How FedRAMP Impacts CMMC Compliance

As the Cybersecurity Maturity Model Certification (CMMC) program enforcement nears, defense contractors face a double challenge: securing their own systems and validating the cloud services they rely on. That’s where FedRAMP comes in. By meeting FedRAMP standards, contractors can streamline one of the key components of achieving CMMC certification, cloud security.

Two Cybersecurity Government Bodies Converge 

Think of CMMC and FedRAMP as separate but complementary guardians of sensitive government data, each with distinct but overlapping purpose when it comes to protecting government data by independent security assessment. CMMC operates as the Department of Defense (DoD)’s compliance enforcement mechanism, aimed at verifying that defense contractors who handle Controlled Unclassified Information (CUI) are complying with cybersecurity requirements. Similarly, FedRAMP functions as the government-wide marketplace for secure cloud services, establishing standardized protocols across all federal agencies that are independently verified.

This distinction matters more than you might realize. While CMMC focuses specifically on DoD contractors and their information systems, FedRAMP casts a broader net, applying to all federal agencies and any cloud service providers that want to do business with the federal government and store, process, or handle federal data. The convergence occurs when government contractors use external cloud services to store, process or transmit CUI. This is where two separate cybersecurity frameworks work in tandem to protect government data.

CMMC's Three-Tiered Architecture

The current CMMC 2.0 framework streamlines previous iterations into three distinct levels, each calibrated to protect different categories of sensitive information:

CMMC Level 1 addresses basic cybersecurity hygiene for firms handling Federal Contract Information (FCI). This tier requires annual self-assessments against 15 fundamental security requirements, focusing on foundational practices like access control and incident reporting.

CMMC Level 2 represents the compliance destination for most defense contractors, encompassing organizations that process CUI. This level mandates adherence to all 110 security controls outlined in NIST SP 800-171, with assessments conducted every three years by Certified Third-Party Assessment Organizations (C3PAOs).

CMMC Level 3 applies to contractors involved with the most sensitive Department of Defense (DoD) programs, requiring compliance with the 110 NIST SP 800-171 controls plus an additional 24 enhanced security requirements from NIST SP 800-172. The Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) conducts comprehensive on-site evaluations of these protocols. 

Now, if you’ve been complying with the Defense Federal Acquisition Regulation Supplement (DFARS) contract requirements, you should be prepared already. DFARS 252.204-7012 has required DoD contractors to safeguard controlled unclassified information (CUI) with the NIST SP 800-171 controls since 2017. The CMMC program seeks to enforce this existing requirement with a tiered certification model. In other words, if you’ve had DFARS 7012 requirements in your contracts already, you should hopefully be ready for CMMC assessment.

FedRAMP's Strategic Role in Compliance Architecture

At what point does FedRAMP enter the compliance equation? FedRAMP becomes essential when CUI extends beyond your internal systems into external, third-party managed cloud environments, which is always the case with Software-as-a-Service (SaaS) solutions. The FedRAMP program defines three impact levels for authorization: FedRAMP Low, FedRAMP Moderate and FedRAMP High. For defense contractors that have external cloud services that will store, process or transmit CUI, those cloud service providers must have FedRAMP Moderate authorization or equivalence, and be listed on the FedRAMP Marketplace, to support CMMC Level 2 & Level 3 certification.

FedRAMP Moderate authorization requires cloud service providers to implement 325 security controls and conduct continuous monitoring in order to achieve this status by external assessment. FedRAMP Moderate Equivalency requires the same level of security and external assessment but does not require a federal agency sponsorship. The FedRAMP program was originally intended, and is primarily used, to provide a vetted marketplace for federal agencies to purchase SaaS solutions, but when DoD inserted the requirement for cloud services to demonstrate FedRAMP Moderate security into the DFARS 252.204-7012 language, the option for equivalency was offered as a way for SaaS providers that do not serve federal agencies a way to provide their services to defense contractors.

