DFARS Archives - Tech Prognosis Blog

Why this article on CUI vs. FCI matters

If you’re a prime, a sub, or an overwhelmed SMB in the Defense Industrial Base (DIB), your CMMC journey starts with one decision: What data are we protecting – Federal Contract Information (FCI), Controlled Unclassified Information (CUI), or both? Get this wrong and everything downstream – scope, controls, budget, tools, even your chances at award – will be off. The good news: you can make this call with clear, objective criteria grounded in FAR 52.204‑21 (FCI) and 32 CFR Part 2002 (CUI), along with DoD and NIST guidance.

Quick CUI vs. FCI definitions (plain English)

FCI (Federal Contract Information)
Information not intended for public release that the Government provides to you or that you generate under a Federal contract to deliver a product or service. If it’s on a public website or simple payment data, it’s not FCI. Think SOWs, deliverable drafts, CO emails, project plans. FCI invokes FAR 52.204‑21 and its 15 basic safeguards.
CUI (Controlled Unclassified Information)
Unclassified information that Federal law/regulation/policy requires or permits safeguarding or limited dissemination. It is created or possessed by the Government, or by you for/on behalf of the Government. CUI is standardized under the government‑wide CUI Program and cataloged in the CUI Registry; DoD also maintains a DoD‑specific registry. In DoD contracts, CUI generally triggers DFARS 252.204‑7012 and NIST SP 800‑171 implementation.

Practical rule of thumb: If it’s just contract‑related but not public, it’s probably FCI. If a law/regulation/policy says it needs protection (e.g., export control, Controlled Technical Information (CTI), Personally Identifiable Information (PII) tied to a DoD purpose), it’s CUI – check the registry category and your contract.

3 CMMC Controls MSSPs Should Already Have (But Might Not) — Plus Real‑World Case Studies

Hey there, MSSP heroes! Let’s cut to the chase: If you’re prepping for a CMMC audit, you’re already ahead of the game. But here’s the kicker—many MSSPs (just like you!) might be missing a few key CMMC controls staring them right in the face.

CMMC isn’t just about checking boxes—it’s about proving you’re trustworthy enough to protect sensitive government data. And while you’ve likely got solid security practices in place, CMMC’s specific requirements can trip you up if you’re not paying attention.

As a CISM & CISSP‑holding MSSP myself, I know how overwhelming the CMMC landscape can feel. There are so many controls! But here’s the good news: You probably already have the foundation for several critical CMMC controls… you just might not realize it!

In this post, we’ll uncover three essential CMMC controls that every MSSP should have in their toolbox — yet many overlook. I’ll break each one down with real‑world examples, a simple analogy, and actionable tips. Let’s turn “uh‑oh” into “I’ve got this!”