What an SSP should include
To begin building your CMMC SSP template, you first need to determine what compliance tier your organization must meet, based on the type of data you handle. Level 1 compliance applies to organizations processing federal contract information (FCI). This level requires an annual self-assessment and a formal affirmation that the organization has implemented 17 basic security practices.
Level 2 is the standard for the vast majority of the defense industrial base (DIB), as it applies to any contractor that handles controlled unclassified information (CUI). This level aligns with the 110 security requirements of NIST SP 800-171. Level 2 SSPs are significantly more detailed, as they are the basis for a triennial assessment conducted by a CMMC third-party assessment organization (C3PAO). (In certain non-prioritized cases, a rigorous self-assessment is permitted.)
Level 3 is reserved for the most sensitive programs. In addition to the 110 requirements of Level 2, contractors must implement 24 selected requirements from NIST SP 800-172. These assessments are conducted directly by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
System boundaries and in-scope assets
The most critical step in developing an SSP for CMMC is defining the scope of the assessment. Inaccurately defined boundaries can lead to audit failure and significant cost overruns. To prevent this, categorize all assets based on their relationship with CUI.
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CUI assets: Systems, devices, and applications that store, process, or transmit CUI (e.g., servers hosting project data, employee laptops that access CUI repositories).
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Security protection assets: Assets that provide security functions to the CUI environment, even if they do not hold CUI themselves (e.g., firewalls, security information and event management [SIEM] systems).
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Specialized assets and contractor risk managed assets (CRMA): Depending on the environment, organizations may also need to identify specialized assets (e.g., OT, IoT, test equipment) and CRMA, which are treated differently during assessment but must still be documented.
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Out-of-scope assets: Systems that are logically or physically separated from the CUI environment and have no interaction with sensitive data (e.g., HR payroll, marketing websites).
Documenting control implementation
The core of an SSP is the detailed description of how each of the 110 NIST SP 800-171 requirements is satisfied. This is where many organizations stumble, providing generic statements that don’t meet assessors’ "testable" standard. A comprehensive description answers the “reporter’s questions:” who, what, when, and how (where is implied).
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Who: The specific role or party responsible for the action.
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What: The specific security action or behavior being performed.
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When: The frequency or the trigger for the action.
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How: The specific tools, configurations, or technologies used.
Each control implementation description must be mapped to the 320 assessment objectives outlined in the companion document NIST SP 800-171A. The best CMMC SSP examples explicitly tie together how the tools, policies, and processes support controls, demonstrating a coherent security strategy.