Risk Assessment (RA): Protecting Your Contracts by Understanding Your Weak Spots

The Trap That Almost Took Down a Growing Manufacturer

Two years ago, a small precision-machining shop in the Midwest, 35 employees, mostly aerospace contracts, hit what looked like a small IT hiccup. A single CNC engineer couldn’t open design files. Then another workstation locked up. Then the shared drive went dark.

At first, they blamed “one of those quirky updates.” But by the time they realized it was ransomware, it was too late.

Production stopped for three days. A delivery deadline was missed. The prime didn’t cancel their contract, but they issued a stern warning: validate your cybersecurity or lose the work.

After the dust settled, one gap stood out above everything else: They never performed a real risk assessment.

They assumed their IT guy “handling security” was enough. They assumed the biggest threats were exotic hackers – not the unpatched machine in the corner running a legacy OS controlling a vital mill.

In other words, they didn’t know what they didn’t know. And in the Defense Industrial Base (DIB), that’s not just dangerous… it’s disqualifying. Risk Assessment (RA) is about making sure this nightmare never becomes your story.

What Meeting the Objectives Might Look Like

CMMC Level 2 has three Risk Assessment practices:

• RA.L2-3.11.1 – Periodically assess risk to operations, assets, and individuals.
• RA.L2-3.11.2 – Scan for vulnerabilities and remediate them.
• RA.L2-3.11.3 – Remediate discovered vulnerabilities in a timely manner.

Here’s what auditors typically expect to see:

 Risk Assessment (RA.L2-3.11.1)

• A documented risk assessment method (even if simple).
• A list of identified risks and their impact on CUI, operations, people, and systems.
• A review cycle (annual is common).
• Evidence that decisions were made from the assessment (e.g., “We added MFA because our risk assessment showed credential compromise as a top risk”).
• Responsibilities assigned: who performs it, who signs off, who owns remediation.

Vulnerability Scanning (RA.L2-3.11.2)

• Internal + external scans performed on a regular schedule (quarterly is typical).
• Scans should cover workstations, servers, and cloud services where possible.
• Documentation showing which tools were used and output of results.

Vulnerability Remediation (RA.L2-3.11.3)

• A process or SOP describing how vulnerabilities are classified and prioritized.
• Evidence of patching, updates, or compensating controls.
• Tracking sheets or tickets showing remediation timelines.

In short: An assessor doesn’t want perfection. They want consistency, repeatability, and evidence that you know your risks and handle them wisely.

Why It Matters: How Risk Assessment Turns Uncertainty Into Predictable Operations

Risk Assessments are not a compliance exercise, they’re a business survival exercise.

• Protecting your DoD contracts. Prime contractors, DCMA, and DIBCAC assessors all expect a functioning RA process. If you cannot show clear risk identification and mitigation, your SPRS score collapses. Low score = risk to contract renewals.
• Preventing the surprise outages that kill production. The vast majority of cyber incidents in SMBs come from issues that were already known, already visible, and already fixable… had the company been scanning or assessing regularly. RA helps you catch problems before they shut down machines, accounts, or entire workflows.
• Making smarter budget decisions. When leaders don’t understand risk, cybersecurity spending feels like guesswork. When they do understand risk, the right investments become clear.
• Building customer trust. Every prime contractor wants a supply chain full of predictable, low-risk partners. A documented RA process signals maturity and dependability.
• Creating resilience, not just compliance. Risk Assessment is the glue between controls, processes, technology, and day-to-day operations. 

In short: It’s what turns cybersecurity into operational discipline – not “check-the-box” paperwork.

Where Most Companies Slip Up

Here are the pitfalls we see constantly in the DIB:

• Treating Risk Assessments as a one-time document. A risk assessment from two years ago is a relic. In cybersecurity, static equals broken.
• Using tools without interpretation. A scanner might tell you that CVE-2024-XYZ exists. But… is it exploitable in YOUR environment? Does it affect CUI? What happens if a system goes offline to patch it? Tools generate data. Risk Assessment translates that data into decisions.
• No clear owner. If “IT handles it,” that means nobody really owns it. Assessors want clear responsibility.
• Only scanning externally. Internal vulnerabilities are what ransomware actors use once they get in. Skipping internal scans is one of the biggest failures we see.
• No remediation tracking. Many companies scan… but cannot prove they fixed anything.
• Relying solely on managed service providers (MSPs). MSPs help but YOU hold liability for CMMC. Risk must be understood and approved by leadership.

