Governance, Risk, & Compliance (GRC) Guide

Successfully implementing a GRC strategy around CMMC and NIST SP 800-171 requires a structured, phased approach. These phases align with common services used by organizations to achieve and maintain compliance:

1. Discovery & Evaluation

Before organizations can take meaningful steps toward compliance, they must understand where they stand. The Discovery phase involves: 

• Scoping compliance efforts based on contract requirements 

• Conducting a gap analysis to compare current security postures against NIST SP 800-171A Assessment Objectives 

• Developing key documentation, including a System Security Plan (SSP) and Plan of Action and Milestones (POA&M) 

• Calculating and reporting an SPRS score for DFARS 252.204-7019 compliance 

2. Planning

Once gaps are identified, organizations need a clear roadmap to compliance. The Planning phase focuses on: 

• Building POA&M projects to remediate identified gaps 

• Developing a structured CMMC compliance roadmap 

• Prioritizing remediation efforts based on risk and regulatory deadlines 

3. Remediation

This is where the heavy lifting happens—closing compliance gaps and implementing necessary security controls. Key activities include: 

• Executing POA&M remediation projects to mitigate identified risks 

• Developing, refining, and overseeing compliance documentation, such as policies, procedures, and the Shared Responsibility Matrix (SRM) 

• Collecting and managing evidence to demonstrate compliance readiness 

4. Maintenance

Compliance isn’t a one-and-done effort—it requires ongoing oversight. The Maintenance phase ensures that security and compliance postures remain strong over time: 

• Implementing continuous monitoring activities 

• Managing risk and vulnerability programs 

• Adhering to proper change management processes 

• Staying in tune with evolving changes and requirements (hint: CMMC adoption of NIST SP 800-171 Rev 3) 

A GRC tool helps organizations streamline compliance management, track remediation efforts, and provide a centralized repository for security documentation. These platforms often include features such as: 

• Automated tracking of security controls and compliance tasks 

• Centralized dashboards for risk assessment and POA&M management 

• Evidence collection and audit readiness support 

These tools provide DoD contractors with an intuitive platform to manage their NIST SP 800-171 and CMMC compliance efforts, enabling organizations to: 

• Track their compliance journey with real-time dashboards 

• Assign and monitor security responsibilities across teams 

• Automate compliance documentation and reporting 

Many contractors struggle with keeping POA&Ms from piling up. An effective GRC strategy should aim to reduce open POA&Ms to zero—and keep them there. But doing so requires more than a tool or checklist; it demands hands-on support. 

For many DoD contractors, compliance is like building a house—with countless steps, shifting requirements, and uncertainty about where to start. Even when those steps are broken down, the path forward can remain overwhelming. That’s why a Managed GRC solution is the easiest pathway for compliance: it offers step-by-step oversight through the entire compliance journey, ensuring – at any given moment – you are not alone in navigating CMMC and NIST SP 800-171. 

A Managed GRC solution empowers your team to build a fully compliant and sustainable cybersecurity program. With dedicated guidance, this model offers in-depth support while clearly defining responsibilities. Your organization remains responsible for compliance, but expert consultants provide direct support and strategic oversight to meet every requirement. 

This service is structured around the concept of a shared responsibility—reflected in documentation like the Shared Responsibility Matrix (SRM)—where the Managed GRC influences, supports, or owns 100% of the required controls. That means not one of the 320 assessment objectives in NIST SP 800-171a will be carried by your organization alone.  

By integrating with other managed solutions like Summit 7’s Managed Service Provider (MSP), Guardian, and Managed Security Solution Provider (MSSP), Vigilance, this managed GRC layer adds a third pillar: long-term compliance leadership. It's not a one-time engagement but an ongoing partnership designed to prepare you for future assessments, maintain compliance, and continuously strengthen your security posture. 

In short, the Managed GRC approach makes compliance a “we” problem—not just a “you” problem. 

If you would like to learn more about Summit 7's GRC solutions, fill out the form below. Someone from our team will get you the answers you need within one business day: