While CMMC compliance can feel complex, with the right guidance, it is entirely achievable. Every CMMC requirement is designed to safeguard Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). For organizations pursuing CMMC Level 2 assessments, it means having clear, documented evidence that security controls are in place and function effectively.
Overlooking even a small control can create risk, delay certification, or, at worst, jeopardize a contract. Meeting this standard requires evidence that every control is implemented, and every responsibility and expectation is clearly assigned and understood across the organization.
A successful CMMC assessment starts with defined roles, responsibilities, and documentation - and that begins with a well-built Customer Responsibility Matrix (CRM), previously but still often referred to as a Shared Responsibility Matrix, or SRM. The right External Service Provider (ESP) will bring both technical expertise and clarity, ensuring the details are transparent and defensible, and accountability is clearly understood across all stakeholders.
Whether you're working with a Managed Service Provider (MSP) or a Managed Security Service Provider (MSSP), your provider’s approach to the CRM is key to a smooth assessment.
Beyond the high-level mapping of who is accountable for major cybersecurity and compliance domains, such as access control, incident response, and data protection, the CRM also defines ownership across:
By aligning expectations, the CRM helps scope your System Security Plan (SSP) and ensures there’s no confusion about who is responsible for protecting CUI.
But that’s just the start.
Ideally, the CRM should provide a control-by-control accountability map aligned with the 320 CMMC assessment objectives outlined in NIST SP 800-171A. It should also detail the services a client engages in, the client's responsibilities, the ESP's responsibilities, and the impact.
For each of the 320 security requirement assessment objectives, a well-defined, sophisticated CRM model identifies:
This is the roadmap your C3PAO assessor will rely on to verify that controls are clearly assigned, properly executed, and defensible during an assessment.
At Systems Engineering, we go beyond boilerplate templates. Our CRM clearly defines the responsibilities of Systems Engineering and our clients.
We’ve spent years developing a sophisticated supply chain and trusted vendor relationships. This foundation ensures our CRM is coordinated with those of our vendors to capture the complete chain of responsibility, including Systems Engineering’s role and the responsibilities of our vendors.
We take this a step further by working directly with our own curated list of vendors, helping them to update their shared responsibility matrices if necessary. These documents are detailed down to the individual assessment objective level, ensuring nothing is overlooked during evaluations.
Our CRM is the result of years of hands-on experience, and is built to be:
Controlling the flow of CUI requires enforcing approved authorizations across your systems. For example, if you’re removing local administrator rights on end-user devices, that’s a solid first step, but it’s only part of the solution.
For instance, what happens if a user calls the help desk asking to install new software? Without clear accountability and documented evidence, that single request could bypass security safeguards and create a compliance risk.
This kind of oversight shows why a thorough gap analysis in the context of your entire supply chain CRM is essential. It not only highlights where partial coverage leaves vulnerabilities but also forces organizations to validate controls, document responsibilities, and address vulnerabilities before they become assessment-day issues.
Our experience preparing OSCs for certification reveals that the most effective CRMs include:
Based on our history in working with clients on successful CMMC assessments, we’ve helped clients move away from:
While the CRM is essential for passing a CMMC assessment, the value extends far beyond compliance:
As a CMMC Registered Provider Organization (RPO) and an experienced Managed IT and Cybersecurity provider, we bring both the strategic compliance expertise and the technical depth to:
We don’t just describe controls. We help implement, maintain, and continuously validate them.
With Systems Engineering as your partner, you gain a dual advantage: strategic compliance advisory and technical implementation expertise. This ensures nothing gets lost between the plan and the practice.
Let’s start with a gap analysis and build a path to confident CMMC certification.