Executive Brief
For Facility Security Officers (FSOs), cybersecurity readiness has officially joined physical and personnel security as a core clearance responsibility. The Department of Defense (DoD) is connecting Facility Clearance (FCL) eligibility with Cybersecurity Maturity Model Certification (CMMC) compliance.
- Weak cyber practices can trigger questions during Defense Counterintelligence and Security Agency (DCSA) reviews or Foreign Ownership, Control, or Influence (FOCI) mitigation.
- Industrial Security Representatives (IS Reps) are asking about Controlled Unclassified Information (CUI) protection and CMMC readiness during facility assessments.
- FSOs who coordinate early with IT and compliance teams will reduce risk, streamline reviews, and strengthen their security posture.
Want to protect both your clearance and your contracts? Dig deeper below.
The Expanding Role of the FSO
The Facility Security Officer’s job is no longer confined to physical access control and personnel vetting. CUI now sits squarely in the FSO’s operational lane.
DCSA and the DoD view poor cybersecurity as a potential national security risk. That means even if your classified environment is secure, weak handling of CUI in your unclassified systems can still raise flags.
CMMC readiness shows DCSA that your facility can protect sensitive defense information across all environments, not just in the secure area.
Why FSOs Should Care About CMMC
FSOs are the first line of defense for protecting classified and sensitive information. As DCSA reviews evolve, cybersecurity is being evaluated alongside personnel, physical, and information security.
- DCSA alignment: Cybersecurity gaps are now considered part of overall facility risk during security vulnerability assessments.
- FOCI implications: Weak cyber controls may trigger additional mitigation measures under FOCI reviews, such as requiring enhanced monitoring, board resolutions, or technology control plans to limit foreign access to CUI or IT systems.
- Eligibility impact: A cyber incident involving CUI can delay or jeopardize your facility clearance renewal.
CMMC isn’t just an IT requirement, it’s a facility-level security expectation.
Where FCL and CMMC Requirements Overlap
FSOs already manage many of the same principles that CMMC enforces. The overlap between National Industrial Security Program Operating Manual (NISPOM) and National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 controls is significant.
Key areas to watch:
- Access control: Manage and document who has access to both classified and CUI systems.
- Incident reporting: Follow DCSA and DoD protocols for both classified and cyber incidents.
- Personnel training: Ensure cleared and uncleared staff understand how to handle CUI within cleared environments.
- System integrity: Maintain configuration control, encryption, and monitoring that protect both physical and digital assets.
FSOs who bridge these frameworks strengthen both compliance and credibility during audits.
How FSOs Can Lead CMMC Integration
CMMC readiness succeeds when the FSO leads coordination between security, compliance, and IT. By positioning cybersecurity within your existing facility security program, you create efficiency and demonstrate unified risk management.
- Build a joint task group: Bring together your FSO, Information System Security Manager (ISSM), and compliance lead to align control implementation.
- Review CUI requirements under 32 CFR Part 2002: Ensure your facility’s procedures for handling and protecting CUI align with the same principles driving CMMC and NIST SP 800-171 implementation.
- Review the System Security Plan (SSP): Verify it reflects how your facility stores, transmits, and protects CUI.
- Run integrated drills: Combine insider threat, access control, and cyber incident tabletop exercises for a 360° response strategy.
The FSO doesn’t need to be the IT expert, but they do need to ensure all parts of the security program work together.
What’s at Risk if You Wait
An FCL is a privilege, not a permanent status. As DCSA deepens its focus on cyber readiness, failure to maintain or demonstrate CMMC progress could create clearance risk.
- Delays in revalidation or mitigation approvals
- Additional oversight during security reviews
- Possible disqualification from cleared work until issues are resolved
CMMC certification provides an objective way to demonstrate that your facility protects defense information at every level.
Stay Ahead of the Curve
FSOs who embrace CMMC as part of their broader facility program are positioning their organizations for long-term success. Coordinating early with IT and compliance not only prevents surprises, it proves your facility is fully aligned with the DoD’s modern security expectations.
Protect your clearance and your contracts.
FAQs
Does CMMC apply to cleared facilities that only handle classified data?
If your facility handles only classified information and no CUI, CMMC may not directly apply. However, many cleared contractors work on mixed contracts where both classified and CUI data exist. DCSA is increasingly reviewing how facilities protect CUI even outside classified systems.
How does NISPOM relate to CMMC?
NISPOM governs how cleared contractors protect classified information. CMMC, based on NIST SP 800-171, governs how they protect CUI. Both share control areas such as access management, incident reporting, and personnel security and DCSA expects consistency between them.
What should an FSO do first to prepare for CMMC?
Start with a joint meeting between your FSO, ISSM, and compliance lead. Map your NISPOM and NIST 800-171 controls, identify overlap, and confirm that CUI protection is addressed in your SSP.
Will cybersecurity issues affect my facility clearance?
Yes. A cyber incident or documented noncompliance related to CUI can trigger a DCSA review or impact your facility’s eligibility for certain programs. Strong CMMC alignment reduces that risk and demonstrates proactive security management.
