Global Tech OSC Achieves Level 2 Final Status
Overcoming Failing SPRS Score to Renew Standing in a Multi-Billion Dollar DoD Contract Re-Compete
Executive Summary: A CMMC Implementation Strategies Case Study
This CMMC implementation strategies case study details how a global advanced defense software and manufacturing company successfully navigated the CMMC Level 2 certification process. This achievement in CMMC compliance enabled them to renew their standing in their contract recompete. They overcame a failing SPRS score and the steep challenges of the company’s complex, multi-divisional structure with expansive Controlled Unclassified Information (CUI) scope. KLC Consulting’s (KLC) expertise with Secure Software Development Lifecycle (SSDLC) was one of several keys to this success.
That specialized knowledge underpinned KLC’s initial C3PAO Mock Assessment, which identified key CUI scoping and CMMC compliance deficiencies. Our findings provided this Organization Seeking Certification (OSC) with the insight needed to self-remediate while KLC maintained DoD-mandated C3PAO independence. The OSC’s SPRS score improved dramatically from a failing score of 80 to a perfect score of 110, culminating in their CMMC Level 2 certification.
About the Organization Seeking Certification (OSC) and Its CMMC Compliance Journey
- Industry: Advanced Defense Software & Manufacturing
- Company Size: A global leader with over 20,000 employees and a hierarchy of multiple CAGE Codes.
- Key Challenge: Achieving CMMC Level 2 compliance by early 2025 was critical to securing their standing in a multi-billion-dollar DoD contract due for recompete; certification in CMMC, currently held by fewer than 1% of its industry peers, provides a compelling competitive advantage.
- CMMC Scope: A complex, multi-division enterprise encompassing five U.S.-based facilities and over 800 users handling CUI. Operations include hybrid infrastructure (Azure GCC High and on-premises IT), manufacturing facilities, and extensive software development and production environments that utilize custom APIs to serve CUI to external customers.
The CMMC Level 2 Challenge: Complexities and Critical Demands
The company began its CMMC Level 2 certification journey under intense pressure with several inherent complexities:
- Urgent, High-Stakes Timeline: The CMMC Level 2 certification was time-sensitive and directly tied to the OSC’s standing in a crucial multi-billion-dollar DoD contract recompete. Delay or failure directly threatened a huge contract loss.
- Complex Environment Demanding specialized CMMC Assessment Expertise: The sheer scale and diversity of the OSC’s operational environment, as previously outlined (five U.S. facilities, over 800 users, hybrid systems, and multiple development pipelines), presented daunting CMMC Assessment challenges that demanded rare and highly specialized C3PAO expertise.
- Specialized Software Security Needs for CMMC Compliance: As a provider of advanced software, including APIs that deliver CUI externally, robust SSDLC practices and software security controls were paramount for CMMC Compliance. The OSC required a C3PAO with expertise in software security to accurately evaluate their development and DevSecOps processes.
- No Room for Surprises: Given the heavy implications of the DoD contract, the OSC demanded assurance that unforeseen issues would not jeopardize the certification timeline.
- Pervasive Sensitive Data: The Assessment required validating protections for a wide array of enterprise assets, including source code with CUI.
Needing rare, specialized expertise to overcome these challenges, the OSC chose KLC Consulting, Inc. as its C3PAO to conduct its official CMMC Level 2 Assessment, preceded by a strategic Mock CMMC Assessment.
KLC Consulting’s CMMC Certification Strategy: A Two-Phased Assessment Approach Designed for Success
KLC Consulting employed a strategic two-phased Assessment approach, maintaining DoD-mandated C3PAO independence throughout the engagement.
Phase 1: The Mock CMMC Assessment Illuminates the path to CMMC Compliance
KLC Consulting’s CMMC Mock Assessment illuminates the path to compliance by providing a realistic simulation of an official CMMC Level 2 Certification Assessment. It’s like the full-contact scrimmage teams play to prepare for an in-season game. This lower-priced practice-run assessment brings the full intensity and scrutiny of Official CMMC Level 2 assessment, identifying and explaining deficiencies from an independent C3PAO perspective. It’s designed to empower your team’s self-remediation efforts through lessons learned and build confidence for success in your official Level 2 assessment.
Key Focus Areas: KLC’s assessors devoted particular attention to the OSC’s SSDLC practices, the handling of CUI within the development lifecycle (including version control, code storage, and build pipelines), the intricacies of their hybrid cloud (Azure GCC High), and on-premises infrastructure.
