Common Challenges in DoD Certification Compliance And How to Fix Them

Maintaining compliance with the U.S. Department of Defense (DoD) cybersecurity certification requirements is not optional it's a mandatory element of working with or within the DoD ecosystem. Whether under DoD 8570 or the updated DoD 8140 framework, all cybersecurity, IT, and information assurance professionals must hold the appropriate credentials for their job roles.

But real-world compliance isn’t always straightforward.

Organizations especially contractors and subcontractors frequently face challenges such as certification gaps, renewal delays, unclear job-role alignment, inconsistent documentation, workforce turnover, changing DoD frameworks, and costly training requirements. These issues not only threaten compliance they can halt contracts, trigger penalties, or even lead to loss of government business.

This comprehensive guide breaks down the most common challenges organizations face in maintaining DoD certification compliance and proven strategies to fix them quickly and effectively.

1. Misalignment Between Job Roles and Required DoD Certifications

The Challenge

Many organizations incorrectly assign certifications to roles. For example, employees performing IAT Level II tasks may only be certified at IAT Level I. Under DoD policy, this is noncompliant job roles must match exactly with certification level requirements.

Reasons this happens:

• Employees shift responsibilities without HR updates
• Contractors lack clear role definitions
• Leadership misunderstands DoD Work Role IDs
• Legacy roles still reflect old 8570 categories instead of updated 8140 taxonomy

The Fix

• Map each employee to a DoD Cyber Workforce Work Role (8140 Work Role ID)
• Use DoD’s NICE-based Cyber Workforce Framework (CWF) to determine required certifications
• Regularly audit job descriptions and update them as roles evolve
• Create a centralized workforce compliance matrix
• A simple internal matrix can prevent 80% of certification mismatches.

2. Certification Expiration and Renewal Failures

The Challenge

One of the most common problems is letting certifications expire, especially those requiring CEUs or annual fees.

This affects:

• CompTIA certifications (Security+, CySA+, CASP+)
• ISC2 (CISSP, CCSP)
• ISACA (CISM, CRISC)
• GIAC certifications

The impact is serious:

• Employees become noncompliant instantly
• They may be removed from DoD networks
• Contractors risk losing contract eligibility

The Fix

Implement an automated certification tracking system Use tools like:

• SAP Litmos
• Skillsoft
• DoD Workforce Qualification Tracking (WQT)
• Internal HRIS reminders

Set renewal alerts at 180, 90, and 30 days before expiration

Provide employees with pre-approved CEU resources:

• CompTIA CEU portal
• ISC2 courses
• Vendor trainings
• Industry conferences

Create a renewal reimbursement policy This ensures employees renew on time without personal financial delays.

3. High Costs of Certification & Training

The Challenge

DoD-approved certifications can be expensive. Costs include:

• Exam voucher fees
• Training courses
• Continuing education
• CEU maintenance fees
• Retake costs

Examples:

• CISSP: ~$749 exam + $125 annual fee
• Security+: ~$392
• CySA+: ~$392
• CASP+: ~$520
• GIAC certifications: $2,000–$8,000

For large contractor teams, costs multiply quickly.

The Fix

• Budget certification costs annually as part of contract overhead

• Use discounted DoD training partners

• Adopt internal training options to reduce costs

• Provide employees with retake support or “second-shot vouchers”

• Create a tiered certification roadmap Instead of sending every employee to high-level training, build a progression path:

• IAT I → A+, Network+

• IAT II → Security+

• IAT III → CySA+ / CASP+

• IAM I–III → CISM, CISSP

• IASAE roles → CISSP-ISSEP

This avoids unnecessary high-fee certifications.

4. Difficulty Navigating 8140 vs 8570 Requirements

The Challenge

Most organizations still struggle to understand the difference between the two frameworks:

• DoD 8570 used a category-based structure (IAT, IAM, etc.)
• DoD 8140 uses a role-based structure aligned to NICE

Many contractors still rely on 8570 charts even though DoD 8140 is now the governing (and more detailed) standard.

This causes:

• Incorrect certification assignments
• Confusion about which credentials count under the new system
• Compliance gaps during audits

The Fix

• Transition all workforce mapping to DoD 8140 DoD Cyber Workforce Framework (DCWF)
• Update internal compliance documentation
• Train HR and program managers on 8140 Work Roles (e.g., 411, 511, 612, 722)
• Stop using outdated 8570-only charts
• Use DoD’s official Cyber Workforce Qualification Viewer for accurate mapping.

