Education · CMMC
CMMC for tutor and grader workflows
CMMC in tutor and grader workflows: what compliance requires, who asks for evidence, and the records to keep.
01 / The rule
What CMMC requires
Defense contractors and subcontractors that process, store or transmit Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) on contractor systems.
- 01Level 1: annually self-assess against the 15 FAR 52.204-21 safeguarding requirements and affirm in SPRS.
- 02Level 2: meet the 110 NIST SP 800-171 Rev. 2 requirements, by self-assessment or C3PAO assessment every three years.
- 03Level 3: hold Level 2 certification plus a government (DIBCAC) assessment of 24 NIST SP 800-172 requirements.
- 04Post results in SPRS and have a senior official affirm compliance annually.
- 05Give the contracting officer the CMMC unique identifiers (UIDs) for systems handling FCI or CUI and report any changes to them during performance (DFARS 252.204-7021(e), NOV 2025).
- 06Flow down the required CMMC level to subcontractors handling FCI or CUI.
02 / In this sector
In a tutor and grader workflow
Applies to AI systems as to any system: AI tools, models or cloud AI services that process FCI or CUI fall inside the assessed boundary and must meet the same controls.
District administrators, school leaders, and student equity teams.
Title VI · FERPA · §504 / IDEA.
03 / Records
Records to keep
- 01System security plan covering the assessment boundary
- 02SPRS score and annual affirmation records
- 03Plan of action and milestones with closeout dates
- 04CMMC certificate or self-assessment results and UID
Optional evidence · where Planisphere fits
Keep a record anyone can check
When your team meets a duty, Planisphere can seal the event it reports as a receipt.
A disclosure shown, a review signed, a model change approved: the event your system reports.
The event becomes a sealed receipt, dated and attributed to whoever is signed in.
Paste the receipt into Verify. No account or key.
A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.
SOURCES
Go back to the source
Holland & Knight
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Related: CMMC: the full guide · CMMC for defense · CMMC for medicine · CMMC for law