Does your organization handle cui?
Most defense contractors don’t realize how often they come across CUI in everyday work. In two minutes, learn if your company may already handle CUI.
Executive Brief
In-house IT teams sit at the center of most CMMC efforts. They manage systems, support users, and keep the business running while being asked to implement a demanding compliance framework.
CMMC compliance is not just another IT project. It introduces formal role separation, evidence requirements, and governance expectations that can conflict with day-to-day operational realities.
Dig deeper below to learn how internal IT teams can approach CMMC strategically, decide what to own versus outsource, and avoid common pitfalls that slow readiness or increase risk.
Why CMMC Creates Pressure for In-House IT Teams
CMMC Level 2 requires full implementation of all 110 NIST SP 800-171 controls. Those controls span technical, administrative, and procedural domains.
For internal IT teams, this often means:
- Supporting users while implementing security controls
- Acting as system administrators and compliance owners
- Producing assessment evidence while keeping systems operational
CMMC expects documented separation of duties, repeatable processes, and objective evidence. Many IT teams are structured for speed, not audit readiness.
Role Separation Requirements and Why They Matter
CMMC does not require large teams, but it does require segmentation.
At a minimum, organizations must separate:
- System administration from security oversight
- Control implementation from control validation
- Day-to-day IT support from compliance governance
Common problem areas:
- The same admin configures systems, approves changes, and validates compliance
- No independent review of logs, alerts, or access approvals
- Security policies exist but are not enforced or reviewed consistently
Role separation can be achieved through internal checks and balances or external support. What matters is that it is documented, enforced, and defensible during assessment.
Managing Compliance Work Without Breaking IT Operations
CMMC readiness is sustained work, not a one-time push.
Internal teams that succeed usually:
- Assign a compliance owner who is not the help desk
- Treat CMMC tasks as scheduled operational work, not side projects
- Use defined workflows for evidence collection and reviews
- Protect time for documentation, validation, and remediation
Trying to handle CMMC only after hours or between tickets is one of the fastest ways to stall progress.
When to Handle CMMC In-House vs. Outsource
There is no universal right answer. Most contractors land somewhere in the middle.
Common in-house responsibilities:
- System administration and configuration
- User access management
- Day-to-day security operations
- Environment-specific documentation
Commonly outsourced functions:
- Gap assessments and readiness reviews
- SSP and POA&M structure guidance
- Independent control validation
- Strategic roadmap development
If your team lacks experience with NIST 800-171 assessment objectives or SPRS scoring mechanics, external guidance reduces rework and reporting risk.
MSP vs. Consultant vs. Full DIY
Each model carries tradeoffs.
Full DIY
- Lowest external cost
- Highest internal time burden
- Increased risk if experience is limited
Managed Service Provider (MSP)
- Strong operational support
- Not all MSPs are CMMC-aware
- Must clearly define compliance responsibilities
Compliance Consultant or Advisor
- Focused on strategy and assessment readiness
- Does not replace IT operations
- Works best alongside internal teams
The strongest outcomes come from intentional combinations, not single-vendor promises.
Why a Shared Responsibility Matrix Is Non-Negotiable
Any partnership with an external service provider without a documented responsibility split creates risk.
A shared responsibility matrix should clearly define:
- Who implements each control
- Who maintains evidence
- Who reviews and validates controls
- Who responds during an assessment
This protects internal IT teams from being held accountable for work they do not control and prevents vendors from overstepping or underdelivering. If it is not written down, it will be questioned during assessment.
CMMC compliance does not replace internal IT operations or shift accountability to a partner. It formalizes how security work is performed, documented, and independently validated.
Internal teams remain essential, but they do not need to carry the entire burden alone. Clear role separation, realistic resourcing, and well-defined partnerships make compliance achievable without burning out your staff.
The goal is not perfection. The goal is defensible, repeatable, and auditable security.
FAQs
Can a small IT team meet CMMC role separation requirements?
Yes. Role separation is about independence and documentation, not headcount.
Can an MSP be fully responsible for CMMC compliance?
Compliance is a shared responsibility, but ultimate accountability stays with the contractor.
Is outsourcing compliance a shortcut?
No. Outsourcing supports strategy and validation. Implementation still matters.
