Implementing a robust security program for Cybersecurity Maturity Model Certification (CMMC) Level 2 compliance can seem complex, but it is essential for organizations managing Controlled Unclassified Information (CUI). This is a high-priority consideration for companies who work with or are contractors for the Department of Defense (DoD). Following a phased approach ensures each step is strategically organized, making the journey to compliance smooth, structured, and sustainable. Below, we break down each phase of the security program implementation, detailing the purpose and key tasks involved to achieve a compliant and secure operational environment.
Phase 1: Assess
CMMC L2 Scoping Exercise
The first step in implementing a CMMC Level 2-compliant security program is to understand where CUI resides within your organization and how it flows. CUI encompasses sensitive data that requires controlled access, and this information might be handled by various people, systems, and devices within your network. The CMMC L2 Scoping Exercise identifies all assets that interact with CUI, establishing a clear scope for the assessment. This phase ends with the creation of an Assessment Scope document, which categorizes assets based on their interactions with CUI, laying the groundwork for a focused and accurate assessment.
CMMC L2 Assessment
Utilizing a Compliance Management Platform (CMP), we assess the organization’s current security posture against CMMC L2 standards. The CMP enables a streamlined approach to the entire security program lifecycle, including documentation, evidence collection, task management, and reporting. Through this assessment, we identify gaps and generate necessary documents such as the System Security Plan (SSP), the Plan of Action and Milestones (POA&M), and calculate the Supplier Performance Risk System (SPRS) score—crucial for demonstrating compliance with contractual obligations.
Phase 2: Plan
CMMC L2 Program Documentation
Once the assessment is complete, we move to the planning phase, where program documentation is drafted. During this phase, we work closely with your team to create a comprehensive set of policies, procedures, checklists, and monitoring practices tailored to meet CMMC Level 2 requirements. This documentation forms the backbone of your security program, setting a structured approach to compliance activities. Notably, you’ll need to license the documentation package from our preferred vendor, ensuring standardized and reliable documentation.
The objective is not only to fulfill compliance requirements but also to maintain ongoing evidence of your security practices. By establishing clear documentation, your organization gains a clear, actionable roadmap for maintaining compliance and tracking key security activities over time.
Phase 3: Build
CMMC L2 CUI Enclave
Building a secure environment for managing CUI is critical for compliance. Microsoft’s Cloud platform is leveraged to establish a secure enclave, designed specifically for handling sensitive information. The CUI Enclave consists of Microsoft 365 GCC (Government Community Cloud) for collaboration tools such as Exchange, SharePoint, Teams, and OneDrive. Additionally, Azure Government is employed to create a Virtual Desktop Environment that is securely partitioned.
We configure supplementary services such as Entra ID, Defender, Purview, Sentinel, and Intune, applying security policies that align with the documentation created in the planning phase. This secure enclave becomes the operational hub for all CUI activities, ensuring that sensitive data is protected at every access point.
Phase 4: Onboarding
Onboarding, Training, and Testing
As the technical foundation is built, the onboarding phase brings users into the secure CUI Enclave. We establish a Security Awareness Training program that includes risk-based, role-based, and insider threat awareness sessions to meet CMMC L2 requirements.
User Acceptance Testing (UAT) is also conducted, a critical step that validates the system’s functionality in real-world scenarios. This process confirms that the security controls are correctly implemented and capable of handling CUI securely. Through comprehensive testing, we ensure that the CUI Enclave is not only functional but ready for ongoing use in a compliant and secure manner.
Maintenance Checklists and Change Approval Board (CAB) Meetings
With the system operational, we establish a regular maintenance routine. The CMP assists in creating and managing recurring tasks tied to the upkeep of the CMMC L2 Security Program. These tasks include vulnerability report reviews, threat intelligence assessments, audit log evaluations, asset patching, and incident response testing, conducted on a structured weekly, monthly, quarterly, and annual cadence.
The Change Approval Board (CAB) meets during this phase to review any adjustments or updates to the security program. Through CAB meetings, we ensure that all changes are meticulously approved, documented, and executed in alignment with compliance standards. At this stage, the System Security Plan (SSP) is finalized, capturing all security practices in one unified document.
Phase 5: Manage
Ongoing Program Management
The final phase emphasizes the importance of sustained management to maintain CMMC L2 compliance. This includes conducting regular CAB meetings, reviewing any non-compliant systems, managing change requests, and monitoring privileged activities. A proactive approach to security control reviews ensures that all practices remain aligned with compliance requirements as regulations and threats evolve.
Cybersecurity Maintenance Process
Effective program management means implementing continuous reviews and updates. Tasks include ongoing vulnerability assessments, threat intelligence review, asset patching, and risk evaluations. Comprehensive management of documentation is also vital; we maintain a record of all activities to provide a detailed audit trail. User and device onboarding and offboarding are closely managed to ensure that only authorized users access CUI, and hardware/software inventories are consistently updated.
The Manage phase ensures that your security program remains agile, responsive, and aligned with compliance requirements. By fostering a culture of continuous improvement, we help organizations stay secure and compliant in a dynamic cybersecurity landscape.
Sounds Like a Plan
Implementing a CMMC Level 2-compliant security program requires a meticulous, phased approach. From assessing your current state and planning a structured response to building a secure environment and managing ongoing operations, each phase builds upon the last to create a cohesive, compliant, and sustainable security program. Through collaboration and strategic implementation, we make navigating the path to CMMC L2 compliance achievable and maintainable, empowering your organization to handle CUI securely and confidently.
