By Payam Pourkhomami, President & CEO of OSIbeyond
Many defense contractors wonder if they can simply hire a provider to handle their CMMC compliance obligations from start to finish. It’s a natural question given the complexity of CMMC compliance and the fact that outsourcing has solved countless other business challenges. However, cybersecurity compliance operates under fundamentally different rules than typical business services, so the answer isn’t a simple “yes” or “no.”
What You Can and Can’t Delegate in CMMC
While you can’t transfer ultimate accountability for compliance, you can strategically outsource significant portions of the technical work required to achieve CMMC compliance.
The divide between what can and can’t be outsourced typically follows a clear pattern: technical implementation and monitoring activities are prime candidates for outsourcing, while governance, policy decisions and legal obligations must remain under your direct control. This split isn’t arbitrary. Instead, it reflects both the legal framework of defense contracting and the practical realities of organizational security.
In practice, the majority of CMMC Level 2 requirements can be effectively supported by qualified Managed Service Providers, or MSPs, or Managed Security Service Providers, or MSSPs, for most SMBs, which leaves a fairly manageable number of requirements that require your organization’s direct involvement and decision-making authority.
CMMC Compliance Activities Typically Outsourced to MSPs
The technical side of CMMC compliance is where MSPs shine by bringing specialized expertise, enterprise-grade tools and 24/7 operational capabilities that would be prohibitively expensive for most SMBs to develop internally. Here are some examples of what defense contractors commonly delegate to their MSP partners:
- Firewall and network security management: MSPs excel at deploying and managing enterprise-grade firewalls with comprehensive logging and rule management. When implemented, they directly address CMMC 2.0 Level 2 requirements SC.L2-3.13.1, which requires organizations to “monitor, control and protect communications at the external boundaries,” and SC.L2-3.13.5, which mandates “implementing subnetworks for publicly accessible system components that are physically or logically separated from internal networks.”
- Endpoint detection and response, or EDR: MSPs can implement and manage EDR solutions across an entire device fleet, which satisfies the requirements of SI.L2-3.14.2 (obliges organizations to “provide protection from malicious code at designated locations within organizational systems”) and SI.L2-3.14.5 (mandates “performing periodic scans of organizational systems and real-time scans of files from external sources”).
- Vulnerability scanning and patch management services: MSPs can scan your systems for security weaknesses, prioritize patches based on risk and implement updates during approved maintenance windows. These services directly support several key CMMC 2.0 Level 2 requirements derived from NIST SP 800-171. Specifically, they help meet RA.L2-3.11.2, which requires organizations to “scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities are identified,” as well as RA.L2-3.11.3, which mandates that identified vulnerabilities be “remediated in accordance with risk assessments.”
- Government cloud architecture and security: For organizations using FedRAMP-authorized solutions like Microsoft GCC High or AWS GovCloud, MSPs can provide expertise in architecting compliant environments to comply with SC.L2-3.13.8, which requires organizations to “implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission,” and SC.L2-3.13.11, which mandates “employing FIPS-validated cryptography when used to protect the confidentiality of CUI.”
- Audit logging and monitoring configuration: MSPs have experience with configuring comprehensive audit logging to capture required events across cloud environments. This directly supports the extensive audit and accountability family of controls, including AU.L2-3.3.1, which requires creating and retaining “system audit logs and records to the extent needed to enable the monitoring, analysis, investigation and reporting of unlawful or unauthorized system activity,” and AU.L2-3.3.4, which mandates alerting “in the event of an audit logging process failure.”
- 24/7 Security Operations Center, or SOC, services: MSPs provide round-the-clock security monitoring through managed detection and response (MDR) services. With their 24/7 SOC services, they directly address SI.L2-3.14.6, which requires organizations to “monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks,” and SI.L2-3.14.7, which mandates identifying “unauthorized use of organizational systems.”
- Security incident correlation and response: Beyond basic monitoring, MSPs provide advanced correlation of security events across multiple systems. This supports AU.L2-3.3.5 (expects organizations to “correlate audit record review, analysis and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious or unusual activity”) and AU.L2-3.3.6 (calls for “audit record reduction and report generation to support on-demand analysis and reporting”).
As you can see, there’s a substantial range of technical controls that MSPs can effectively manage, and the examples above represent just a portion of the technical implementation work that can be outsourced. That said, this extensive technical support doesn’t mean you can hand over the keys to your compliance program. Knowing what can’t be outsourced is equally important to your CMMC success.
