CMMC Compliance & CUI Protection | Steelhead Technologies

Program Phases

Phase 1

Policy & Documentation

Q1 – Q2 2026

Active

Progress

90%

Comprehensive information security policy library developed and reviewed
All required policies uploaded to compliance platform with control mappings
All 5 FedRAMP program roles formally acknowledged (ISSO, System Owner, AO, SAOP, ISSM)
Program compliance framework configured with control ownership assigned
System architecture and access boundary documented and reviewed
Final policy approvals in progress; full library sign-off targeted this quarter
Full compliance platform control coverage at 100% of 325 controls

Phase 2

System Security Plan (SSP) Development

Q1 – Q2 2026

Active

Progress

82%

System Security Plan structure established
Security control documentation complete across all 18 NIST control families
Third-party interconnection security agreements documented for all external services
Risk assessment and threat modeling complete; risk register established
Supply chain risk management plan drafted
System description, architecture narrative, and data flows being finalized
Plan of Action & Milestones (POA&M) initialized

Phase 3

3PAO Selection & Engagement

Q1 – Q2 2026

Complete

Progress

100%

Competitive third-party assessor evaluation complete; all proposals received and evaluated
Peer benchmarking with industry counterparts complete
3PAO selected for formal assessment (Sep 4); pre-assessment advisor engaged
Final vendor meetings held — April 17, 2026
Assessor contract executed — Q3 assessment slot formally locked
Assessment scope and statement of work finalized
Assessor kickoff meeting scheduled

Phase 4

FedRAMP-Compliant Environment Buildout

Q2 2026

Active

Progress

40%

Cloud environment architecture and security controls designed
Identity and access management architecture confirmed
CI/CD pipeline architecture finalized; build and deployment security controls integrated
SIEM (Microsoft Sentinel) and EDR (Defender for Endpoint) platforms selected
FedRAMP-authorized cloud environment provisioning in progress
Virtual desktop environment configuration planned
Architecture validated against documented security baseline

Phase 5

Evidence Collection & Security Testing

Q2 – Q3 2026

Upcoming

Progress

Continuous monitoring evidence collection across all 325 controls
Authenticated vulnerability scanning across all boundary components
Independent penetration testing
Business continuity and disaster recovery testing
Findings remediation and risk acceptance documentation

Phase 6

3PAO Formal Security Assessment

Q3 – Q4 2026

Not Started

Progress

Third-party assessor document review
Security control testing and validation
Staff interviews and process verification
Security Assessment Report received and reviewed
Assessment findings remediated

Phase 7

ATO Package & Authorization

Q4 2026

Not Started

Progress

Final authorization package compiled
Internal Authorizing Official review
Authorization to Operate signed — target Q4 2026

Risk Posture

Assessment partnership secured Active

Pre-assessment advisory engagement active Active

Security documentation substantially complete Active

Parallel workstreams active Active

Continuous monitoring dependency — environment live required Watch

Penetration testing scoped and confirmed — assessor-led Locked

Internal AO engagement — pending assessment outcomes Locked

Ongoing Compliance Commitments

monitoring

Monthly risk reviews

Executive + program cadence

event_repeat

Annual reassessment

Full program refresh cycle

radar

Continuous control monitoring

Automated + manual attestations

groups

Dedicated program ownership

Named control owners

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Evidence retention

7-year artifact policy

assignment

POA&M management

Tracked remediation SLAs

schedule

Continuous monitoring cadence

Monthly CM reporting