Can You Outsource 100% of Your CMMC Compliance? Here’s What You Need to Know

A common question we hear from defense contractors is: Can I outsource my entire compliance burden to a provider and make this compliance problem go away?  

It’s an understandable question. CMMC compliance is complex, and if you’re running a small or mid-sized business, you’ve got enough on your plate already. 

Unfortunately, the short answer is no. You can’t just write a check and be done with it. And if someone tells you otherwise, that’s a major red flag. 

Compliance is not like an insurance policy. 

A lot of executives think of compliance as something they can purchase like an insurance policy—pay the premium, get coverage, and forget about it. But cybersecurity compliance doesn’t work that way.  

Even the best Managed Service Providers (MSPs) and Managed Security Service Providers (MSSPs) can only handle part of the equation. There’s still a significant portion of compliance that requires internal oversight, organizational processes, and a culture of security. 

What an External Provider Can (and Can’t) Do for You 

A solid MSP/MSSP can help with a lot: 

1. Implementing security tools and controls 
2. Managing cloud environments and secure enclaves 
3. Monitoring systems for threats and vulnerabilities 
4. Providing incident response support 
5. Assisting with documentation and reporting 

However, they can’t: 

1. Make executive security decisions for your company 
2. Train your employees on security best practices daily 
3. Control how your organization handles physical security, visitor management, or insider threats 
4. Answer assessment questions that only internal leadership can address 

Even with the most capable provider, your organization retains ultimate responsibility for compliance. There’s no way around that. 

Beware of Providers Promising a '100% Compliance Solution' 

If a provider is selling you a total compliance solution that claims to handle everything for you, you should be skeptical.  

One of the easiest ways to separate legitimate providers from overpromisers is to ask if they map their services (in their Shared Responsibility Matrix) to NIST SP 800-171A—the verification procedures that assessors use to validate compliance. 

Here’s why this matters:  

Some vendors claim, “We cover all of NIST 800-171,” but that statement is often meaningless. NIST 800-171 lays out high-level requirements, but 800-171A provides the verification procedures—the specific things assessors will check to confirm compliance. 

If a provider doesn’t map their services to 800-171A, they may be covering only part of what’s required, leaving you with a major gap when it’s time for an audit. 

Shared Responsibility: How to Tell What’s Actually Covered 

The best way to clarify what a provider is actually handling is by asking for a Shared Responsibility Matrix (SRM). A good SRM should: 

1. Clearly define what the provider is responsible for and what falls on you 
2. Break down responsibilities at a control level, not just a requirement level 
3. Include specific verification procedures from 800-171

For example, one of the easiest ways to spot an overpromising provider is to ask: “Who determines our authorized users?” If they claim to handle that for you, that’s a major red flag. 

The designation of authorized users is a management decision that only you can make. A provider can help enforce those decisions technically, but they can’t make them on your behalf. 

The Risk of Taking a 'Hands-Off' Approach 

Even if you find a great provider, taking a completely hands-off approach is risky. Here’s why: 

1. You’re still liable. If something goes wrong, your organization—not the provider—will be on the hook for compliance failures, including potential False Claims Act violations. 
2. CMMC is about culture, not just tools. Compliance is an ongoing process that requires buy-in from leadership and employees. 
3. The assessment will reveal gaps. If you haven’t actively engaged in compliance, you may discover during an assessment that certain requirements weren’t fully addressed—and by then, it’s too late. 

At Summit 7, we’ve seen cases where companies thought they were compliant because they outsourced everything, only to find out later that their provider hadn’t actually done what they claimed. This is happening more frequently now as some MSPs/MSSPs realize they don’t want to deal with CMMC and are quietly backing out of contracts. 

How to Protect Yourself When Working with an External Service Provider 

If you’re partnering with an MSP/MSSP for compliance support, here’s how to avoid getting burned: 

1. Ask for their SRM mapped to 800-171A. If they don’t have one, run. 
2. Verify what they actually implement. Don’t take broad claims at face value—ask for specifics. 
3. Ensure your contract has penalties for non-performance. If they fail to deliver, you need a way to hold them accountable. 
4. Maintain internal oversight. Regularly review security controls, training, and policies to ensure ongoing compliance. 
5. Be prepared for assessments. Your provider should help prepare you, but you need to be actively involved in the process. 

Final Thoughts 

While an external provider can be a valuable partner in your compliance journey, they cannot take full responsibility for your organization’s compliance.  

The companies that succeed with CMMC are those that take an active role in the process, establish a strong security culture, and work with their providers—not just outsource and forget. 

If it sounds too good to be true, it probably is.  

The best thing you can do is ask the right questions, demand transparency, and stay engaged in your own compliance efforts. That’s the only way to ensure that when an assessment comes, you’re truly ready. 

If you want to hear more about our MSP, Guardian, reach out to us in the form below.