Continuous Compliance Is the New Operational Standard
The implementation of DFARS 252.204-7021 formally embeds the Cybersecurity Maturity Model Certification (CMMC) program into Department of Defense contracts. This clause establishes a clear mandate: Cybersecurity compliance is no longer self-attested, and it is not a one-time effort.
To remain eligible for DoD contracts, organizations must achieve and maintain the required CMMC level, demonstrating sustained protection of Controlled Unclassified Information (CUI) in accordance with NIST SP 800-171.maintain the required CMMC level, demonstrating sustained protection of Controlled Unclassified Information (CUI) in accordance with NIST SP 800-171.
What DFARS 252.204-7021 Technically Requires:
Under this clause, contractors must:
- Achieve the applicable CMMC level prior to contract award (as required)
- Undergo third-party assessment for Level 2 when applicable
- Maintain ongoing implementation of the 110 NIST SP 800-171 security requirements
- Ensure operational effectiveness of technical and administrative controls
- Retain objective evidence supporting compliance claims
- Address deficiencies through documented remediation plans
Compliance must be demonstrable, repeatable, and defensible. Continuous Visibility, Documentation, and Governance
DFARS 252.204-7021 shifts cybersecurity from a project milestone to an operational discipline requiring:
1. Continuous Monitoring
- Log review and security event monitoring
- Configuration management validation
- Access control enforcement
- Vulnerability scanning and remediation tracking
2. Documentation & Evidence Management
- Current and accurate System Security Plan (SSP)
- Managed Plans of Action & Milestones (POA&Ms)
- Policy lifecycle control
- Evidence repository mapped to each requirement
3. Executive Governance
- Defined cybersecurity roles and accountability
- Risk register oversight
- Periodic internal readiness reviews
- Leadership reporting and decision-making integration
If controls degrade, documentation lapses, or governance weakens, certification status—and contract eligibility may be jeopardized. The Risk of Treating Compliance as a One-Time Event Organizations that approach CMMC as a checklist exercise face significant exposure:
- Audit findings and remediation delays
- Contract performance risk
- False Claims Act liability
- Loss of competitive standing in the Defense Industrial Base
Cybersecurity compliance must be institutionalized across IT, security, compliance, HR, and executive leadership.
Operational Reality.
DFARS 252.204-7021 establishes a permanent shift:
- From self-attestation to verified assessment
- From annual reviews to sustained oversight
- From policy documentation to operational proof
- From reactive compliance to proactive governance
The new baseline for doing business with the DoD requires continuous readiness not episodic preparation. LP3 CMMC Compliance Services brings unmatched depth, proven experience, and a comprehensive ecosystem of cybersecurity expertise to guide organizations through the full spectrum of CMMC compliance. Our team combines technical mastery, regulatory insight, and operational know-how with a network of partners and tools that ensure not only certification readiness, but sustainable, enterprise-wide cybersecurity resilience.
Built for Continuous Readiness
LP3 transforms compliance from a project into a managed operational capability.
1. Strategic Compliance Architecture- We align your environment to CMMC Level 1 or Level 2 requirements with a structured, defensible compliance framework.
2. Remediation & Control Implementation- From technical safeguards to documentation maturity, LP3 closes gaps systematically and efficiently.
3. Continuous Monitoring & Governance- We implement sustained oversight including:
- Ongoing evidence collection
- POA&M lifecycle management
- SSP updates and control validation
- Executive reporting and risk tracking
- Internal readiness reviews
4. Audit Defense & Assessment Readiness
When a C3PAO arrives, you are prepared not scrambling.
The LP3 Difference
Most firms help you prepare for an audit. LP3 ensures you operate in a state of continuous compliance. We integrate cybersecurity governance into leadership operations aligning IT, security, HR, legal, and executive accountability under a unified compliance framework.
LP3 Services transform compliance from a reactive obligation into a strategic advantage. By leveraging our expertise, organizations achieve audit-ready certification, reduce operational and regulatory risk, maintain continuous cybersecurity posture, and secure their position within the Defense Industrial Base. With LP3, compliance becomes sustainable, defensible, and aligned with both mission objectives and business growth.
