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CMMC Compliance Path: 3 Proven Strategies | FirstCall Consulting

Written by Travis Sands | Aug 1, 2025 11:18:57 AM

If you’re a defense contractor or part of the Department of Defense (DoD) supply chain, CMMC (Cybersecurity Maturity Model Certification) is no longer a “someday” initiative—it’s a present-day priority. With compliance deadlines looming and new contract requirements fast approaching, the question isn’t if you need to comply, but how you’re going to get there.

In this post (and podcast episode), we’re decoding your CMMC path by breaking down how to choose the right implementation strategy—one that aligns with your current state, business objectives, and available resources.

Why CMMC Strategy Isn’t One-Size-Fits-All

Every organization’s CMMC journey is unique. The size of your business, the type of data you handle, and your current cybersecurity maturity level all influence the strategy you should pursue.

A small subcontractor managing only Federal Contract Information (FCI) may not require the same scope or effort as a large prime contractor handling Controlled Unclassified Information (CUI) or International Traffic in Arms Regulations (ITAR) data across multiple departments. Some organizations already have strong security infrastructure but lack documentation, while others may be starting from the ground up with limited IT resources and tight deadlines.

Trying to force a standard solution across these very different scenarios often leads to common pitfalls—overspending on unnecessary tools, failing audits due to scope confusion, or losing out on contracts because of compliance delays. At FirstCall Consulting, we’ve worked with a wide range of defense-focused organizations navigating CMMC Levels 1, 2, and 3. What we’ve learned is simple: your implementation strategy needs to reflect your actual operations, risk level, and growth trajectory.

Here are the three strategic paths we most often recommend to clients—each designed to help you reach compliance efficiently and with confidence.

1. The Gap Assessment Path

This path is designed for organizations that need a clear understanding of their current cybersecurity posture against CMMC requirements. It’s ideal if you’re new to CMMC, have outdated policies, are unsure of your in-scope systems, or need to validate existing prep work.

How it works: The Gap Assessment begins with a comprehensive evaluation of your existing technology, documentation, user behavior, and security policies against the CMMC requirements relevant to your business (e.g., Level 1, 2, or 3). We identify specific areas where your current practices fall short (“gaps”), assess associated risks, and provide a detailed, prioritized roadmap for remediation.

Key Benefits:

  • Clarity and Direction: You gain a precise understanding of your current compliance status, what’s missing, and the exact steps needed to bridge those gaps.
  • Realistic Planning: Receive accurate timeframes and budget estimates for your compliance journey, eliminating guesswork and preventing last-minute surprises.
  • Early Wins: Identify and address straightforward deficiencies quickly, such as policy updates or multi-factor authentication rollouts, building immediate confidence and momentum.
  • Foundation for Success: Establishes a solid baseline for a well-informed and efficient compliance journey, providing the essential starting point if you’re unsure where to begin.

2. The GCC/GCC High All-In Path

This path is tailored for organizations committed to leveraging Microsoft’s Government Community Cloud (GCC) or GCC High environments as the cornerstone of their CMMC compliance strategy. It’s particularly suited for businesses where most employees in their organization handle Controlled Unclassified Information (CUI) and get a large portion of revenue from government contracts.

How it works: This approach involves a full migration or optimization of your IT infrastructure within the chosen Microsoft government cloud environment (GCC or GCC High). Our teams will assist with eligibility validation and licensing, then meticulously configure and implement all necessary Microsoft 365 and Azure services to meet CMMC and NIST SP 800-171 controls.

This includes formalizing security policies aligned with government regulations, deploying advanced security tools like Managed Detection and Response (MDR) and Security Information and Event Management (SIEM), and establishing robust policies and procedures. The “all-in” aspect means a comprehensive transition to or build-out within these environments, ensuring all in-scope data and systems reside and operate compliantly within the Microsoft cloud.

Key Benefits:

  • Holistic Compliance: Provides a robust platform that inherently supports a significant portion of CMMC, DFARS, and ITAR compliance requirements, particularly related to data sovereignty.
  • Leveraged Security: Benefits from Microsoft’s extensive security infrastructure, continuous updates, and compliance certifications (e.g., FedRAMP High), reducing your individual burden.
  • Streamlined Operations: Centralizes data and applications within a single, highly secure environment, simplifying management and reducing the attack surface.
  • Expert Guidance: Our teams provide hands-on support for complex migrations and configurations, ensuring proper alignment with audit expectations and maximizing the benefits of the GCC/GCC High ecosystem.

3. The Enclave Solution Path (VDI or Third-Party Tool)

This path offers a targeted approach to CMMC compliance by creating a segregated, highly secure “enclave” specifically for handling CUI and other sensitive data. It’s an excellent option for organizations that wish to minimize the scope of their CMMC compliance efforts, protect sensitive data without overhauling their entire IT environment, or leverage specialized third-party tools. This includes Virtual Desktop Infrastructure (VDI) or other purpose-built secure environments.

How it works: Instead of re-architecting your entire corporate network, this strategy focuses on building a distinct, isolated environment (the “enclave”) where all CUI processing, storage, and transmission occur. This could involve:

  • Virtual Desktop Infrastructure (VDI): Implementing a VDI solution where users access a secure, virtualized desktop environment that is fully compliant with CMMC controls. All CUI interactions are confined to this VDI, allowing the broader corporate network to remain outside the direct CMMC scope.
  • Third-Party Secure Enclave Tools: Utilizing a specialized third-party solution (often a Software-as-a-Service or Managed Security Service) that provides a pre-built,
    CMMC-compliant environment for handling sensitive data. These tools typically offer features like secure file sharing, collaboration, and application access within their isolated platform.

Our role involves designing, implementing, and managing this enclave, ensuring strict access controls, data flow restrictions, and the application of all relevant CMMC practices within this contained environment. This often includes integrating with your existing identity management and security tools while maintaining logical and physical separation from non-enclave systems.

Key Benefits:

  • Scope Reduction: Significantly limits the scope of your CMMC assessment by isolating CUI to a controlled environment, reducing the overall effort and cost of compliance.
  • Rapid Deployment: Enclave solutions, especially those provided by third-party tools, can often be deployed more quickly than a full enterprise-wide security overhaul.
  • Enhanced Security: Provides a highly hardened and monitored environment specifically designed to protect sensitive data from advanced threats.
  • Simplified Management: Reduces the burden of continuous compliance management by leveraging specialized tools and potentially external expertise to maintain the enclave’s security posture.

How to Choose Your Path

Choosing the right path begins with asking the right questions. Do you know how many employees handle sensitive data? What kind of data do you handle—just FCI, or also CUI or ITAR? How much internal capacity do you have to support a rollout? And how soon do you need to be fully compliant?

The answers to these questions will point you toward the most logical and cost-effective path. More importantly, they’ll help prevent delays, overspending, and uncertainty as you navigate the CMMC landscape.

And remember: CMMC isn’t just about passing an audit. It’s about protecting your business, securing your data, and reinforcing your role as a trusted partner in the defense supply chain.

Final Thoughts: Make Your First Call Count

Choosing your CMMC implementation strategy is more than a technical decision—it’s a business-critical move. A well-executed plan can open doors to new contracts, enhance your operational maturity, and build long-term resilience. A misstep, however, could lead to lost opportunities, compliance risks, or lots of wasted time and money.

That’s why FirstCall Consulting is here. Whether you’re mapping your first steps, upgrading your infrastructure, or looking for a fully managed solution, we offer the clarity, expertise, and speed you need to move forward with confidence.

🎯 Book a free 30-minute strategy call with a CMMC specialist → BOOK NOW