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    CMMC Compliance for Solution Implementers

    Solution implementers (SIs) are the engine behind countless DoD 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 CUI and must now be protected under strict requirements.

    Manufacturing

    Architectural, Engineering, and Construction

    Regulated Research

    Solution Implementers

    Private Equity

    Transportation

    Top CMMC Pain Points in Solution Implementers

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    Mixed Environments

    Some work on government-furnished equipment, others on your devices; CUI still follows you.

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    Subcontractor Risk

    You’re working with consultants, teaming partners, and JVs: how do you share data compliantly?

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    Large IT Teams

    Corporate IT may support the whole org but can’t meet DoD-specific compliance needs.

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    Low Revenue % from Defense

    CMMC applies, but you can’t justify wrapping your entire org in compliance.

    Options for Solution Implementers

    Enclave (Most Common)
    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

    All-In Approach (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

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    Frequently Asked Questions

    Can MSPs inherit and manage all CMMC responsibilities for clients?
    No. While Managed Service Providers (MSPs) can implement and operate many controls on behalf of clients, they cannot fully absorb the client’s compliance responsibilities. The Department of Defense 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 SRM (Shared Responsibility Matrix) include?
    An effective SRM (now called a Customer Responsibility Matrix) 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.
    Can an MSP access multiple 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 POA&Ms (Plans of Action & Milestones). 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.
    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.

    “The support from everyone at Summit 7—project managers, billing team leads, and even individual techs within Guardian and Vigilance—has been phenomenal.”

    – Brady Murry, ISSM, Cayuse Government Operations

    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.

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