Scoping — Official DoD FAQ

How Do I Properly Handle System Changes While Maintaining CMMC Compliance?

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Source Source: DoD CIO CMMC FAQs v5 (F-Q5)

For any changes that may impact FCI/CUI processing, security requirements, or CMMC Assessment Scope, you should: (1) Before implementation — evaluate the change with security impact analysis, assess effects on CUI flow, document in change management, and review with Affirming Official; (2) During implementation — document in Operational Plan of Action; (3) After implementation — update the System Security Plan and review with Affirming Official before next annual affirmation.

Change Management for CMMC Compliance

Maintaining CMMC compliance isn't a one-time achievement — it requires ongoing vigilance, especially when making changes to your environment. The DoD provides a structured approach.

Step 1: Before Implementation — Evaluate

  • Security Impact Analysis (CM.L2-3.4.4): Assess how the change affects your security posture
  • CUI Flow Review (AC.L2-3.1.3): Determine if the change affects how CUI is processed, stored, or transmitted
  • Change Management Documentation (CM.L2-3.4.3): Record the planned change in your CM process
  • Affirming Official Review: Get consensus on whether the change impacts continued compliance

Step 2: During Implementation — Track

  • Document the change and any temporary risks in your Operational Plan of Action (OPA) per CA.L2-3.12.2
  • Identify responsible personnel
  • Track progress to completion

Step 3: After Implementation — Update

  • Update your System Security Plan (SSP) per CA.L2-3.12.4
  • Modify all affected sections
  • Review with Affirming Official before the next annual affirmation

The Bottom Line

If a security impact analysis reveals a new risk not covered in your existing SSP, you likely have a significant change that may require reassessment. When in doubt, document conservatively and consult with your Affirming Official.

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