CUI for CMMC

The CUI – CMMC Connection

CMMC 2.0 requirements are directly tied to the protection of CUI. The framework establishes three levels of cybersecurity maturity:

• Level 1: Focuses on the protection of Federal Contract Information (FCI)

• Level 2: Encompasses the protection of CUI and requires implementation of 110 security controls from NIST SP 800-171

• Level 3: Provides enhanced protection for CUI in critical programs and technologies

Most defense contractors handling CUI will need to achieve at least CMMC Level 2 certification, which represents the bulk of compliance effort across the DIB.

Common CUI Pain Points and Practical Solutions

Pain Point 1: Identifying CUI in Your Environment 

Many contractors struggle with the fundamental question: “What information in our possession actually qualifies as CUI?”

Solution: Implement a structured CUI identification process:

1. Review contract language carefully: Look for references to CUI, NIST SP 800-171, controlled technical information, or similar terms in your contracts and RFPs

2. Consult the CUI Registry: Visit the NARA CUI Registry to understand the 20 categories and 125+ subcategories of CUI.

3. Conduct data flow mapping: Document how potentially sensitive information moves through your organization.

4. Create a CUI inventory: Maintain a detailed record of all identified CUI, including its category, source, format, and location.

5. Establish a CUI review board: Form a cross-functional team to make determinations about ambiguous information.

Pain Point 2: CUI Marking and Handling Procedures 

Once CUI is identified, contractors often struggle with appropriate marking, handling, and dissemination procedures.

Solution: Develop comprehensive CUI handling policies:

1. Implement proper marking: Apply standardized CUI markings to documents and materials containing CUI according to 32 CFR Part 2002

2. Create handling procedures: Establish clear guidelines for how CUI should be handled, processed, transmitted, and destroyed.

3. Train all personnel: Ensure everyone who might come into contact with CUI understands proper handling procedures.

4. Document authorized users: Maintain an up-to-date list of individuals authorized to access specific categories of CUI

5. Implement need-to-know principles: Restrict CUI access to only those who require it to perform their job functions.

Pain Point 3: CUI in Cloud Environments  

As organizations increasingly migrate to cloud services, protecting CUI in these environments presents unique challenges.

Solution: Take a deliberate approach to cloud usage with CUI:

1. Verify FedRAMP Moderate (or equivalent) compliance: Ensure your cloud service provider meets this minimum standard for CUI protection.

2. Implement customer-responsible controls: Remember that many NIST 800-171 controls remain your responsibility even in cloud environments.

3. Create data classification policies: Clearly define what types of data can be stored where

4. Use encryption properly: Implement encryption both in transit and at rest for all CUI.

5. Monitor cloud security posture: Continuously assess your cloud environment for security gaps.

Pain Point 4: Managing CUI with External Parties

Contractors often struggle with how to handle CUI when working with subcontractors, vendors, and other external parties.

Solution: Implement robust supply chain CUI management:

1. Flow down requirements: Ensure all CMMC and CUI protection requirements are properly flowed down to subcontractors

2. Assess supplier capabilities: Evaluate whether external parties have the necessary safeguards to protect CUI

3. Limit CUI sharing: Only share CUI with external parties when absolutely necessary

4. Use secure transmission methods: Implement encrypted email or secure file-sharing solutions for external CUI sharing

5. Document all CUI exchanges: Maintain records of what CUI was shared, with whom, when, and for what purpose

Technical Implementation of CUI Protection

1) Creating CUI Enclaves 

For many organizations, segregating CUI into a well-defined boundary or “enclave” represents the most practical approach to compliance. Key considerations for CUI enclaves include:

1. Boundary definition: Clearly define what systems, networks, and data repositories are part of your CUI environment

2. Access controls: Implement strong authentication and authorization for the enclave

3. Monitoring and logging: Ensure comprehensive visibility into activities within the CUI boundary

4. Data transfer controls: Establish secure methods for moving information in and out of the enclave

5. Documentation: Maintain detailed network diagrams and system security plans for the CUI environment

2) Implementing Multi-Factor Authentication for CUI Access

NIST 800-171 requirement 3.5.3 mandates multi-factor authentication (MFA) for local and network access to systems containing CUI. Practical implementation approaches include:

1. Software authenticators: Applications like Microsoft Authenticator or Google Authenticator

2. SMS-based solutions: While less secure, can be a starting point (though not recommended for high-sensitivity environments)

3. Biometric authentication: Fingerprint or facial recognition paired with another factor

A small defense contractor with limited IT resources was able to successfully implement Microsoft Authenticator for their CUI systems with minimal cost and user disruption.

