November 4, 2025
While both the Cybersecurity Maturity Model Certification (CMMC) and the Federal Risk and Authorization Management Program (FedRAMP) strengthen federal information security, they were created for different missions.
CMMC protects Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) throughout the defense supply chain. FedRAMP standardizes how cloud services used by federal agencies are assessed, authorized, and continuously monitored.
Defense contractors and cloud service providers often find that these frameworks intersect in practice. Understanding how they relate helps organizations align security controls, manage risk, and avoid duplicating effort.
This guide explains each framework’s purpose, scope, and process, then compares their key differences and overlaps to help organizations navigate federal compliance with clarity and confidence.
What Is CMMC?
The Department of Defense (DoD) developed CMMC to ensure every organization within the Defense Industrial Base (DIB) safeguards CUI and FCI. It combines multiple requirements (most notably NIST SP 800-171 and DFARS 252.204-7012) into one enforceable program for DoD contractors and subcontractors.
CMMC 2.0 Tiers
CMMC 2.0 simplifies the original five-tier model into three levels:
- Level 1 – Foundational: 15 basic cybersecurity practices that protect FCI.
- Level 2 – Advanced: Aligns with the 110 controls in NIST SP 800-171, focused on CUI.
- Level 3 – Expert: Adds select requirements from NIST SP 800-172 for high-priority defense missions.
Who Must Comply With CMMC?
Any organization that stores, processes, or transmits CUI or FCI for the DoD — whether on-premises, in a private cloud, or through a hybrid architecture — must certify to the level specified by its contract. That includes prime contractors, manufacturers, and specialized service providers throughout the DIB.
Assessment Requirements
Compliance is verified through periodic assessments and affirmations:
- Level 1: Annual self-assessment with affirmation in the Supplier Performance Risk System (SPRS).
- Levels 2: Either an annual self-assessment or a triennial C3PAO certification (depending on contract requirements), plus annual affirmations.
- Level 3: Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) assessment every three years with annual affirmations..
CMMC certification levels are tied to contract language and the sensitivity of information handled. While CMMC applies to on-prem and hybrid systems, cloud environments supporting DoD contracts must demonstrate compliance with the DoD Cloud Security Requirements Guide (SRG) or FedRAMP Equivalency.
Equivalency allows DoD to accept cloud services that meet FedRAMP and additional SRG controls when formal FedRAMP authorization is not feasible for DoD-specific systems. It does not replace CMMC for contractors operating on-prem or hybrid networks with CUI or FCI.
What Is FedRAMP?
The Federal Risk and Authorization Management Program creates a uniform approach for securing cloud services used by federal agencies. Administered by the FedRAMP Program Management Office (PMO) under the General Services Administration (GSA) and supported by the Joint Authorization Board (JAB), FedRAMP standardizes security assessment, authorization, and continuous monitoring across agencies.
FedRAMP applies only to cloud systems and assigns impact levels (low, moderate, and high) based on FIPS 199 classifications for confidentiality, integrity, and availability. The corresponding controls derive from NIST SP 800-53:
- Low: Basic safeguards for public or low-impact data.
- Moderate: Enhanced controls for sensitive information such as PII or PHI.
- High: Comprehensive controls for mission-critical systems.
By law, agencies must use FedRAMP-authorized cloud services for commercial adoption. Any cloud service provider (CSP) that wants to do business with the federal government must obtain authorization for each specific cloud service offering (CSO).
FedRAMP Authorization Process
Here’s a quick overview of the authorization process:
- Readiness Assessment: Evaluates whether the CSP is prepared for formal review.
- Full Security Assessment: Performed by an accredited Third Party Assessment Organization (3PAO).
- Authorization to Operate (ATO): Granted by either a sponsoring agency.
Authorization is not a one-time event. CSPs must submit monthly vulnerability scans, timely incident reports, and annual assessment packages to maintain status. This ongoing oversight ensures controls adapt to system changes and emerging threats.
CMMC vs. FedRAMP: Key Differences and Similarities
To understand how these frameworks interact in practice, it helps to look at where they diverge and overlap:
Scope & Audience
CMMC governs the defense industrial base, covering any organization that handles CUI or FCI in on-prem or hybrid environments. Within hybrid architectures, the on-prem segment is subject to CMMC, while cloud components must meet DoD SRG or FedRAMP Equivalency standards.
FedRAMP applies to cloud service offerings used by civilian agencies and authorizes each specific service rather than the provider’s entire enterprise environment.