CMMC Compliance Tasks That Remain Internal Responsibilities
Certain aspects of CMMC compliance must remain under your organization’s direct control, and they reflect the fundamental principle that your organization (not your service providers) holds the DOD contract and bears ultimate accountability for protecting sensitive information. Here are the key areas that can’t be delegated:
- Access control decisions and user authorization: While MSPs can implement the technical mechanisms for access control, your organization must make the actual decisions about who gets access to CUI systems. This addresses AC.L2-3.1.1, which requires limiting “information system access to authorized users, processes acting on behalf of authorized users or devices.” Only your management can determine which employees need CUI access for their job functions.
- Physical security and facility access controls: CMMC requires the implementation of physical protection measures that inherently require on-site presence. PE.L2-3.10.1 requires limiting “physical access to organizational information systems, equipment and the respective operating environments,” while PE.L2-3.10.3 mandates escorting “visitors and monitoring visitor activity.” Your staff must physically check badges, escort visitors and secure your facilities, all of which are activities that remote MSPs simply can’t perform.
- System Security Plan, or SSP, ownership and approval: Your organization must maintain ownership of the System Security Plan, as required by CA.L2-3.12.4, which mandates developing, documenting and periodically updating system security plans. While an MSP can provide technical input and templates, your leadership must understand, approve and sign off on the SSP.
- Incident response decision-making and reporting: While MSPs can detect and help contain incidents, other key response decisions, such as the decision to shut down systems, notify customers or report to authorities, must come from your leadership and thus remain your responsibility. What’s more, the DFARS 252.204-7012 requirement to report cyber incidents to DOD within 72 hours is a legal obligation that falls solely on the prime contractor.
- Supply Chain Management responsibilities: Under DFARS 252.204-7012, the prime contractor must ensure that any subcontractors handling Covered Defense Information are also compliant and must flow down those requirements through contracts. Once again, an MSP might assist with vendor vetting, but your organization must formally oversee and document supply chain compliance controls.
The above-listed CMMC compliance tasks involve judgment calls, legal obligations and organizational knowledge that simply can’t be transferred. MSPs are extensions of your security operations, but you are legally responsible for compliance.
How the Shared Responsibility Matrix Can Help Split Compliance Duties
One of the biggest challenges defense contractors face when partnering with MSPs for CMMC compliance is keeping track of who handles what. With 110 security controls in CMMC 2.0 Level 2 and even more in Level 3, it’s alarmingly easy for requirements to fall through the cracks.
The Shared Responsibility Matrix, or SRM, solves this problem by creating a comprehensive document that maps every single CMMC requirement to a specific responsible party. Rather than vague statements like “MSP handles security monitoring,” the SRM specifies exactly which aspects of monitoring the MSP provides, what evidence they’ll deliver and what decisions remain with your organization.
Organizations seeking certification must obtain an SRM from all in-scope external service providers and cloud service providers to demonstrate the following common scenarios:
- Your organization retains control over governance decisions, policies and any activities requiring business judgment.
- Your MSP handles technical implementations like configuring firewalls, managing security tools and providing 24/7 monitoring.
- If you’re using cloud services like Microsoft GCC High or AWS GovCloud, the cloud provider assumes responsibility for physical datacenter security and platform-level controls.
The SRM is a mandatory requirement for CMMC assessments. When a C3PAO asks who is responsible for a specific control, you can immediately point to the documented assignment in your SRM. This clarity speeds up the assessment process and demonstrates to assessors that you’ve thoughtfully planned your compliance program.
Beyond compliance, the SRM serves as an operational tool that prevents finger-pointing when issues arise. If a security incident occurs, there’s no confusion about who makes specific decisions, who handles reporting and so on, which transforms what could be a chaotic situation into a coordinated response.
Conclusion
While complete outsourcing isn’t possible when it comes to CMMC compliance, a strategic partnership with a qualified MSP can still dramatically reduce the technical burden on your organization. The key lies in understanding which responsibilities you must retain and building a framework that clearly defines everyone’s role.
The experts at OSIbeyond understand this unique challenge and can help you build a compliance strategy that leverages the best of both internal governance and external technical expertise. Schedule a consultation to discuss how we can help you achieve CMMC compliance.