3) Encryption Solutions for CUI Protection

Proper encryption is fundamental to CUI protection, especially for requirement 3.13.11 (encrypt CUI at rest). It needs to be FIPS validated. 

Effective encryption strategies include:

1. Full disk encryption: BitLocker (Windows) or FileVault (Mac) for endpoint protection

2. File-level encryption: For more granular protection of specific documents

3. Database encryption: For structured CUI stored in databases

4. Email encryption: Solutions like Microsoft Information Protection for protecting CUI in communications

5. Encrypted backups: Ensuring backup copies of CUI remain protected

Developing a CUI Program

A mature CUI management approach requires a structured program with clear governance.

Key program elements include:

1. CUI policy: A formal document establishing CUI management requirements

2. CUI procedures: Step-by-step instructions for handling CUI

3. Designated CUI Program Manager: An individual responsible for program oversight

4. Training program: Regular education for all personnel who handle CUI

5. Compliance monitoring: Ongoing assessment of adherence to CUI requirements

6. Incident response procedures: Specific protocols for potential CUI breaches

Integrating CUI Management with Existing Processes

Rather than creating entirely new workflows, successful organizations integrate CUI protection into existing business processes.

Integration opportunities include:

1. Contract review process: Add CUI identification steps to contract analysis

2. Information lifecycle management: Incorporate CUI considerations into data handling procedures

3. Employee onboarding/offboarding: Include CUI training in onboarding and CUI access termination in offboarding

4. Vendor management: Add CUI handling capabilities to vendor assessment criteria

5. Risk management: Incorporate CUI-related risks into your overall risk management framework

Preparing for your CMMC Assessment

A) Gap Assessment and Remediation  

Before pursuing formal CMMC certification, conducting a thorough gap assessment is essential.

Recommended approach:

1. Perform initial self-assessment: Use the DoD Assessment Methodology to establish a baseline

2. Conduct detailed practice reviews: Examine each NIST 800-171 requirement in depth

3. Develop a detailed Plan of Actions & Milestones (POA&M): Document all gaps with remediation plans

4. Implement high-priority controls first: Focus on fundamental practices with significant security impact

5. Document evidence of implementation: Maintain records that demonstrate compliance

B) Documentation Preparation

Proper documentation is crucial for successful CMMC assessment. Essential documentation includes:

1. System Security Plan (SSP): A comprehensive document describing your cybersecurity implementation

2. Configuration management documentation: Records of system hardening and configuration standards

3. CUI handling procedures: Detailed protocols for managing CUI throughout its lifecycle

4. Incident response plan: Procedures for addressing cybersecurity incidents

5. Training records: Evidence of security awareness and specialized CUI training

Beyond CMMC Compliance

While achieving CMMC certification is necessary for defense contractors, the most successful organizations recognize that effective CUI protection offers benefits beyond compliance.

Robust CUI management:

• Enhances your competitive position for government contracts

• Protects your own intellectual property with similar sensitivity

• Demonstrates commitment to national security

• Builds trust with government clients and prime contractors

• Creates organizational discipline that improves overall security posture

By adopting a structured, programmatic approach to CUI management, you not only satisfy regulatory requirements but also strengthen your organization’s security foundation and competitive position in the defense industrial base.

As you continue your CMMC journey, remember that proper CUI protection isn’t just about checking compliance boxes—it’s about contributing to national security while building a more resilient organization.

Additional Resources:

• NIST SP 800-171 Rev 2

• DoD CUI Training