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Scoping guide

CUI Scoping Decision Guide for CMMC

Use this to make the CUI boundary concrete enough for pricing and cleanup. The useful facts are simple: what data is involved, where it travels, who touches it, and which paths can be contained.

Ask this before the call: what does the contract actually say?

Look for clauses, DD Form 254 context, flow-downs, marking instructions, customer direction, and deliverable language. Then use FCI vs CUI for CMMC to separate classification basics from operating-scope facts.

Draw the CUI flow, not just the system list

Track where CUI is created, received, stored, processed, transmitted, printed, discussed, and archived. Include email, file sharing, engineering tools, ticketing, backups, and collaboration spaces.

Name every role that can touch the workflow

Scope is not only servers and laptops. Include employees, admins, subcontractors, MSPs, cloud providers, consultants, and anyone whose job gives them access to covered workflows.

Do not assume an enclave fixes messy flow

A managed enclave can isolate CUI, but only if users, endpoints, integrations, exports, and residual data paths cooperate. Compare enclave and Microsoft migration tradeoffs before assuming either is simpler.

Bring enough evidence for a serious quote

Bring a rough boundary diagram, CUI-flow notes, asset list, tool inventory, user counts, contracts, and known gaps. Better inputs produce fewer change orders and less rework.

Keep the small-business boundary narrow, but honest

Small contractors often need containment, not a company-wide transformation. Narrow the environment where the facts allow it, but do not declare inconvenient CUI paths out of scope.

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