Certified but Unable to Build: The Hidden Risk of Underscoped CMMC Enclaves (W02d)
Many companies are pursuing CMMC Level 2 by building the smallest possible enclave that can pass an assessment. That strategy may appear efficient, but it can create a serious business and legal trap: the “certified” environment may not actually support the work required under the contract. This talk will examine why CMMC scope must be driven by actual contract performance, not by the narrowest technical boundary an organization can defend during an assessment. Drawing on lessons from manufacturers, primes, and the defense supply chain, it will discuss how CUI moves through contracts, engineering, program management, supply chains, email, ERP/MES systems, file transfer, and production equipment. The central question is simple: Can the company actually receive, process, share, manufacture, and deliver using only systems inside its authorized CMMC scope?
If the answer is no, the organization faces more than an operational problem. A company that relies on a small certified enclave to win or retain a contract while knowingly performing the actual work on noncertified systems may be creating an intentional compliance gap with False Claims Act implications. The talk will help attendees recognize underscoping risks, ask the right cross-functional questions, and align CMMC boundaries with actual business data flows before the assessment—not after contract execution exposes the mismatch.