Preparing Your Team for CMMC: Key Roles and Responsibilities

The Cybersecurity Maturity Model Certification (CMMC) 2.0 is a mandatory framework designed to enhance the cybersecurity posture of contractors and suppliers in the Defense Industrial Base (DIB). With increasing cyber threats targeting sensitive defense-related information, the Department of Defense (DoD) has reinforced the importance of proper security practices, defining clear roles and responsibilities, and structured compliance management. 

But where do you start? 

One of the most common pitfalls in CMMC compliance is unclear roles and responsibilities within an organization. Companies risk falling behind deadlines, failing assessments, and losing valuable contracts without a structured approach. 

This blog will walk you through: 

• The key roles needed for CMMC compliance 
• How to assign responsibilities effectively 
• Common challenges teams face and how to overcome them 
• Best practices for streamlining compliance efforts 

Why Clearly Defined Roles Matter in CMMC Compliance 

Cybersecurity isn’t just an IT concern—it’s an organization-wide effort. From executive leadership to frontline employees, everyone is responsible for securing Controlled Unclassified Information (CUI) and meeting NIST SP 800-171 requirements. 

Without defined roles, organizations often face: 

• Confusion – Who is responsible for what? Lack of clarity leads to missed tasks, audit failures, and compliance gaps.
• Inefficiency – Overlapping responsibilities or redundant efforts waste time and resources. 
• Increased risk – Cybersecurity gaps caused by a lack of accountability can result in breaches, penalties, or contract loss. 

By assigning clear roles and implementing structured compliance workflows, businesses can create an efficient, audit-ready process. 

Expanded Key Roles in a CMMC Compliance Team 

In alignment with CMMC 2.0’s structure and recent updates, here’s a deeper look at key organizational and external roles: 

Executive Leadership / Compliance Sponsor 

Who: CEO, CIO, CISO, CFO, or Board of Directors 
Responsibilities: 

• Evaluate the business impact of CMMC compliance versus market opportunity. 
• Provide strategic and budgetary support. 
• Designate a Compliance Officer or CMMC Program Manager. 
• Define and endorse company-wide CMMC policies. 

Compliance Manager / CMMC Program Lead 

Who: Compliance officer or dedicated program lead 
Responsibilities: 

• Liaise with C3PAOs and manage external audits. 
• Oversee POA&M development and SPRS score accuracy.
• Align organizational controls with NIST SP 800-171. 
• Monitor continuous improvement and certification maintenance. 

Legal & Data Protection Officer (DPO) 

Responsibilities: 

• Ensure DFARS 252.204-7012 and FAR compliance. 
• Identify and classify CUI and FCI. 
• Mitigate legal risks related to cybersecurity contracts. 
• Align data protection with contractual and federal obligations. 

IT & Security Team 

Roles: CISO, ISSO, IT Director, Security Engineers 
Responsibilities: 

• Implement and monitor security controls (access, encryption, endpoint security). 
• Ensure FedRAMP Moderate compliance for CSPs handling CUI. 
• Conduct patch management and enforce secure configurations. 
• Lead incident response and risk management processes. 

Risk Manager & Internal Auditor 

Responsibilities: 

• Conduct gap assessments and develop POA&Ms. 
• Monitor and document risk continuously. 
• Support readiness assessments and external audit preparation. 

Procurement & Vendor Management 

Responsibilities: 

• Ensure vendor compliance and flow-down clause enforcement. 
• Conduct contract reviews and manage third-party cybersecurity risks. 
• Work with legal and compliance on supply chain risk management (SCRM). 

HR & Training Coordinators 

Responsibilities: 

• Develop and deliver security awareness and role-based training. 
• Conduct phishing simulations and monitor training completion. 
• Promote a culture of cybersecurity vigilance. 

Third-Party Consultants, RPOs, and ESPs 

Who: 

• C3PAO: Conducts Level 2/3 assessments. 
• CCP/CCA: Certified professionals responsible for guidance and audits. 
• RPOs: Help prepare for certification, but do not assess. 
• ESPs/MSPs/MSSPs: Support IT and security implementation. 

Responsibilities: 

• Provide expert guidance and remediation plans. 
• Support SSP/POA&M documentation. 
• Offer infrastructure, staff augmentation, and assessment support. 

Regulatory Update & Compliance Phasing 

• 32 CFR is now effective (as of Dec 2024), and 48 CFR is in proposed status (as of Jan 2025). 
• Movement from self-attestation to third-party certification (especially at Level 2+). 
• POA&Ms are only allowed for specific controls and must be closed within 180 days. 
• Cloud Service Providers must be FedRAMP Moderate (or equivalent) when handling CUI. 
• Violations in SPRS reporting could invoke the False Claims Act—highlighting the need for accuracy. 

How Sikich’s STARS Program Simplifies CMMC Compliance 

Sikich’s Scope, Train, Assess, Remediate & Support (STARS) Program helps organizations achieve compliance efficiently through a structured, phased approach. 

The STARS Program Helps You: 

• Eliminate uncertainty with expert-led guidance. 
• Reduce risk via proactive assessments. 
• Accelerate documentation and security control development. 
• Maintain compliance through ongoing monitoring. 

The STARS Five-Step Framework: 

1. Scope: Define the compliance boundary and assign key roles. 
2. Train: Ensure all teams are educated on CMMC duties. 
3. Assess: Conduct internal readiness assessments. 
4. Remediate: Close gaps via detailed POA&Ms and control enhancements. 
5. Support: Maintain certification with continuous oversight. 

Organizations using STARS reduce time-to-certification by over three months compared to manual or siloed approaches. 

Best Practices for Preparing Your Team 

• Start Early: Compliance timelines are tight—get ahead now. 
• Define Roles Clearly: From board-level oversight to system admins, everyone must know their part. 
• Invest in Education: CMMC success relies on trained, cyber-aware teams. 
• Automate Where Possible: Use platforms to manage documentation, monitoring, and assessments. 
• Perform Internal Audits: Regular check-ins reduce surprises during official reviews. 

Conclusion 

CMMC 2.0 compliance is not just a checkbox—it’s a strategic commitment. With clearly defined roles and responsibilities, proactive assessments, and structured programs like STARS for CMMC compliance, your organization can protect sensitive information, retain DoD contracts, and build a culture of continuous security improvement. 

Is your team ready for CMMC? Now is the time to assign responsibility, identify gaps, and start the journey toward certification—with confidence. Reach out to our experts today!