5. Poor Documentation & Audit Readiness

The Challenge

Many companies discover compliance gaps during audits simply because documentation is incomplete. Common issues include:

• Missing copies of certificates
• Missing CEU transcripts
• Incorrect employee records
• Lack of training logs
• Outdated certification registry
• No proof of renewal

Even if employees are actually certified, missing documents count as noncompliance until verified.

The Fix

Maintain a centralized digital compliance folder for each employee:

• Certificates
• CEU reports
• Renewal receipts
• Training records
• Job-role mapping

Prepare a DoD audit-ready binder for each contract:

• Workforce matrix
• Role alignment documents
• Compliance attestations

Perform quarterly internal compliance audits

With strong documentation practices, most compliance issues disappear.

6. Workforce Turnover & Skill Gaps

The Challenge

Cybersecurity workforce turnover is high often 20–30% annually. When certified employees leave, compliance gaps appear instantly.

Challenges include:

• Vacant IAT/IAM roles
• Loss of experienced personnel who held multiple certifications
• Delays hiring replacements
• Onboarding employees without required credentials

The Fix

• Cross-train multiple employees for critical roles
• Build certification succession plans
• Provide certification bonuses to encourage retention
• Hire proactively and maintain a pipeline of cleared, certified professionals
• Use conditional hiring (“must obtain certification within 60 days”)

Turnover is unavoidable but noncompliance is not.

7. Employees Struggling to Pass Certification Exams

The Challenge

DoD-approved exams like CISSP, CySA+, CASP+, and GIAC can be difficult. Not all employees pass on the first attempt, delaying compliance.

Failure reasons:

• Insufficient study time
• Poor-quality training courses
• Language or testing anxiety
• Difficulty with adaptive exam formats
• Lack of hands-on labs

The Fix

• Provide structured training plans
• Use reputable DoD-approved training vendors
• Implement internal lab environments
• Give employees paid study hours each week
• Offer mentor support from certified senior staff
• Use second-shot vouchers to reduce retake costs

Better-prepared employees mean faster compliance.

8. Insufficient Leadership Awareness of Certification Requirements

The Challenge

A surprising number of compliance issues occur simply because:

• Leadership doesn’t fully understand DoD frameworks
• HR teams are unaware of job-role requirements
• Project managers don’t validate certification status
• Contractors rely on outdated guidance

This results in systemic compliance failures.

The Fix

• Create internal DoD certification training for leadership and HR
• Hold quarterly compliance briefings
• Document standardized onboarding and validation processes
• Require leadership to sign compliance acknowledgment forms

Compliance improves dramatically when leadership understands the stakes.

9. Delays in Access, Onboarding & System Authorization

The Challenge

Employees may be hired but unable to perform tasks because their certification isn’t yet approved. This leads to operational bottlenecks such as:

• Delays in network access
• Delays in system authorization
• Problems with contract deliverables
• Noncompliant access being assigned out of urgency

The Fix

• Require certification BEFORE granting privileged access
• Integrate certification verification into onboarding workflows
• Coordinate with the government lead or contracting officer early
• Use interim solutions with non-privileged roles when necessary

Early preparation prevents costly delays.

10. Failure to Monitor Ongoing DoD 8140 Updates

The Challenge

The DoD continuously updates:

• Approved certification lists
• Work role requirements
• CEU guidelines
• Qualification standards
• Reciprocity policies

Organizations relying on old information quickly fall out of compliance.

The Fix

• Assign a compliance officer to track DoD cyber workforce updates
• Subscribe to DoD CIO announcements
• Update internal policy annually
• Attend government training and industry conferences

Staying current ensures long-term compliance.

Conclusion

DoD certification compliance is complex but entirely manageable with the right structure, planning, and visibility. The most common challenges include:

• Role-certification mismatches
• Expired credentials
• High training costs
• Documentation failures
• Workforce turnover
• Knowledge gaps in leadership
• 8570 vs 8140 confusion

By applying the fixes outlined in this guide centralized tracking, proper role mapping, standardized training, leadership education, and internal auditing organizations can achieve continuous, reliable, audit-ready compliance across all contracts and work roles.