Information Technology Navigator

Defense contractors facing CMMC compliance have a fundamental architecture decision to make before they spend a dollar on licensing or migration services. Should you move your entire organization into a Microsoft 365 GCC High tenant, or should you build a CMMC enclave that isolates only the users and systems that handle Controlled Unclassified Information (CUI)? The answer depends on how much of your business actually touches regulated data, what your contracts require, and how much complexity your IT team can realistically manage.

This guide compares both approaches so you can make the right call for your organization's compliance posture, budget, and operations.

Key Insights: What You Need to Know About CMMC Enclave vs. Full GCC High Migration

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If your organization handles Controlled Unclassified Information (CUI) under a Department of Defense contract, you already know that Microsoft 365 GCC High is the cloud environment built for your situation. What most defense contractors underestimate is the true GCC High cost once you move past the per-user license fee and into the full picture of migration, operations, and long-term compliance.

This guide breaks down what GCC High actually costs for defense contractors, which Microsoft licensing options apply, and where the budget surprises tend to hide.

Key Insights: What You Need to Know About GCC High Cost and Licensing

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Defense contractors handling sensitive government data face a critical infrastructure decision that directly affects their eligibility for DoD contracts. Microsoft GCC High has emerged as the de facto standard cloud environment for organizations in the Defense Industrial Base working with Controlled Unclassified Information (CUI) and export-controlled data. If you're evaluating cloud platforms for CMMC compliance or wondering whether your current Microsoft 365 setup meets DoD requirements, understanding the distinction between GCC High and other Microsoft cloud offerings isn't optional-it's essential to your contract eligibility.

Key Insights for Defense Industrial Base (DIB) Compliance

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On October 15, 2024, the final rule for the Cybersecurity Maturity Model Certification (CMMC) program was officially published. This rule, codified as 32 CFR, becomes effective on December 16, 2024. The CMMC journey began in 2019 with DFARS Case 2019-D041, and after four years of development, the rule is now finalized. Let’s take a look at the history of the CMMC timeline, what's to come, and how organizations can prepare for what is next.

CMMC Rulemaking Timeline

The rulemaking process illustrated in the graphic below shows a high-level workflow from the Government Accountability Office (GAO).

Figure 1: GAO Federal Rulemaking

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Protecting sensitive and classified information when working for the Federal Government requires constant vigilance. When the government issues a contract, it must specify to the performing contractor when covered defense information (CDI) or controlled unclassified information (CDI) will be generated under the contract. Many prime contractors “flowdown” every FAR and DFARS clause to subcontractors and vendors without considering if that subcontractor or vendor will be processing, storing, or transmitting CDI. Anticipating where CDI may reside once awarded a contract can be a challenge. Here is guidance on ways CDI can flowdown to subcontractors and the defense industrial base (DIB), and steps those organizations should take before signing an agreement.

An Introduction to DFARS

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Many companies are currently evaluating how they might fund initiatives necessary to move their businesses towards compliance with the Cybersecurity Maturity Model Certification (CMMC). There are a few ways to fund these initiatives, but many key items have the potential to impact the amount of funding needed to prepare your organization for certification. So, where do you start to appropriately scope the project, and how do you know how much it will actually cost?

Whether your company plans to meet the CMMC objectives or to stop doing business with the Federal Government, keep in mind that cybersecurity is an important part of maintaining your business health and ensuring resiliency in the future. When businesses suffer a cyberattack and cannot afford the cost to recover, they often go bankrupt. In addition to the new federal regulations being pushed out by the Defense Federal Acquisition Regulations (DFARS), many states have laws requiring levels of protection for different types of information. Other federal governments have also enacted cybersecurity protection measures for their citizens (such as GDPR). Not doing so can also leave you open to lawsuits in the event of a breach or incident.

5 Phases for Cybersecurity Compliance

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Given the current cyber threat landscape, protecting data has never been more critical. We’ve been helping organizations architect and deploy secure data center and cloud environments for over 20 years. We are a Microsoft Gold Partner, Tier 1 Microsoft Direct Cloud Service Provider and AOS-G, GCC and GCC High reseller. We have the proven expertise and technical certifications to design, implement and provide on-going support for highly customized secure enclaves or “greenfield” environments in Microsoft Azure, Azure Government, and Microsoft 365 Commercial and Government community clouds to meet compliance requirements of NIST 800-171 and CMMC 2.0. We can help your team jumpstart the adoption of a cloud platform with Microsoft 365 and Azure.

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If your organization has been working towards NIST 800-171 and is now on the journey to achieve CMMC 2.0 (the Cybersecurity Maturity Model Certification) it can be difficult to understand what you’ve already achieved and what’s left to do. Both standards are intended to reduce threats and strengthen cybersecurity for sensitive government data. Here’s some details on how they relate to each other and what’s involved to take the next steps toward CMMC compliance.

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Microsoft’s Azure Government has become a trusted cloud for US government agencies, contractors and the Defense Industrial Based (DIB), providing unified security to protect the nation's data, and solutions for secure remote collaboration. Microsoft’s Azure Government uses the same underlying technologies as Azure, which includes the core components of Infrastructure-as-a-Service (IaaS), Platform-as-a-Service (PaaS), and Software-as-a-Service (SaaS). The increased security is achieved because it is a physically isolated sovereign cloud environment dedicated to US federal, state, local, and tribal governments, and their partners. It provides an extra layer of protection to mission-critical workloads through contractual commitments regarding storage of customer data that is subject to various US government regulations such as Export Administration Regulations (EAR) and International Traffic in Arms (ITAR). Azure Government offers additional security by relying on screened US personnel.

Azure Government and CMMC

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The Cybersecurity Maturity Model Certification (CMMC) Framework is used by the DoD to verify that sensitive data being handled by defense industrial base (DIB) contractors is properly protected on the contractors’ systems to avoid risk of a compromise from a cybersecurity attack. CMMC uses third-party assessment organizations to verify contractors’ safeguarding of controlled unclassified information (CUI) including International Traffic in Arms Regulations (ITAR) data, federal contract information (FCI), and compliance with certain mandatory practices, procedures and capabilities that can adapt to evolving cyber threats.

What’s New in CMMC 2.0

In November 2021, the DoD announced CMMC 2.0. It’s important to understand key changes and timelines associated with CMMC 2.0, how it compares to CMMC 1.0, and what you need to do to prepare. 

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