Control Frameworks
Both programs are built on NIST principles but differ in implementation:
- FedRAMP: Applies hundreds of controls from NIST SP 800-53, with specific baselines for each impact level.
- CMMC: Level 2 maps to the 110 requirements of NIST SP 800-171; Level 3 adds selected enhancements from SP 800-172.
Organizations can reuse overlapping controls, such as access management or incident response, if they meet the most restrictive standard across frameworks. Alignment should focus on control intent rather than format to maintain validity under both.
Assessment & Authorization Process
CMMC Level 2 may require either an annual self-assessment or a triennial C3PAO assessment, depending on contract language. Level 3 assessments are performed by DIBCAC every three years.
FedRAMP requires 3PAO assessments that feed into an agency decision to grant an ATO; the JAB may issue a P-ATO that agencies can leverage.
Both rely on independent assessment organizations and place continuous oversight at the center of their lifecycles.
Reuse and Reciprocity
Despite their shared roots in NIST controls, no formal reciprocity exists between CMMC and FedRAMP. Artifacts may be reused only if they satisfy each framework’s documentation and control requirements and the stricter implementation intent. Organizations should carefully align system boundaries and evidence to prevent gaps or redundant work.
Cost, Time, and Complexity
Both frameworks demand significant resources, but FedRAMP typically requires more time and investment — often 12 to 18 months and substantial budget commitment for Moderate or High baselines. CMMC Level 2 certifications commonly span eight to 18 months; Level 1 self-assessments take less time, while Level 3 may extend beyond 18 months with greater cost.
Organizations that complete FedRAMP first often gain momentum for CMMC since many controls and policies already exist in mature form.
Which Framework Should Your Organization Consider?
Determining the right path starts with understanding three factors: your federal customer base, the information you handle, and where that data resides.
- If you serve the DoD and manage CUI or FCI on-prem or in hybrid systems: CMMC is required.
- If you offer cloud services to civilian agencies: FedRAMP authorization applies.
- If you operate a DoD-centric hybrid solution: The cloud portion must meet DoD SRG or FedRAMP Equivalency standards, while on-prem components remain under CMMC.
No single system can hold both a CMMC certificate and a FedRAMP ATO. Instead, organizations design separate boundaries or leverage common controls across frameworks.
Mapping business objectives and contract clauses, such as DFARS requirements, helps identify whether CMMC, DoD Equivalency, or FedRAMP applies. Once requirements are clear, compare existing controls to both frameworks and document how shared controls satisfy the strictest parameters first. This reduces rework and creates a more coherent compliance program.
Boundary alignment is often a bigger risk than missing controls. Misaligned evidence packages can trigger months of remediation and delay contract eligibility. Thorough documentation and independent readiness reviews mitigate that risk well before a formal assessment begins.
Frequently Asked Questions
Can FedRAMP replace CMMC?
No. FedRAMP authorization does not satisfy the DoD’s CMMC requirement. Even if a provider operates a FedRAMP-authorized cloud service, contractors must still undergo a CMMC assessment for any on-prem or hybrid systems handling CUI or FCI.
Do both require continuous monitoring?
Yes. Ongoing monitoring, evidence collection, and control updates are central to sustaining compliance for both CMMC and FedRAMP.
How often are reassessments required?
CMMC Level 2 and Level 3 certifications require reassessment every three years, with annual affirmations in SPRS to confirm controls remain effective. Some Level 2 contracts may allow self-assessments each year instead of a C3PAO review.
Can documentation be reused between the two?
Yes, in some cases, such as policies and procedures documentation that does not require FedRAMP-provided templates, providers can use these documents for both the CMMC and FedRAMP system only when they meet all FedRAMP requirements for format and control parameters.
Next Steps: Preparing With Insight Assurance
Early gap analysis and clear documentation are essential for successful CMMC and FedRAMP assessments. Organizations benefit from objective evaluation that clarifies alignment requirements before formal fieldwork begins.
Insight Assurance offers:
- Independent readiness reviews for CMMC, FedRAMP, and DoD FedRAMP Equivalency
- Objective assessment services to validate alignment with federal frameworks
- Detailed reporting that supports audit preparation and documentation accuracy
- Dedicated assessment teams and responsive communication throughout the process
Whether your goal is a CMMC Level 2 certification or a FedRAMP Moderate authorization, Insight Assurance provides the independent assessments and transparent reporting needed to validate and document your compliance posture.
Ready to take the next step? Contact Insight Assurance to request an independent readiness review or learn more about our CMMC, FedRAMP, SOC 2, and ISO/IEC 27001 assessment services.