Deficiencies Identified: The Mock Assessment revealed specific deficiencies and explained why they caused non-compliance with CMMC Level 2 requirements. The most serious deficiencies include:
| Missing Software Process | CUI was present in source code and development processes were established, but the SSP failed to detail software development and change management procedures. |
| Incomplete Baseline | The configuration baseline did not encompass the hardware and software of the software support infrastructure. |
| Undefined CUI Incident Reporting | The SSP failed to outline a specific incident reporting process for CUI. |
| Unsynchronized Clock Issue | In-scope system clocks were not synchronized as specified in the CMMC Assessment Guide. |
| Incomplete CSP Inheritance | The SSP lacked documentation for some Cloud Service Provider (CSP) inheritances. |
| Unsecure File Sharing System | The file sharing system lacked FIPS validation and Multi-Factor Authentication (MFA). |
| Inconsistent Vulnerability Scanning | The frequency of vulnerability scans did not align with established policies and procedures. |
Failing Initial SPRS Score: The Mock Assessment determined an initial failing Assessment score of 80, a finding of wide-ranging CMMC compliance gaps.
Empowered Self-Remediation: Using KLC Consulting’s detailed Mock Assessment findings, the OSC undertook improvements and self-remediated identified deficiencies. As a result, they confidently entered their formal certification Assessment knowing they were aligned with CMMC requirements.
Phase 2: The Official Assessment Conveys CMMC Level 2 Certification
After the OSC completed CMMC self-remediation utilizing KLC’s Mock Assessment findings, the engagement transitioned to Phase 2: the official CMMC Level 2 certification Assessment, delivered by authorized C3PAO KLC Consulting. KLC tailored its methodology to the OSC’s unique scale and complexity:
- Cross-Functional Engagement: To ensure full coverage, KLC’s CMMC certified assessors (CCAs) engaged with all OSC’s relevant stakeholder groups, spanning IT, security, manufacturing, and software development units.
- Full Scope Verification: Assessors scrutinized the OSC’s CUI boundary and scoping documents to validate data flows, confirming the inclusion of all applicable systems, users, and third-party vendors.
- SSDLC and Software Environment Evaluation: The assessment team evaluated the OSC’s SSDLC practices and interviewed software engineering teams to confirm alignment with the CMMC Level 2 requirements for handling CUI within Development lifecycles.
- Hybrid Cloud & On-Prem Assessment Expertise: KLC validated compliance across on-premises systems and the Azure GCC High environment, reviewing inherited FedRAMP security responsibilities and customer-specific obligations.
- Specialized Expert Assessment Team: KLC utilized CCAs with deep expertise in complex defense contracting environments, specifically in large-scale IT and secure software development operations, ensuring efficient and effective technical assessment execution.
The Result: CMMC Level 2 Certification Success and Renewed DoD Standing
This C3PAO Assessment engagement with KLC Consulting culminated in the following critical achievements for this global technology company:
| Perfect SPRS Score – 110 | Following the Mock Assessment determinations, the OSC self-remediated their compliance deficiencies. This led to an improvement in their SPRS score from a failing score of 80 to a perfect score of 110 in the official Assessment, validating that all required CMMC practices were met. |
| Achieved CMMC Level 2 Certification | A Case Study in Compliance Success, this OSC successfully obtained its Certificate of CMMC Level 2 Final Status, meeting all requirements without conditions or delays. A milestone achievement in CMMC compliance. |
| Renewed Contract Standing and Enhanced Overall Status | The CMMC Level 2 certification reaffirmed the company’s standing in its critical multi-billion-dollar DoD contract recompete. It also strengthened their stature in other DoD CUI-related opportunities. |
| A Foundation for CMMC Level 3 | Achieving CMMC Level 2 provides the OSC with the requisite foundation to pursue CMMC Level 3 should future contractual needs arise. |
The Conclusion
This CMMC certification case study demonstrates how this global technology company reaffirmed its standing in a crucial DoD contract and strengthened its position as a leading industry partner with the Department of Defense. KLC Consulting’s deep SSDLC expertise with multi-divisional hierarchies and strategic two-phased CMMC assessment approach were the keys to transform an initial fail to a perfect SPRS score. This CMMC implementation lessons learned case study highlights the value that a C3PAO with industry-specific expertise brings to successfully navigating today’s complex CMMC landscape and achieving CMMC success.
“KLC Consulting was the right C3PAO for us”
A STATEMENT OF RELIEF AND APPRECIATION
Why KLC Consulting is the Right C3PAO for You
We understand the natural apprehension people feel going into their high-stakes CMMC assessment. You worry you’ll get the invasive “gotcha!” type of auditor. At KLC Consulting, our warm, interactive assessment style alleviates that concern. Our assessment philosophy is to be the objective C3PAO that validates your demonstrated security practices without digging deeper in search of flaws, ensuring an assessment delivered with a clear understanding and the human touch.
Assessing organizations that develop software for Department of Defense applications requires rare, specialized knowledge. KLC Consulting possesses deep expertise in evaluating SSDLCs and DevSecOps environments. We understand precisely how CUI should be handled and protected within codebases, design specifications, and continuous integration/delivery pipelines. Our depth of knowledge far exceeds foundational C3PAO requirements and the capabilities of most C3PAOs in the marketplace today, ensuring a precise assessment for even the most advanced operational contexts.
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