phraCTO LLC is registered in SAM.gov | Cage Code: 11TR6

For the manager who got handed CMMC

You still have to self-assess. Your Senior Official still signs.Get it defensible for $997, not $50k.

CMMC for Microsoft® 365 GCC High: every control, every objective, every solution — already written. $997 one-time. Start implementing today.

110 controls. 320 assessment objectives. 735 pre-written solutions.

Approval kit = ROI one-pager + pre-drafted approval email. Free.

The Phase 2 deadline is suspended. Your obligations aren't.

NIST 800-171
Still in your contracts under DFARS 252.204-7012
Self-Assessment
Still required — same 110 controls, same 320 objectives
SPRS Affirmation
Still signed by your Senior Official, every year
DIBCAC + DOJ
Still auditing, still settling False Claims Act cases

June 2026: DIBCAC audited a small Alabama defense contractor at −170. A perfect score is 110. Settling with DOJ cost them $507,144.

The Approval Kit

Two things the person who approves $997 of corporate spend needs to see. Free. No sales call.

1. ROI one-pager

$997 vs $50k RPO vs $10k–$50k/yr GRC vs DIY. Side-by-side math your CFO can sign off in under a minute.

2. Pre-drafted approval email

Fill in your boss’s name. Hit send. The pitch is written for you by someone who has sat on both sides of the assessment table.

One-time request. No sales call unless you ask.

Need Approval? Here's the Math.

CMMC Consultant

$50K–$150K

3–12 months

Still need to implement yourself

GRC Platform

$10K–$50K/yr

Ongoing cost

Templates only — you fill in the blanks

CMMC for M365

$997 once

Start today

Pre-written by a CMMC Registered Practitioner

$997 is less than a single day of consultant billing. It's less than one month of most GRC platforms. And unlike both, the work is already done — you're buying finished, implementation-ready content for every CMMC Level 2 control mapped to M365 GCC High.

Get the ROI One-Pager (PDF)

Send it to your manager, your CISO, or your contracting officer.

Want a Guided Tour?

Preview Control 3.1.1 free — full SSP language, policies, procedures, configuration instructions, and evidence guidance. No signup, no paywall. Or book a 15-minute demo and we'll walk you through the full tool live.

Sound Familiar?

You need CMMC Level 2 but don’t know where to start
You’re running M365 GCC High (or migrating to it)
You’ve been Googling NIST 800-171 controls for weeks and still don’t have SSP language written
You got a consultant quote and it was $50K–$150K
You know the work needs to get done but you don’t have dedicated compliance staff
Your contracts already carry DFARS 252.204-7012 — and your SPRS score is already on file

The Deadline Is Gone. The Liability Isn't.

What the July 2026 Phase 2 suspension did not change:

  • NIST 800-171 is still in your contracts. DFARS 252.204-7012 has required all 110 controls since 2017 — the suspension didn't touch it.
  • You still self-assess and post a score in SPRS. DFARS 252.204-7019/7020 and CMMC Phase 1 remain fully in force.
  • A senior official still signs the dotted line. Your Affirming Official personally attests your compliance in SPRS — every year.
  • DIBCAC is still auditing. When the government's score doesn't match the one you posted, DOJ treats the gap as a False Claims Act problem — and your own employees can file as whistleblowers and keep a share.
  • The False Claims Act is the new deadline. LOGZONE: $507,144 (June 2026 — DIBCAC-audited at −170 on a scale that tops out at 110). MORSECORP: $4.6M (reported a 104 while its actual score was −142; the whistleblower collected $851K). Raytheon: $8.4M.

The work is unavoidable. The question is whether the affirmation your leadership signs is backed by real implementation — or by hope.

Everything You Need for a Defensible Self-Assessment

SSP Language

Copy-and-paste language for every assessment objective — written in third person, present tense, ready for your System Security Plan.

Policies & Procedures

Complete, exportable Word documents. Not templates — finished documents you can adopt and brand.

M365 GCC High Configuration

Step-by-step instructions with exact GCC High portal URLs, navigation breadcrumbs, and settings for Entra ID, Intune, Defender, Purview, Exchange, and more.

Evidence Guidance

Per-objective guidance: which screenshot to capture, which portal page, which certification URL to reference.

Progress Dashboard

Track Met / Not Met / NA across all 320 objectives. See your compliance posture at a glance by domain and control.

All 110 Controls. All 320 Objectives.

Complete coverage of NIST 800-171 mapped to CMMC Level 2 — nothing left out, nothing summarized.

This is not a GRC. This is not a template library. This is the finished work — every control, every objective, every solution — mapped specifically to Microsoft 365 GCC High.

When Your Score Gets Checked

Your self-assessment uses the same NIST 800-171A methodology a DIBCAC auditor uses if DoW comes knocking — three assessment methods:

Examine

Documentation gets reviewed: SSP, policies, procedures, system configurations, and evidence artifacts.

Interview

Your team gets asked how controls are implemented and maintained in practice.

Test

Controls get verified to actually function as documented in your environment.

For every one of the 320 assessment objectives, the determination is: Met, Not Met, or Not Applicable.

A DIBCAC audit grades the same 320 objectives you graded yourself. The question is whether your answers survive when someone else checks the math.

CMMC for M365 gives you the documentation, the configuration instructions, and the evidence guidance an audit will ask for — written by a Certified CMMC Registered Practitioner and Microsoft 365 GCC High Expert who knows exactly what holds up under review.

Compare Your Options

CMMC for M365CMMC ConsultantGRC PlatformDIY / AI
Cost$997 once$50K–$150K$10K–$50K/year“Free” + 500 hours
SSP LanguageDone. All 320 objectivesExtra costNot includedYou write it (AI hallucinates)
Policies & ProceduresComplete Word docsExtra costEmpty templatesYou write them
M365 GCC High ConfigStep-by-step with URLsYou still do it yourselfNot includedTrial and error
Evidence GuidancePer-objectiveVerbal adviceNot includedGuesswork
Time to ValueTodayWeeks to monthsWeeks to monthsMonths to never
By PractitionersYes (CRP)VariesNoNo

Is this for you?

Yes, if:

  • You handle CUI for DoD contracts (or will)
  • You’re on Microsoft 365 GCC High (or migrating)
  • You must self-assess against all 110 CUI controls — and want it to hold up if DIBCAC checks
  • You have someone who can implement — even part-time

No, if:

  • You’re on commercial M365 and have no plan to move
  • You only handle FCI — CMMC Level 1’s 15 basic requirements (this covers the 110-control Level 2 list)
  • You need a GRC platform or an auditor — this is reference content, not a tool of record
  • You want someone to do the work for you — we sell the documentation, you implement

Built by Practitioners, for Implementers

CMMC for M365 was built by phraCTO LLC — a team led by a Certified CMMC Registered Practitioner (CRP) and Microsoft 365 GCC High Expert with 25 years of federal IT experience. Every SSP statement, every policy document, every configuration instruction was authored by people who understand both sides of the assessment table.

This isn't generic compliance content repackaged. It's the exact guidance we'd give if you hired us as consultants — at a fraction of the cost.

phraCTO LLC is registered in SAM.gov under CAGE Code 11TR6 — a real federal contractor, not an anonymous brand. Verify us in the public SAM.gov registry before you spend a dollar.

byphraCTO LLC

Common Questions

Is this a GRC tool?+
No. This is an interactive reference document. You read our pre-authored content, copy it into your own SSP or GRC, and follow our instructions to configure Microsoft 365 GCC High. The only thing you edit is a compliance status (Met / Not Met / NA) per objective to track your progress.
Is this specifically for GCC High?+
Yes. Every portal URL, navigation breadcrumb, and configuration instruction is written for Microsoft 365 GCC High — not commercial Microsoft 365. If you’re on GCC High or migrating to it, this is built for you.
CMMC Phase 2 is suspended — do I still need this?+
Yes. The suspension paused the C3PAO certification mandate, not the requirements. DFARS 252.204-7012 still requires all 110 NIST 800-171 controls, you still self-assess and post your score in SPRS, and a senior official still affirms it annually. DIBCAC still audits, and DOJ is actively settling False Claims Act cases against contractors whose self-reported scores didn't hold up. This is the implementation content that makes your self-assessment real. Full breakdown: what the suspension actually changed →
Will this guarantee my self-assessment holds up?+
No tool can guarantee that — your score depends on your actual implementation. What we provide is the complete reference to implement and document every objective honestly, so the score your senior official signs is one you can defend — and you’ll save hundreds of hours of research and tens of thousands of dollars doing it.
Can I preview it before I buy?+
Yes. We give away Control 3.1.1 with all objectives and solutions — free, no signup. Preview it here →
Is this a subscription?+
No. $997 one-time. No monthly fees, no annual renewals, no per-user charges. Pay once, access everything.
Who built this?+
CMMC for Microsoft 365 Tool brought to you by phraCTO LLC. By GovCon, for GovCon. CMMC experts with 25 years of federal IT experience. Years of hands-on Microsoft 365 GCC High expertise. phraCTO LLC is registered in SAM.gov under CAGE Code 11TR6 — verify us in the public SAM.gov registry.

The Audit Deadline Is Gone.The False Claims Act Isn't.

Make the self-assessment your Senior Official signs a defensible one.

One-time payment. Instant access. All 110 controls.