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Microsoft Government CMMC AMA
Event details
We want to hear from our customers and answer their questions around how we can help them achieve CMMC compliance with your Microsoft Azure and Microsoft 365 subscriptions. We will be hosting an "Ask Microsoft Anything" (AMA) session on Tuesday, April 12th from 10:30 AM - 11:00 AM PST here and answering questions in the comments below.
This event is open to all Tech Community members and we'll have members of the Microsoft product experts standing by to provide answers.
Feel free to post your questions about CMMC anytime in the comments below beforehand, if it fits your schedule or time zone better, though questions will not be answered until the live hour.
***Please note : This AMA is only to answer questions in regards to achieving CMMC compliance with our Microsoft products, including Microsoft Azure and Microsoft 365.
98 Comments
- Joshua1984Copper ContributorWill Microsoft privide GTM resources to better enable Partners with this?
- RichardWakeman
Microsoft
Howdy Joshua, the CMMC 2.0 Acceleration Program was constructed as scaffolding for our partners. https://aka.ms/CMMCAccelerationProgramUpdate. Please also reach out to us directly for more discussion.
- skipster311-1375Copper ContributorWe are building out a GCC high for cmmc level2. We already have a commercial tenant. Users will only have one device\workstation. How do we keep users from using their device that is azure ad joined to the commercial tenant from using this same device to log into the GCC high tenant ? We dont want the users to have to use two separate devices (one for gcc high and one for commercial)
- Justin_Orcutt
Microsoft
Hi James - We see many organizations leveraging one device/workstation but having those users access both commercial and government environments. Most will leverage Azure Virtual Desktop (https://azure.microsoft.com/en-us/services/virtual-desktop/). We are also really excited about Windows 365 as some of the organizations do not have the bandwidth to manage the configuration of virtual desktops (https://docs.microsoft.com/en-us/windows-365/overview). Organizations that are already in GCCH leverage W365 or AVD to access commercial resources this way users spend the majority of their time in a higher baseline environment. In the future W365 will be available for GCCH (https://www.microsoft.com/en-us/microsoft-365/roadmap?featureid=93691).
- Which Certificate will valid for Microsoft Endpoint Configuration Manager? and How about MS-101 does it meet the requriment for MECM?
- Sarah_GilbertSilver ContributorHello! This AMA was specifically for CMMC so I am not sure how your question pertains to this. I recommend getting started with this link here: https://trainingsupport.microsoft.com/en-us/mcp/forum/all/microsoft-intune/eb3f8646-9ff4-4fb1-a562-c9ec555ff292?auth=1
- JoeatheistCopper ContributorThanks for holding this/these discussions! My company does not use any cloud services. It is a preferential choice made by our CEO. We are currently using Office 2021 Pro. Does this meet the requirements for NIST 800-171/CMMC 2.0? We also do not allow any remote connections, we all work in the office, not from home. Not much need for cloud services as we can store everything on our in-house physical server.
- Paul Meacham
Microsoft
You certainly can be compliant on-premises, no argument about that. Cloud services do help customers get a leg up on compliance as we offer a breadth of tools and services that allow customers to meet requirements for collaboration, security, compliance, device management, hardware, compute, memory, storage, development, etc. The reason folks are using the cloud is because they may not have the technical skill sets or the capital investment and time required to manage hardware and software and networking. For large companies that do have the expertise and capital their work force is looking for modern tools to compete in the market as well as the ability to attract and retain new talent who want to work from anywhere with any device (coauthoring, text, chat, calling, email, calling, meeting join, whiteboarding, @mentioning, etc.). While you may say that you do not have much need for cloud services, I would point out that you have limited organizational resilience (BC/DR plan) with your servers in-house at a single location. You also cannot leverage cloud economies of scale to free up cash flow and transfer CAPEX to OPEX thereby gaining benefit from a positive net present value. Moreover, you are highly vulnerable to risks inside and outside the org without having advanced machine learning to reason over your behavioral analytics, logs, devices and files to expose risks and take remediating steps. Lastly, you are doing everything all on your own, there is no cloud service provider to help with shared scope of responsibility, support escalations or professional services. So yes, you can be compliant on-prem, but it may not be a good idea given the benefits of the cloud and the fact that that is the direction that every technology company is going.- JoeatheistCopper ContributorUnfortunately, the decision to go cloud is out of my hands. Our CEOs, past and present, do not want to utilize the technology. No amount of persuasion has worked since "the cloud" became a thing. That is not likely going to change anytime soon. Thank you for your input though. It is greatly appreciated.
