A Cybersecurity Maturity Model Certification (CMMC) assessment is a formal evaluation conducted by a Certified Third-Party Assessment Organization (C3PAO) to determine whether an organization meets the cybersecurity requirements of its targeted CMMC level. The primary focus is the protection of Controlled Unclassified Information (CUI), in alignment with the standards outlined in NIST SP 800-171.
The assessment reviews the organization’s implementation of required security controls, as well as supporting documentation such as the System Security Plan (SSP) and Plan of Action and Milestones (POA&M). Organizations must also provide structured evidence of how CUI is safeguarded across systems and processes. Preparing for a CMMC assessment involves a rigorous, multi-day on-site evaluation. This includes clearly defining the scope and boundaries of the IT environment where CUI is handled, submitting required documentation, and remediating any identified gaps within a specified timeframe to achieve certification.
What is a CMMC Assessment
The CMMC is a cybersecurity framework developed by the U.S. Department of Defense (DoD) to ensure that defense contractors and subcontractors adequately protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within their information systems.
CMMC aligns with existing cybersecurity standards—primarily NIST SP 800-171—and features a three-tiered certification model under CMMC 2.0, streamlining earlier versions. Organizations handling CUI must undergo third-party assessments to verify compliance, strengthen their security posture, and protect the Defense Industrial Base (DIB) from increasingly sophisticated cyber threats. The certification process involves evaluating the implementation of required security controls, supporting documentation, and organizational practices throughout the contract lifecycle.
What is Controlled Unclassified Information (CUI)
Controlled Unclassified Information (CUI) refers to sensitive but unclassified information created or possessed by the U.S. government that requires safeguarding or dissemination controls in accordance with applicable laws, regulations, and government-wide policies.
Unlike classified information, which is restricted to individuals with a strict “need to know,” CUI must still be protected to prevent unauthorized access that could harm national security or violate statutory requirements. The CUI Program, established under Executive Order 13556, standardizes how federal agencies and contractors handle, mark, safeguard, and disseminate such information. Examples of CUI include privacy data, attorney-client privileged information, and controlled technical information. The goal is to prevent sensitive data from being exposed or aggregated in ways that could be exploited by adversaries.
Defining CUI Boundary for CMMC Compliance
CUI boundary refer to the clearly defined perimeter within an organization’s IT environment where Controlled Unclassified Information is processed, stored, or transmitted. Establishing these boundaries is critical for CMMC compliance because it delineates the scope of systems and networks that require protection under the CMMC framework. The boundary includes all hardware, software, and network components that interact with CUI, ensuring that security controls such as firewalls, access controls, encryption, and monitoring are applied effectively.
Key Aspects of CUI Boundary
- External Boundaries: These are the outer limits of the organization’s IT environment, typically protected by corporate firewalls controlling inbound and outbound traffic. They include all points where CUI enters or exits the network, including remote user devices if they store or process CUI directly.
- Internal Boundaries: Within the organization, internal system boundaries segment different parts of the network or systems that handle CUI, such as application servers and databases. These boundaries are protected by internal firewalls or other controls to prevent unauthorized lateral movement and to enforce a zero-trust security posture.
- Documentation and Visualization: Defining boundaries requires thorough documentation, often in the form of network diagrams or data flow maps that show where CUI resides, how it moves through systems, and where security controls are implemented. This documentation is essential for the assessment process and ongoing compliance.
- Scope Determination: Organizations must identify all contracts requiring CUI handling and map CUI flows across their systems to accurately define the scope of their CMMC compliance efforts. Missing any CUI flows or systems within the boundary can jeopardize compliance.
How Elevate can Help
Navigating the complexities of CMMC compliance can be challenging, especially when it comes to accurately defining and securing the boundaries where Controlled Unclassified Information (CUI) is handled. Elevate provides expert guidance and hands-on support to help organizations clearly scope their IT environments, implement necessary security controls, and prepare thoroughly for a successful CMMC assessment. With deep knowledge of NIST SP 800-171 requirements and a practical, risk-based approach, Elevate ensures that your compliance efforts are focused, efficient, and aligned with both regulatory expectations and business objectives.