Articles/Author
NS

Nikolai Spine

CMMC Compliance Specialist

Specializes in NIST 800-171 control implementation, assessment preparation, and evidence architecture for defense contractors pursuing CMMC Level 2 certification.

12 articles published

EncryptionFeb 2025

FIPS 140-2 vs 140-3: Validated vs Compliant Guide for CMMC

Learn why 'FIPS compliant' encryption fails CMMC assessments. Discover how to find your CMVP certificate number and the difference between validated vs. compliant modules for NIST SP 800-171 control 3.13.11.

Tolerance5 min read
Legal RiskFeb 2025

False Claims Act Risks for CMMC: SPRS Scores, Self-Attestation, and Qui Tam Exposure

Every SPRS score upload under DFARS 252.204-7019 is a legal representation to the federal government. Learn how the False Claims Act applies to CMMC self-assessments and what the Aerojet Rocketdyne case means for your attestation.

Tolerance6 min read

What Is the COTS Exemption for CMMC? DFARS 252.204-7021 Explained

A COTS (Commercially Available Off-the-Shelf) item is exempt from CMMC under DFARS 252.204-7021,but only if sold without modification under FAR 2.101. Learn the legal test and where 'commercial' stops meaning 'exempt.'

Tolerance6 min read

CMMC Level 2 Scoping Guide: The 5 Asset Categories and How to Reduce Your Boundary

Master CMMC Level 2 scoping under 32 CFR Part 170. Learn how to categorize CUI Assets, Security Protection Assets, Contractor Risk Managed Assets, and Specialized Assets to shrink your assessment boundary and reduce compliance costs.

Tolerance7 min read
Remote WorkFeb 2025

Is Home Office in Scope for CMMC? Remote Work Scoping Rules Explained

Remote work is one of the most underestimated CMMC scoping risks. Learn when work-from-home devices enter your assessment boundary, how MDM and VDI affect scope under NIST SP 800-171, and how to document remote access in your SSP.

Tolerance7 min read

How to Write a CMMC System Security Plan (SSP): Step-by-Step Guide

Step-by-step guide to writing a CMMC System Security Plan (SSP). Learn how to map all 320 NIST SP 800-171A assessment objectives to verifiable evidence and prepare your SSP for a C3PAO audit.

Tolerance8 min read
POA&MMar 2025

CMMC POA&M Rules: The 180-Day Closeout, 88/110 Score Threshold, and Conditional Status

Understand the CMMC 180-day POA&M closeout rule under DFARS 252.204-7021. Learn which 1-point and 3-point controls are eligible for deferral, the minimum 88/110 SPRS score threshold, and how Conditional CMMC Status works.

Tolerance7 min read

GCC High vs Microsoft 365 Commercial: Which Do You Need for CMMC Level 2?

Microsoft 365 Commercial cannot satisfy DFARS 252.204-7012 or support a defensible CMMC Level 2 assessment for CUI. Learn when GCC High is required, when GCC or a CUI enclave is sufficient, and how FedRAMP Moderate authorization fits in.

Tolerance17 min read

How to Prevent CUI Spill Into the Wrong Cloud Tenant for CMMC

A CUI spill into a non-compliant cloud tenant fails CMMC assessments and triggers DFARS 252.204-7012 incident reporting. Learn how spills happen through email, sync clients, and shadow IT,and the enforceable DLP and conditional access controls that stop them.

Tolerance17 min read

How to Migrate to GCC High Without Expanding Your CMMC Assessment Scope

GCC High migrations are compliance projects, not IT projects. Learn how coexistence periods, duplicate repositories, and legacy connectors drag new systems into your CMMC boundary,and how to plan a scope-neutral migration.

Tolerance18 min read

Are Backups in Scope for CMMC? Repositories, Replicas, and Recovery Media Rules

Backups containing CUI are fully in scope for CMMC Level 2 assessment. Backup servers, immutable repositories, offsite replicas, tape, and their admin accounts are all assessable under NIST SP 800-171. Learn how to scope and evidence your backup architecture.

Tolerance16 min read

Offsite Backup Storage for CUI: FedRAMP Requirements and CMMC Boundary Logic

Moving CUI backups offsite does not move them out of CMMC scope. Learn when offsite backup targets require FedRAMP Moderate authorization, how FIPS 140-validated encryption at rest applies, and where the assessment boundary follows the data.

Tolerance10 min read