- Paul Meacham
Microsoft
You certainly can be compliant on-premises, no argument about that. Cloud services do help customers get a leg up on compliance as we offer a breadth of tools and services that allow customers to meet requirements for collaboration, security, compliance, device management, hardware, compute, memory, storage, development, etc. The reason folks are using the cloud is because they may not have the technical skill sets or the capital investment and time required to manage hardware and software and networking. For large companies that do have the expertise and capital their work force is looking for modern tools to compete in the market as well as the ability to attract and retain new talent who want to work from anywhere with any device (coauthoring, text, chat, calling, email, calling, meeting join, whiteboarding, @mentioning, etc.). While you may say that you do not have much need for cloud services, I would point out that you have limited organizational resilience (BC/DR plan) with your servers in-house at a single location. You also cannot leverage cloud economies of scale to free up cash flow and transfer CAPEX to OPEX thereby gaining benefit from a positive net present value. Moreover, you are highly vulnerable to risks inside and outside the org without having advanced machine learning to reason over your behavioral analytics, logs, devices and files to expose risks and take remediating steps. Lastly, you are doing everything all on your own, there is no cloud service provider to help with shared scope of responsibility, support escalations or professional services. So yes, you can be compliant on-prem, but it may not be a good idea given the benefits of the cloud and the fact that that is the direction that every technology company is going. - Justin_Orcutt
Microsoft
Hi Joe - Great question. Many dib companies are evaluating how they can achieve CMMC compliance using what they already have in place. With that being said, implementing and maintaining the 110 controls of CMMC and meeting all of the 300+ assessment objectives on prem can be challenging. To help we have published the CMMC placemat to help you map individual services to requirements of CMMC: https://www.microsoft.com/en-us/download/details.aspx?id=102536. You might also find our blog on understanding compliance between offerings helpful: https://techcommunity.microsoft.com/t5/public-sector-blog/understanding-compliance-between-commercial-government-and-dod/ba-p/3258326- RichardWakeman
Microsoft
In terms of rich client software running on-premises, such as Office 2021, is considered COTS when it's not connected to the cloud. In other words, compliance is 100% customer scope of responsibility to get the endpoint where the COTS software runs to be compliant. Many of our customers will lay down a STIG for Windows and for Office to harden the endpoint. That said, we do recommend you use the suggestion by Justin for the Product Placemat. You will find that Microsoft Endpoint Manager (Intune) and Defender for Endpoint (EDR) are fabulous options to assist you in demonstrating compliance.
- Joshua1984Copper ContributorCan Co-Op funds be used to help Partners achieve CMMC Compliance?
- Sarah_GilbertSilver ContributorHello. Marion answered this question previously but here is the answer from above : Partner Co-op funds are used for marketing efforts. You can use the "On Site Champion" option to create a solution or offering. This would allow you to hire a CMMC consultant to audit your offerings and make recommendations on how to adapt them to help your customers reach compliance. This could not be used to assess your own CMMC compliance gaps, which we recommend going to a C3PAO for an assessment.
- Joshua1984Copper ContributorDoes Microsoft have a Walking Deck that highlights the benefits and details of CMMC? (Like they do around other Cloud Industry Solutions)
- Sarah_GilbertSilver Contributor
Hi Joshua, not a deck but check out the Microsoft CMMC page and this CMMC overview blog.
- TDS_David_WOccasional ReaderHow does MS plan to be CMMC compliant? Will there be products that have only US citizens with admin rights? Are any countries off limits for hiring people with powerful access?
- Bergin2
Microsoft
David, we plan on achieving CMMC V2 L2 as soon as the DoD releases final guidance. We have prepared and ensured our systems, security plans, and control procedures meet or exceed the existing guidance. GCCH currently has US Cit access restrictions in place and MSFT operates our Federal tenant on GCCH using US Cit admins, operating on US soil, only. This additional constraint is NOT a CMMC control but rather derived from existing arrangements with the USGov. - LisaHaywood
Microsoft
In addition to being a Cloud Service Provider and System Integrator, Microsoft is also a Defense Contractor. As such, we too are undergoing our journey to meet CMMC compliance for federal business. All services released in the US Sovereign Cloud are contained within an accreditation boundary supporting US Export Controls requiring screened US persons and data sovereignty in the Continental United States (CONUS). Microsoft does not bar customers from deciding within their own tenant users who can/cannot have access nor do we screen your users for this. This is the responsibility of the customer.
- ndelenaCopper ContributorWhat are the current rules around conducting a penetration test against a company's footprint in GCC High and Azure government? We have a handful of clients that are expecting eventual CMMC Level 3 requirements.
- Justin_Orcutt
Microsoft
Hi Nick - Thank you for asking this. We do have a Penetration Testing Rules of Engagement which outlines scope and engagement: https://www.microsoft.com/en-us/msrc/pentest-rules-of-engagement?msclkid=bf4ba221ba8711ec80349cf2bb73b179. Aside from this Microsoft also conducts penetration testing on a regular basis of our services and software.- ndelenaCopper ContributorThanks Justin! Just to clarify, these rules apply to GCC High and Azure Government as well?
- SamClark2411Copper ContributorAssumed that if you migrate to an Microsoft 365 GCC High environment and your AD lives in Azure then Azure needs to also be in a GCC High environment, correct? And the same for the vice-versa scenario? It's not one or the other but rather both or neither?
- Justin_Orcutt
Microsoft
Hi Sam - This is an important underpinning to how the service works. If you are in M365 GCCH the identity will reside in Azure Gov. If you are in M365 commercial the identity will be in commercial. Here is a blog from Richard Wakeman with more information about this. https://techcommunity.microsoft.com/t5/public-sector-blog/history-of-microsoft-cloud-offerings-leading-to-the-us-sovereign/ba-p/2157821- RichardWakeman
Microsoft
Also, if you are hosting "AD" as traditional Windows Server based VM's running AD DS, then we recommend those VM's run in Azure Government IaaS. Technically, those VM's can reside anywhere, but recommended guidance is to host the VM's in an environment where you can meet the higher watermark for compliance.
- ptsukaharaCopper ContributorAny plans/timeframe for Azure Devops Service coming to GCC High?
- Justin_Orcutt
Microsoft
Hi Peter - At this point we do not have a timeline to share for Azure DevOps. With that being said we see GCCH customers leveraging both Azure DevOps Server(https://azure.microsoft.com/en-us/services/devops/server/) or Github Enterprise deployed in Azure Gov.- RichardWakeman
Microsoft
We also are closing the gap in functionality between ADO & GitHub, and will surface as a SaaS offer in GCCH. GitHub that is FedRAMP compliant is called "GHAE".