How to Start Strong (and Grow Stronger)

Here’s a two-tiered approach: a “Starting Point” for compliance, and then the NEX Level enhancements to build real resilience and business advantage. 

A Starting Point: The Minimum to Meet Compliance

These are practical actions you can implement relatively quickly to satisfy the assessment objectives for RA. These five steps are enough to pass most assessments.

1. Perform a simple annual risk assessment. You identify the biggest threats to your environment, document how each one could affect the confidentiality of your CUI, assign someone responsible for addressing it, and organize the risks so the most important issues rise to the top.
2. Run quarterly vulnerability scans, both external and internal, and use the results to drive your patching cycles. The goal isn’t to collect reports; it’s to make sure every finding turns into an action that actually strengthens your environment.
3. Create a vulnerability remediation SOP. It explains how your team evaluates risks, categorizes them by severity, and sets clear timelines for fixing them. For example, 7 days for critical issues and 30 for high-severity items. This standard creates consistency and removes guesswork.
4. Keep evidence. Tickets, logs, meeting notes, emails, and scan reports become your audit trail – simple, organized documentation that proves what work was done and when.
5. Review risks at least annually. Review risks at least once a year – updating the assessment whenever new systems come online, contracts change, incidents occur, or operations shift. This ensures your risk picture stays aligned with reality instead of becoming a one-and-done document.

The NEX Level: Operational Maturity

Once you’ve covered the basics, here are advanced practices you can turn into competitive advantage… not just compliance. 

• Risk register integrated into decision-making. That starts with treating the risk register as a core decision-making tool, not an afterthought. When security risks are evaluated alongside budget, scheduling, procurement, and operational planning, leaders can make choices with a full view of organizational impact.
• Monthly vulnerability cadence. A monthly vulnerability cadence keeps risk manageable by shrinking the window between scans and reducing the likelihood of major surprises. But frequency alone isn’t enough; scoring must reflect the business, not just the technology. Downtime costs, safety implications, contractual obligations, and customer disruption should all factor into how vulnerabilities are prioritized.
• Business impact scoring should go beyond technical severity. Instead of relying solely on CVSS numbers, organizations should evaluate how a vulnerability would affect downtime, safety, contractual commitments, and the customer experience. This broader lens ensures that remediation priorities align with real operational risk rather than abstract technical scores.
• Threat-informed risk assessments. These add realism to the process by grounding decisions in how attackers actually operate. Using real-world techniques from frameworks like MITRE ATT&CK or current CISA advisories helps teams map out plausible exploitation paths instead of guessing where threats might emerge. This approach produces assessments that reflect genuine adversary behavior.
• Automate patching where possible. Wherever possible, routine updates, especially for cloud systems and user workstations, should be handled automatically. Automation reduces human error, speeds up remediation, and eliminates many of the delays that attackers rely on.
• Quarterly leadership risk briefings ensure that executives remain engaged without getting lost in technical detail. CEOs and senior leaders don’t need CVE identifiers or scan outputs they need clarity on business impact, potential operational disruption, and whether risk is moving in the right direction. Framing security in business terms keeps leadership aligned and supportive.
• Tie vulnerabilities to asset criticality. This brings necessary context to remediation decisions. Not all systems matter equally; patching a test workstation carries nowhere near the same urgency as patching the ERP server that keeps the business running. By weighing vulnerabilities against the importance of the affected asset, organizations focus their limited time and resources where they matter most.

NEX Level practices reduce downtime, audit stress, incident cost, and the chaos factor that crushes small teams.

The Weather Radar Lesson

A risk assessment is your weather radar. Pilots don’t fly cross-country without continually checking for storms. They don’t say, “Well, we looked at the weather last year – should be fine.”

Instead, they look for patterns, make judgments, reroute when needed, and stay ahead of danger. Risk Assessment in CMMC is the same.

