Medicine · CMMC
CMMC for clinical AI workflows
CMMC in clinical AI 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 clinical AI 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.
Clinical committees and health system AI governance.
HHS §1557 · HIPAA · FDA PCCP.
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
RELATED
Related: CMMC: the full guide · CMMC for defense · CMMC for law · CMMC for education