3 Risks of Overlooking CUI Scoping for CMMC

Identifying how and where Controlled Unclassified Information (CUI) is stored, transmitted, and processed within your organization is a critical first step to achieving CMMC compliance. Many organizations overlook this step, however, leading to gap assessment fatigue, unwanted costs, and a lack of leadership and organizational buy-in. 

In this article, we’ll break down everything you need to know about CUI scoping for CMMC, including: 

• What is scoping for CMMC? 
• Why is identifying your system boundaries necessary for achieving CMMC compliance? 
• What are the risks of not completing a CUI scoping exercise? 

What is CUI Scoping for CMMC? 

Scoping for CMMC is the process of identifying how and where CUI is stored, transmitted, and processed within an organization. Organizations must conduct an in-depth investigation into their systems and personnel to: 

• Identify how CUI enters, leaves, and flows throughout their organization. 
• Identify the people, processes, and technology that interact with or create CUI. 
• Develop conceptual diagrams and documents illustrating this data flow. 

Why is Scoping Needed? 

Clearly defining the areas of your organization that touch CUI is a foundational step to determining which areas of your organization are required to adhere to NIST 800-171. A scoping analysis provides you with system-boundary and data-flow diagrams that will serve as your blueprint for all other stages of compliance, including security gap assessments, remediation services, and the C3PAO assessment. 

3 Risks of Overlooking CUI Scoping for CMMC  

1. Underestimating the Scope of Your CUI, Leading to Costly Surprises

When an organization assumes it knows where its CUI is without conducting a proper investigation, there’s a high risk that certain CUI will go overlooked and, subsequently, unprotected. This can lead to audit failures, delays in certification, additional costs, and critical security weaknesses. 

For instance, organizations that have set up Cloud enclaves for their CUI may assume that no CUI is being transmitted out of the enclave. However, this isn’t always the case – we recently helped a client discover that several employees were transferring CUI out of the enclave and accessing it in out-of-scope applications, expanding the organization’s CMMC scope by 100%. 

In virtually every instance where 112Cyber’s has provided advisory services to organizations that have overlooked scoping, at some point later in the process, additional locations of CUI are uncovered. When this occurs, time and cost estimates are always expanded, and IT and security owners are always placed in the unenviable position of needing to request additional funding.

Conducting a CUI scoping exercise minimizes costly surprises and provides more cost certainty to C-level executives and boards of directors.

2. Overestimating the Scope of Your CUI, Leading to Unnecessary Investments

Organizations that don’t properly map out their CUI also commonly make their scope larger than it needs to be, resulting in excessive spending and resource allocation. Implementing NIST 800-171 security controls across business areas that don’t require them can be costly and inefficient, as time, money, and personnel are diverted from critical areas to less important ones. 

For example, we recently helped a client: 

• Determine that over 400 users did not require logical access to a CUI enclave, saving duplicate Microsoft licensing costs of 130%. 
• Identify five satellite offices that did not store, transmit, or process CUI, resulting in significant savings in physical security and media handling. 
• Reduce the percentage of resource-intensive software and specialized-equipment assets that required CMMC compliance to 40%, resulting in significant VDI infrastructure savings.

Analyzing and mapping out exactly how and where CUI exists in your systems allows you strategically prioritize InfoSec and compliance investments based on risk. By identifying those specific components of your environment that contain CUI, you can limit those areas of your systems and business that are subject to CMMC compliance — reducing the overall cost of meeting the CMMC compliance mandate.

3. Misalignment with Business Objectives

When building a strategy to protect CUI, it’s crucial to align it with your organization’s business objectives to ensure cultural buy-in and success. Misalignment can lead to over-engineered or poorly integrated solutions that negatively impact business operations, resulting in wasted investment, user shortcuts, and increased security and data leakage risks. 

Conducting a CUI scoping analysis allows you to gain insight into how your CMMC program might impact day-to-day operations. Balancing security and usability to minimize disruption is key and often requires tailored solutions to meet your organization’s unique needs. 

While implementing cybersecurity controls and maintaining compliance are critical, the long-term success of cybersecurity investments depends on alignment with operational continuity of users handling sensitive data. 

Get Started with Scoping Your CUI for CMMC 

Whether you’re just starting your CMMC journey and are unsure of where to start, are struggling to understand what CUI is and where it’s located in your organization, or want to minimize the areas of your environment subject to compliance, 112Cyber’s CUI scoping, or CUI Data Mapping, service is here to help. 

Our Certified CMMC Professionals and Assessors will investigate your environment to trace where CUI enters, leaves, and flows. From there, we’ll provide suggestions on how to reduce and centralize this data flow, leaving you with fewer areas subject to compliance.