The recently announced FedRAMP 20x initiative promises to streamline authorization processes, potentially reducing timelines from months to weeks while eliminating agency sponsorship requirements. However, these improvements remain in development, and current authorization pathways continue to require significant time and investment.

External Service Provider Requirements: Where CMMC and FedRAMP Intersect

When your organization leverages cloud service providers (CSPs) that will store, process, or transmit CUI, both CMMC and FedRAMP requirements converge. The DFARS 252.204-7012 clause explicitly requires cloud service providers handling Controlled Unclassified Information to demonstrate FedRAMP Moderate authorization or equivalency.

This requirement creates a critical decision point for your compliance strategy. You can’t simply inherit FedRAMP authorization from your commercial cloud providers—each organization in the supply chain has to independently demonstrate compliance with applicable requirements. As a result, SaaS and Platform-as-a-Service (PaaS) offerings require separate assessments and listings on the FedRAMP marketplace.

Foundational Document: A System Security Plan

Central to proving compliance is the System Security Plan (SSP)- the foundational document that demonstrates how your organization implements required security controls, enabling continuous monitoring. Typically spanning hundreds of pages, this comprehensive document serves as both a compliance artifact and an operational guide for your cybersecurity program.

Assessors will scrutinize your SSP to verify that documented controls align with actual implementation. Plus, prime contractors now increasingly request SSPs from subcontractors as part of their due diligence processes, making this document essential for maintaining supply chain relationships.

The Fall 2025 Inflection Point: No Longer a Moving Target

Not long ago, CMMC was viewed as a future concern. Now, the DoD's submission of the final 48 CFR rule to the Office of Management and Budget in July 2025 marks a decisive milestone in CMMC implementation. The official program will be codified on November 10, 2025, and CMMC certification requirements will appear in virtually all DoD solicitations.

This timeline eliminates previous uncertainty about CMMC's implementation schedule. Contractors can no longer treat CMMC as a future consideration; it's now an immediate business requirement that will determine cyber posture and, as a result, contract eligibility within months.

The phased rollout structure provides some implementation flexibility, but don't mistake this for extended deadlines. Phase 1 begins with the rule's effective date, requiring CMMC Level 1 and CMMC Level 2 self-assessments for applicable contracts. Phase 2, beginning in 2026, mandates third-party certifications for CMMC Level 2 compliance.

Action Items for Your Contracting Firm

The convergence of regulatory deadlines and enforcement activities suggests that immediate attention to several critical areas would be wise: 

Conduct a comprehensive gap analysis against NIST SP 800-171 requirements, identifying specific controls that require implementation or enhancement. This assessment should inform your SPRS scoring and provide the foundation for remediation planning.

Develop or update your System Security Plan to reflect current security implementations and planned improvements. Ensure this document accurately represents your security posture to avoid potential False Claims Act exposure.

Evaluate your cloud service providers for FedRAMP authorization status, particularly those that will access or store CUI. Develop migration plans for non-compliant services before contract requirements take effect.

Establish accurate SPRS reporting procedures that reflect your actual security implementation status. Given the False Claims Act implications of inaccurate reporting, consider engaging qualified cybersecurity professionals to validate your assessments.

Prepare for third-party assessment by identifying potential C3PAOs and understanding their availability and timelines. The Cyber AB marketplace includes current listings of accredited assessment organizations.

CMMC and FedRAMP compliance is a strategic imperative that will determine your organization's continued participation in the defense industrial base. Contracting firms that proactively address these requirements position themselves for competitive advantage, while those that delay face potential exclusion from lucrative government contracts.

Deltek’s Costpoint GovCon Cloud Moderate (GCCM) solution is purpose-built to support government contractors in achieving their CMMC Level 2 certification. Read more about Deltek’s proactive approach to completing the FedRAMP Moderate Equivalency assessment for Costpoint GCCM and its deep expertise in government contracting.