OSC — How do I implement?

Advisory • Assurance • Audit — The Foundation of Readiness

Microsoft 365 Commercial cannot lawfully store CUI. DFARS 7012(b)(2)(ii)(D) requires FedRAMP Moderate or equivalent for any cloud service handling covered defense information, and the M365 productivity services in Commercial (Exchange Online, SharePoint Online, OneDrive for Business, Teams) are not FedRAMP Moderate authorized. M365 Commercial works for FCI under Level 1. For CUI under Level 2, the Microsoft path is GCC where there is no ITAR or GCC High where there is ITAR since these data centers are U.S. persons operated. The common "Microsoft Commercial is FedRAMP High" objection confuses Azure Commercial, the IaaS, with M365 Commercial, the productivity suite. Different products, different FedRAMP scopes.

Can You Store CUI in Microsoft 365 Commercial Instead of GCC High?

Microsoft 365 Commercial cannot lawfully store CUI. DFARS 7012(b)(2)(ii)(D) requires FedRAMP Moderate or equivalent for any cloud service handling covered defense information, and the M365 productivity services in Commercial (Exchange Online, SharePoint Online, OneDrive for Business, Teams) are not FedRAMP Moderate authorized. M365 Commercial works for FCI under Level 1. For CUI under Level 2, the Microsoft path is GCC where there is no ITAR or GCC High where there is ITAR since these data centers are U.S. persons operated. The common "Microsoft Commercial is FedRAMP High" objection confuses Azure Commercial, the IaaS, with M365 Commercial, the productivity suite. Different products, different FedRAMP scopes.
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The CMMC Verb Test: How to Decode What Your Assessor Is Actually Looking For

The CMMC Level 2 Assessment Guide does not score 110 controls — it scores ~320 individual NIST SP 800-171A objectives, and each objective contains a single verb that tells the assessor exactly what evidence type is required. Documentation verbs (“defined,” “specified,” “documented,” “established,” “identified”) demand written artifacts. Operational verbs (“monitored,” “implemented,” “enforced,” “performed,” “tested”) demand live evidence — logs, configs, dated records. Context-dependent verbs (“controlled,” “authorized,” “reviewed”) require both. A policy can never satisfy an operational verb; a log can never satisfy a documentation verb. Match the evidence to the verb and you have 80% of the readiness work done.
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Heather Smith

Herrington Editor Post Blog

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