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CMMC Compliance Path Analysis  |  Prepared by Simpatico Systems

Microsoft 365 GCC Path
vs. StormCloud Gov Enclave

An honest look at what each path requires of your organization — in time, money, effort, and risk.

What's Included with StormCloud + CMMCReady
🧠
Component 1
The Consulting
Simpatico vCISO + compliance program management — policy writing, gap closure, user lifecycle, MFA admin, helpdesk, 24/7 SOC, and regulatory updates.
🏰
Component 2
The Enclave
StormCloud Gov — FedRAMP Moderate IL4 Ready, 90/110 controls active at first login, VDI seats, CUI isolation, SOC monitoring, pre-built SSP artifacts.
★ Assessment Cost Included*
🏆
Component 3
THE ASSESSMENT
Vaultes C3PAO — a Cyber AB-authorized third-party assessor conducts your official CMMC Level 2 assessment. Results submitted to SPRS and eMASS. Bundled. Done.
* Assessment fees are collected by Simpatico Systems and held in escrow on behalf of Vaultes for disbursement upon assessment scheduling.
Current Path
GCC / GCC High
Microsoft 365 tenant
DIY compliance build
CMMCReady Path
StormCloud Gov
Enclave + Consulting + Assessment
all in one program
Controls You're Responsible For
Out of 110 NIST SP 800-171 requirements
~75
35 CONTRACTOR-ONLY
40 SHARED — YOU CONFIGURE & MANAGE
35 MICROSOFT INHERITED
GCC gives you the tools — not the compliance. ~68% of requirements still require contractor implementation or active management. Conditional Access, MFA, DLP, audit logging, IR — all on your team.
35 Contractor-Only 40 Shared (Your Config) 35 Inherited
9 customer + 16 shared
90 INHERITED — ACTIVE AT FIRST LOGIN
16 SHARED — SIMPATICO MANAGES YOUR SIDE
9 CUSTOMER — POLICIES & PERSONNEL (SIMPATICO ASSISTS)
90 of 110 controls are live in the enclave the day you log in — sourced from the StormCloud Gov SRM. Simpatico manages the remaining shared and customer controls as part of the program.
90 Inherited at Login Simpatico Manages Shared 9 Customer (We Assist)
Assessment Readiness
What you show the C3PAO on day one
Significant Effort Required
Reaching 90/110 on GCC demands deep NIST 800-171 expertise, months of deliberate configuration, and a specialist who knows how Microsoft's controls map to each practice. SSP, evidence packages, boundary diagrams — all from scratch. Miss one, get a finding.
SSP Written From Scratch Evidence Manually Gathered Config Expertise Required C3PAO Sourced & Paid Separately
90 / 110 at First Login
Pre-built SSP artifacts, system boundary docs, and evidence packages are included — validated against the StormCloud SRM. Vaultes C3PAO is already embedded. No separate sourcing, no alignment gap, no surprise bill.
90/110 Active at Login SSP Artifacts Included Evidence Ready Day One C3PAO Already Included ✓
Time to Certification
From today to assessment-complete
12 – 24 months
Building and documenting 75 controls from scratch takes time even with expert help. Every config must be made, tested, and evidenced to assessor standards. Delays compound.
1 – 3 months
Onboarding in 30–60 days. Remaining controls closed by Simpatico in parallel. Vaultes assessment begins as soon as posture is confirmed — often within the same quarter you start.
Cost
Initial + annual operating cost (25–50 users)
$40K – $115K to start
Implementation
$20K – $60K (one-time)
Documentation
$15K – $40K (one-time)
M365 Licensing
$20K – $40K / yr (25–50 users)
Operations
$25K – $60K / yr (500–800 hrs)
C3PAO Assessment
Billed separately — not included
Rule of thumb used by CMMC advisors: ~$1,500 – $2,500 per user per year all-in. Scope creep, tooling gaps, and internal labor are the norm — and the C3PAO assessment is a separate invoice on top.
$40K–$115K to Start $55K–$130K / yr After 500–800 Security Hrs/yr Assessment Not Included
$6K – $12K / month
Small org
~$6K / mo
Larger org
~$12K / mo
Flat monthly fee. Enclave + consulting + C3PAO assessment — all bundled. No surprise invoices. No change orders for standard scope. No separate assessment bill.
Fixed Monthly OpEx Assessment Included ✓ All-In Pricing
Internal Staff Burden
What your team owns day-to-day, forever
High — Permanent
Someone on your team must continuously manage Conditional Access, MFA policy, DLP, audit log review, account lifecycle, incident response, and policy currency. Minimum part-time security role — indefinitely.
Config on You Policy Ownership on You Monitoring on You IR on You
Minimal
Simpatico owns the compliance program. Your team uses the environment — they don't run it. vCISO, policy management, user lifecycle, MFA administration, helpdesk, and 24/7 SOC monitoring are all included.
vCISO Included 24/7 SOC Included Policy Mgmt Included Helpdesk Included
Risk if L2 Lands in a Contract
What happens if CMMC Level 2 becomes required
Significant Exposure
GCC provides the tools — not the certification. Assessors evaluate configuration and documented evidence. Gaps found on assessment day delay certification by months and cost tens of thousands to remediate. Environment may require redesign.
Tools ≠ Compliance Assessment Gaps Likely Possible Environment Rebuild
Already Ready
StormCloud Gov is FedRAMP Moderate IL4 Ready and purpose-built for CMMC Level 2. If L2 lands in a contract, you're already in the right environment — no migration, no rebuild, no scramble. Activate the Vaultes assessment and go.
FedRAMP Moderate IL4 Ready L2-Certified Environment No Migration Needed
🔁

Your Prior Compliance Investment Carries Forward — Fully

Any work you've already done — gap assessments, CUI data flow mapping, policy and procedure development, risk assessments, POA&M work, personnel training, or scoping decisions — is not wasted. These are durable assets that accelerate onboarding and reduce the effort required to reach certification. Your organizational knowledge, contract scope, and CUI boundaries transfer directly. You're not starting over. You're starting ahead of everyone who begins from scratch.

head start
already
earned
GCC Path — What You're Taking On
  • You have dedicated security staff to continuously manage and evidence 75+ controls
  • You have deep M365 security configuration expertise in-house
  • You are prepared to fund and manage a separate C3PAO assessment engagement
  • You must maintain a current body of evidence at all times — assessors evaluate configuration and artifacts, not licenses
  • GCC can fall out of compliance with every tenant change, update, or staff transition — drift is a constant risk
StormCloud — Built for Your Situation
  • Covers Level 1 and Level 2 — protects you regardless of where requirements land
  • No dedicated security staff required — Simpatico runs the program
  • 1–3 months to certification, not 12–24
  • Fixed cost: $6K–$12K/mo — enclave + consulting + assessment included
  • Your prior Simpatico work is a head start — you start ahead
StormCloud control counts sourced from the StormCloud Gov Shared Responsibility Matrix (securitycentric.net/srm): 90 Inherited · 16 Shared · 9 Customer.
GCC effort distribution based on commonly accepted NIST SP 800-171 inheritance analysis for M365 GCC/GCC High. Actual scope varies by system boundary.

Prepared by Simpatico Systems  ·  simpatico.com/cmmcready  ·  Confidential