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Does CMMC Level 2 require a government cloud tenant, or can I stay on my commercial email and file sharing?

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My ten-person landscaping company is looking at a federal contract for grounds maintenance (NAICS 561730) on a base, above the simplified acquisition threshold. The solicitation mentions CMMC Level 2. We use a commercial productivity suite for email and file sharing.

A consultant told me that CMMC Level 2 means we have to move all our data to a government-only cloud tenant, which would be a big jump in price per seat. I'm trying to figure out if that's really true or if there's a workaround.

Does CMMC Level 2 require a government cloud tenant, or can we stay on our commercial email and file sharing? Does it depend on whether we handle export-controlled data, or what type of data it is? What have other small businesses our size done to meet Level 2 requirements?

asked Jordan P. First-year bidder, landscaping and grounds · Jacksonville, FL · 253 rep

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CMMC Level 2 does not automatically require a government cloud tenant; it depends on the type of data you handle and whether your commercial productivity suite can meet the security requirements for that data.

CMMC Level 2 requires the 110 requirements of NIST SP 800-171 Revision 2. Whether your commercial email and file sharing can be configured to meet these controls is the key. You need to understand what type of federal contract information (FCI) or controlled unclassified information (CUI) you will be processing, storing, or transmitting. If the data is CUI, then the requirements are stricter and often necessitate specific cloud environments that are authorized to handle CUI.

My shop sticks to county and school district work because federal compliance gets complicated and expensive fast. We don't have to deal with CMMC for those contracts. Many small businesses our size find that the cost of compliance, whether it's specialized cloud services or in-house IT upgrades, can be significant. Talk to your APEX Accelerator about the specific data types outlined in the solicitation and what controls your current commercial suite can actually deliver.

answered Marcus T. Verified vendorOwner, janitorial and facilities firm · Columbus, OH · 598 rep

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