices for evidence organization
- Tips for creating clear navigation paths
Ready to transform your SSP from a compliance burden into a strategic asset? DataSure24’s CMMC experts have guided hundreds of organizations through successful assessments.
We understand what assessors need to see — and more importantly, how to present it effectively.
Contact DataSure24 today to learn how our proven SSP optimization process can set you up for CMMC success. Because when it comes to certification, you don’t want to leave anything to chance.