There is a misperception about Microsoft Office 365 government cloud that if you purchase GCC or GCC High, your organization is well on its way to CMMC compliance. Given the fact that the platform supports the controls and is FedRAMP authorized, it can be easy to assume that you are protected. That assumption, however, is incomplete and can be costly.
Microsoft 365 government cloud environments can provide an important foundation for protecting CUI when the appropriate environment is selected, properly configured, and operated within the organization’s defined security boundary. They include built-in capabilities for identity protection, threat detection, audit logging, and data governance that support NIST SP 800-171 implementation, but a FedRAMP authorized platform is infrastructure, not a complete compliance program.
What CMMC Level 2 requires
CMMC Level 2 is based on the 110 security requirements in NIST SP 800-171. Those requirements span technology, processes, people, and organizational practices. Microsoft Office 365 can support, and in some cases directly satisfy many of the technical requirements. However, the platform alone cannot perform the organizational processes, configuration decisions, documentation, or ongoing activities required for compliance.
Common Gaps Organizations Underestimate:
- Written policies and procedures: NIST SP 800-171 requires documented policies covering access control, incident response, configuration management, awareness and training, media protection, and more. Those documents have to be written, approved, maintained, and reflected in how your organization actually operates. An auditor will look for evidence of both the policies and the practices documented and followed.
- System Security Plan (SSP) and Plan of Action and Milestones (POAM): Your SSP documents the assessment scope, system boundary, and how the applicable security controls are implemented to meet NIST 800-171 requirements. A POAM documents noted deficiencies and the actions and milestones for remediation. POAMs are not a substitute for implementing required security practices.
- Continuous monitoring and audit log review: GCC and GCC High can generate extensive audit and security telemetry. Your organization still needs processes for reviewing relevant security events, responding to identified issues, and maintaining auditable evidence that those processes are being performed.
- Incident response planning: NIST SP 800-171 requires organizations to maintain a documented incident response plan, define roles and responsibilities, and demonstrate that the plan has been tested. Annual tabletop exercises are a common way to validate incident-response capabilities and produce supporting evidence.
- Access control management: Microsoft Entra (formerly Azure AD) gives you the tools to implement least-privilege access, multi-factor authentication, and conditional access policies. These tools must be correctly configured and managed in an ongoing manner. User provisioning and deprovisioning, role assignments, and privileged access governance are operational disciplines, not features you turn on once and forget.
- User training and awareness: Your workforce needs to understand how to handle CUI, recognize phishing attempts, and know what to do when something looks wrong. Role-based training, annual awareness programs, and records that demonstrate completion are all required. No license delivers this.
- Physical security: Physical protection requirements can apply to facilities and systems within the CMMC assessment scope. Organizations need appropriate controls for things such as physical access, visitor management, and protecting systems and media from unauthorized access.
DIBCAC Audits are happening now
DCMA is conducting DIBCAC audits now. Misrepresenting your cybersecurity posture can carry serious contractual and compliance consequences. A GCC or GCC High license on an invoice is not evidence of compliance. The organizations that are going to struggle most are those that treated licensing as the finish line. They bought the software, checked a box, and assumed the rest would follow. It doesn’t work that way. Join our upcoming DIBCAC Assessment: No Tricks, No Treats, Just the Facts webinar to understand what organizations need to know, where gaps commonly occur, and how to better prepare for an audit. Don’t wait until an auditor is asking for evidence to find out what’s missing.
What a genuine compliance program looks like
A credible path to CMMC Level 2 compliance starts with a gap assessment, which is an honest evaluation of where your organization stands against all 110 security requirements and 320 assessment objectives. From there, an organization’s journey continues with building the documentation, implementing the missing controls, establishing the ongoing operational practices, and producing the auditable evidence needed to support an assessment. Software is an important component of the larger program.
If your current compliance approach started with a license purchase rather than an assessment, it’s worth taking stock of where the gaps are before an assessor does it for you.
CyberSheath helps defense contractors build operational compliance programs. Our approach starts with a gap assessment and works from there. Contact us for a no-cost initial conversation.