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.
Want to protect both your clearance and your contracts? Dig deeper below.
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.
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.
CMMC isn’t just an IT requirement, it’s a facility-level security expectation.
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:
FSOs who bridge these frameworks strengthen both compliance and credibility during audits.
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.
The FSO doesn’t need to be the IT expert, but they do need to ensure all parts of the security program work together.
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.
CMMC certification provides an objective way to demonstrate that your facility protects defense information at every level.
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.
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.
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.
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.
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.