It doesn’t prevent the storm, but it prevents you from flying into it.

Takeaway: Risk Assessment is your early-warning system – ignore it, and turbulence becomes catastrophe.

Helpful Resources

Understanding and managing risk doesn’t require a security degree. But it does require good tools, practical frameworks, and a structured approach. Below are resources we curated specifically for SMBs

Framework & Standards

• DoD CMMC Resources – Official documentation from the DoD covering CMMC Model v2.0.
• NIST SP 800-171 Rev. 2 – Full text from NIST, the source standard that CMMC maps to.
• NIST SP 800-30 – Guide for Conducting Risk Assessments – The gold-standard playbook for building a risk assessment process.

Free Resources

• CISA Vulnerability Scanning Solutions – Provides external scanning and hygiene services for no cost.
• NIST RMF Quick Start Guide – Great overview for leadership on how risk fits into operations.
• CISA Known Exploited Vulnerabilities (KEV) Catalog – Critical for threat-informed risk prioritization.

Paid Resources

• Tenable Nessus – Industry-leading vulnerability scanner for internal environments.
• CYYNC – A centralized system to plan and track evidence collection, conduct and document self-assessments, manage POA&M items through remediation, and maintain a continuous audit trail.
• Rapid7 InsightVM– Stronger asset management and remediation tracking capabilities.

CyberNEX Resources

• CMMC Decoded: Risk Assessment Reference Sheet – A concise one-page guide for defense contractors that outlines the RA control family, explains why it matters, highlights examples of evidence auditors might expect, provides quick-win actions to get started, and includes links to available resources.
• CyberNEX Blog Archive – Explore all 14 CMMC control families with in-depth explainers, practical recommendations, and actionable insights tailored to defense contractors.

Take the NEXt Step

Compliance is never the finish line – it’s the foundation. The real advantage comes when your business uses CMMC practices to strengthen operations, protect revenue, and earn the trust of your partners and the DoD. Whether you’re trying to pass an assessment or build a truly resilient cybersecurity program, CyberNEX helps you move from “checking the box” to owning your security posture.

Our team has guided dozens of SMBs through CMMC readiness, helping them translate complex requirements into simple, actionable steps. We know where most businesses struggle, and we know how to make progress visible – fast.

👉 Get clarity on your RA gaps and a clear plan forward. Book a Discovery Session with our experts today.

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FAQs

1. What does CMMC Risk Assessment actually require? 
CMMC expects you to regularly identify, evaluate, and prioritize risks to the systems that store or handle CUI. In practice, that means performing a formal risk assessment, running vulnerability scans, reviewing the results, and deciding how you’ll address the issues you find. Assessors aren’t looking for perfection – just a repeatable, documented process that shows you understand your environment and make informed decisions about risk.

2. How often should we do vulnerability scans?
Quarterly scanning is generally accepted as the minimum for CMMC Level 2, but many companies choose to scan more frequently because threats change quickly. Monthly scanning strikes a good balance between effort and visibility. Whatever schedule you choose, the most important part is reviewing the results and remediating issues within a reasonable, documented timeframe.

3. Can my MSP handle the risk assessment for me?
Your MSP can support the process – running scans, providing reports, and helping with remediation – but they can’t own it. Risk decisions must come from your organization’s leadership because only you can determine the operational impact of a vulnerability. Assessors expect to see that your company participates in reviewing risks and approving decisions, even if an MSP provides technical support.

4. What counts as evidence for assessors?

Evidence should show that you perform risk assessments and act on the results. Common examples include:

• A risk register or risk assessment report
• Internal and external vulnerability scan results
• Records showing remediation activity
• Meeting notes or sign-offs confirming leadership review
  You don’t need specialized software—many SMBs use simple documents and organized folders to meet the requirement.

5. Do we need fancy tools?
No. Most SMBs pass CMMC using basic, affordable tools paired with a consistent process. A simple risk assessment template, a spreadsheet-based risk register, and a reliable vulnerability scanner are usually enough. Tools can help, but they only matter if your organization reviews the results and makes clear, documented decisions.