Industry Solutions

CMMC Compliance for Solution Implementers

Solution Implementers (SIs)

SIs are the engine behind countless Department of War (Dow) programs but compliance with CMMC and export control regulations (ITAR/EAR) adds a new layer of urgency.

You’re working on integrations, support, development, and project management all of which touch Controlled Unclassified Information (CUI) and must now be protected under strict requirements.

All-In Solution (For CUI-Heavy Teams)

Bring your whole company into a compliant posture.

Microsoft Gov Cloud + full device coverage
Secures laptops, servers, network gear
Licensing, migration, support, and audit readiness

Ideal for: SIs with >15% of users in defense contracts

Enclave (Most Common for SIs)

Isolate your CUI workflows in a dedicated, compliant space.

Microsoft Gov Cloud + Virtual Desktops (VDI)
Supports secure tool access + mobile/remote users
Optional hybrid setup for on-prem printers, devices
Keeps your corporate environment out of scope

Ideal for: SIs with limited defense footprint or <15% CUI users

Frequently Asked Questions

Can Managed Service Providers (MSPs) inherit and manage all CMMC responsibilities for clients?

No. While MSPs can implement and operate many controls on behalf of clients, they cannot fully absorb the client’s compliance responsibilities. The DoW and assessors require that the client organization understands, verifies, and owns its control implementations, even those delivered by an MSP. Claims of 100% inheritance are rejected in assessments. Clients must still explain how controls work in their environment, maintain documentation, and assign internal stakeholders to each requirement.

Why are many MSPs withdrawing from the CMMC space?

MSPs are under increasing scrutiny from assessors. The expectation now is that service providers show deep knowledge of CMMC, provide documented evidence of how they support compliance, and operate under shared responsibility frameworks. Many MSPs are not prepared to meet these standards, particularly those relying on generalized IT support models. As a result, they are stepping away from CMMC clients, especially as enforcement ramps up. Clients should verify MSP capabilities carefully before signing contracts.

What should an Shared Responsibility Model (SRM include?

An effective SRM clearly maps each of the 110 NIST SP 800-171 controls to the responsible party: client, MSP, or jointly owned. It must align with the CMMC Assessment Process (CAP) and show who owns policy, implementation, and evidence. The SRM is one of the first documents assessors will ask for, and it must be tailored to the actual environment, not a generic template. Summit 7 includes a detailed SRM for every managed client to ensure audit readiness and clarity.

How do MSPs avoid creating false confidence in client compliance?

False confidence arises when MSPs overstate their inheritance or when clients assume all controls are covered just because systems are managed. To avoid this:

– Maintain a clear SRM with defined roles and responsibilities
– Provide clients with implementation evidence and system documentation
– Train client personnel to speak to control ownership during assessments
– Avoid “black box” service models where the client lacks visibility

Summit 7 prioritizes transparency, readiness coaching, and regular review sessions to ensure clients are truly prepared.

Can an MSP access multiple Government Community Cloud (GCC) High tenants under one account?

No. Microsoft GCC High does not support delegated admin or centralized partner access like commercial tenants do. MSPs must create named admin accounts in each individual tenant they manage. While cross-tenant collaboration is technically possible, it requires strict identity governance and role-based access. Summit 7 builds compliant access structures to support tenant-level separation while maintaining administrative efficiency.

What’s the risk of using FedRAMP-equivalent instead of FedRAMP-authorized platforms?

FedRAMP-equivalent environments must demonstrate 100% control implementation with no Plans of Action & Milestones (POA&Ms). That means exhaustive documentation and significantly higher assessment burdens. Many assessors prefer FedRAMP-authorized solutions like GCC High because they streamline the inheritance and verification process. Using FedRAMP-equivalent clouds without full documentation can lead to assessment delays or outright failure.

Can solution implementers also serve as Certified Third-Party Assessment Organizations (C3PAOs)?

No. There’s a strict conflict of interest rule in place. A company cannot both consult on and assess the same client for CMMC. C3PAOs must remain fully independent of implementation services. While implementers like Summit 7 can prepare clients for assessments, they must refer them to separate C3PAOs for certification. This separation ensures objectivity and reduces audit risk.

How do we ensure operational POAMs don’t disqualify a client’s assessment?

Operational POAMs, used internally to track improvements, are allowed before a formal assessment. However, once the C3PAO engagement begins, only limited 1-point deficiencies may remain open under an official POA&M, with strict rules:

– Must have at least an 88/110 SPRS score
– Cannot include 5-point or 3-point control gaps
– Must have documented remediation plans within 180 days

MSPs must help clients close out all major gaps and translate operational POAMs into clean, audit-ready documentation before assessments.

What technical steps must MSPs follow during a client’s GCC High migration?

GCC High migrations are complex and require:

– Reconfiguring mail profiles (automatable)
– Unenrolling/re-enrolling mobile devices
– Cleaning office caches
– Re-assigning or re-integrating user authentication
– Preserving mail, SharePoint, and Teams data
– Each user requires ~30–60 minutes of setup time. MSPs must plan for downtime, user training, and post-migration validation. Summit 7 performs end-to-end migration planning, including identity strategy, data preservation, and post-deployment tuning.

Can we support clients with partially compliant environments?

Yes, but only with caution. CMMC assessors require clear enclave boundaries. If parts of the client’s environment are not compliant, they must be demonstrably out of scope, with network segmentation, access controls, and data governance. MSPs must avoid commingling compliant and non-compliant systems, or they risk pulling the entire environment into scope. Summit 7 helps design tightly scoped enclaves that isolate CUI and allow for phased adoption of compliance controls across the business.

Case Study

NMR Consulting

Hear why NMR Consulting trusts Summit 7 as their MSP/MSSP for all things CMMC.

Headquartered in Huntsville, AL, NMR Consulting is a verified Service-Disabled Veteran-Owned Small Business (SDVOSB). NMR offers services across five business lines: information technology, program management, risk management, logistics, and security consulting.

Testimonials

When I tell big-name defense contractors we’re working with Summit 7, there’s a sigh of relief. That’s a huge advantage.

Matt GustafsonPresident, Clinkenbeard

I have been working with these guys for years now! With lots of hard work and timely communication they made sure they delivered the best to me. Highly recommended!

John DoeCompany Name

“This year, we’re going to pass $400 million. We’re making headway in regulated research. Microsoft and Summit 7 have been a significant contributor toward that growth.”

Reese DangerChief Research Security Officer

Summit 7 provides all the security capabilities we need on our behalf. We can sleep well at night knowing Summit 7’s MXDR service, Vigilance – built on the backbone of Microsoft Defender and Sentinel – has 24/7 monitoring and is a cost-effective model for us.

Reese DangerChief Research Security Officer

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CMMC Compliance for Solution Implementers

Choose Your Industry

Solution Implementers (SIs)

Top CMMC Pain Points for Solution Implementers

Mixed Environments

Subcontractor Risk

Large IT Teams

Low Revenue % from Defense