Your CRM Can Make or Break Your CMMC Success
In this episode, Kaleigh and Bobby shine a spotlight on a frequently misunderstood but critical tool in the CMMC compliance journey: a Customer Responsibility Matrix (CRM).
What Does a CMMC CRM Look Like?
A Customer Responsibility Matrix (CRM) outlines the division of responsibility between an organization and its service providers. This is especially important when third-party vendors are involved in handling Controlled Unclassified Information (CUI). In the context of CMMC, a well-structured CRM ensures that all security obligations are clearly defined, assigned, and traceable. It isn’t just an organizational tool; it’s a 32 CFR requirement: “the security requirements from the Customer Responsibility Matrix (CRM) must be documented or referred to in the OSA’s System Security Plan (SSP)” (83228).
Why CRMs Are Critical for CMMC Compliance
CRMs shouldn’t be treated as an optional CMMC requirement. Not just because they are not optional at all, but also because they are a strategic blueprint in your journey towards compliance. Under NIST 800-171, which forms the backbone of CMMC requirements, organizations must prove not just that the controls are in place, but also who is responsible for maintaining and implementing them.
Even if you use Cloud Service Providers (CSPs), Established Service Providers (ESPs), or external consultants, your organization is still fully responsible for meeting all compliance objectives. That’s why a detailed CRM is essential. Because it prevents ambiguity, reduces risk, and helps avoid compliance gaps during an assessment.
Key Takeaways for Building an Effective CRM:
- Start with What You Deliver: Before creating a CRM, clearly define your system’s scope and the services you provide. Know what data is being processed, who touches it, and where it’s stored.
- Align with NIST 800-171a Controls: Your CRM should directly align with the assessment objectives listed in NIST 800-171a. Whether executed internally or outsourced, each responsibility must be accounted for.
- Account for Multiple CRMs: Depending on how many vendors or services you rely on, you may need more than one CRM. Each should reflect the specific storage responsibilities of that relationship. Also, be sure to clearly define how third-party vendors or consultants will support/implement security controls.
- Clarify Execution, Not Just Ownership: A strong CRM doesn’t just list who owns each control. It also describes how the control will be executed, including: tools, timelines, and oversight processes.
Your CMMC Strategy Starts Here
A vague CRM creates risk. A clear, detailed system helps your team understand its obligations and gives assessors confidence in your maturity level. So, if you’re prepping for a CMMC assessment, be prepared to put CRMs at the forefront of your mind. Because it can be one of the most powerful tools in your compliance toolkit.
For more information, reach out to us or check out our Climbing Mount CMMC podcast.