CMMC Compliance and Securing Financial Systems for DoD

Rose Report: Issue 41

BY TED ROSE, ROSE FINANCIAL SOLUTIONS

We’re all aware of the growing number of cybersecurity and data breach concerns our nation faces. According to Ellen Lord, the undersecretary of defense for acquisition and sustainment, “Cybersecurity risks threaten the industrial base, national security, as well as partners and allies.” To mitigate cyber threats, in January 2020, the Department of Defense (DoD) established the Cybersecurity Maturity Model Certification (CMMC). The CMMC is far-reaching and will impact approximately 300,000 firms in the Defense Industrial Base (DIB) that will need to meet the new standards in order to seek contracts.

The CMMC is comprised of multiple maturity levels that range from “Basic Cybersecurity Hygiene” to “Advanced/Progressive.” According to the DoD, CMMC is intended to serve as a verification mechanism to make sure appropriate levels of cybersecurity practices and processes are in place to ensure basic cyber hygiene as well as protect Controlled Unclassified Information (CUI) that resides on the Department’s industry partners’ networks. Along with CUI, the CMMC aims to protect Federal Contract Information or FCI. This is information provided by or generated for the U.S. government under a contract that is not intended for public release.

CMMC Compliance and Your Financial Systems

As you prepare your company to meet the new standards, it’s important that you do not overlook your accounting and financial systems. Keep in mind it is highly likely that your financial systems include FCI. As such, CMMC would require that your financial systems meet at least Level 1 practices. FCI will likely impact accounting, HR, payroll, email contracts, and BDS systems. You’ll need to consider exactly how this will affect your hosted accounting software and email services as well as your other service providers’ systems. Your goal should be to maintain at least the CMMC Level 1, in some cases, it may be necessary to move to Level 3.

CUI will be defined by your contract. You should discuss your contract with your contracting officer to clarify the presence of CUI. If your financial systems include CUI, you will require to maintain at least CMMC Level 3. If possible, eliminating CUI from your financial systems will reduce the CMMC requirement from Level 3 to Level 1. If this can be accomplished, we recommend that you follow a similar procedure that we see currently utilized for classified information, including using redactions, code words for contract names, and similar tactics. For more information on CUI, visit the National Archives website.

When implementing CMMC standards, make sure that you source providers with CMMC awareness and adequately-compliant financial systems. In October 2020, the DoD issued an interim rule implementing CMMC cyber rules for all DoD contractors. Effective November 30, 2020 contractors may not be awarded contracts, nor can they award sub-contracts, unless they, and their subcontractors, have performed self-assessments and reported those results to a DoD website. Third party verification will be required on certain contracts and will be rolled out and required on all contracts by September 30, 2025. Please consult with your accountant about all of these issues as soon as possible. CMMC implications are rapidly evolving, and this article represents the information that we have up to the date of the article being published.

Ensure your financial systems are CMMC compliant and ready for DoD contracts. Partner with Rose Financial Solutions for expert guidance in navigating these complex requirements. Contact us today to secure your financial systems and stay ahead of compliance demands.

Ted Rose

President, CEO, and Founder

Ted Rose is President, CEO, and Founder of Rose Financial Solutions (RFS). Ted founded RFS 26 years ago and is a recognized pioneer in finance and accounting outsourcing (FAO) and related accounting technologies. RFS is the leader in the next generation of FAO called Finance as a Service for Government Contractors. RFS’ GovCon FaaS encompasses the full range of GovCon/DCAA finance and accounting solutions including full lifecycle compliance for start-ups to $100 million GovCons. For more information please visit: rosefinancial.com.

Ted's Bio

< Older Post

Newer Post >

Share this article:

Visit Us On:

Rose Financial Solutions Empowers Fractional CFOs and CPA Firms to Support Clients with Scalable, AI-Enabled Financial Infrastructure

September 4, 2025

Rose Financial Solutions (“ROSE®”), a pioneer in Finance as a Service ( FaaS ), today announced new strategic partnerships designed to empower fractional CFOs and CPA firms to support clients with scalable financial infrastructure. Through alliances with Apex Finance Solutions, CFO Advisory DC, CTM Partners, and Rubino & Company , ROSE is expanding access to scalable, AI -enabled solutions that simplify financial operations and amplify the value advisors deliver to growing businesses. “Fractional CFOs and CPA firms are critical growth partners for businesses, but they shouldn’t have to build financial infrastructure on their own,” said Ted Rose, President, CEO, and Founder of ROSE . “With these partnerships, we’re giving them access to enterprise-grade tools that drive efficiency, scalability, and insight—so they can remain focused on their most important role: trusted advisors.” At the center of these partnerships is ROSE’s Finance as a Service ( FaaS ) model, which integrates People, Process, Technology, Organization, and Data . This framework simplifies back-office operations while empowering financial leaders with real-time insights, audit-readiness, and proactive decision-making . All four partners now gain access to Easby ® , ROSE’s AI-powered, enterprise-grade automation platform that seamlessly integrates with accounting systems to transform financial data into actionable intelligence. Meet the Partners Apex Finance Solutions : Guides high-performing entrepreneurs with executive-level financial leadership. With Easby®, Apex enhances its strategic advisory capabilities through real-time data insights. CFO Advisory DC : Brings a global perspective from private equity, impact investing, and strategy consulting. Easby strengthens its ability to deliver operational excellence and scalable growth strategies. CTM Partners : Specializes in driving scalable growth and operational efficiency through financial leadership. By leveraging ROSE’s FaaS model, CTM expands client visibility and decision-making agility. Rubino : A Maryland-based CPA firm delivering audit, tax, and CFO consulting expertise (through their CAS – Client Accounting Services). By integrating Easby, Rubino enhances compliance readiness while delivering deeper client insights. “This is just the beginning of our CFO and CPA partner network buildout,” added Rose. “Our goal is to ensure every growth focused organization in the nation has access to the same level of sophistication and scalability as enterprise finance teams—without the cost or complexity. Our nationwide network will reshape the way financial leaders deliver trusted, data-driven advisory services.” About Rose Financial Solutions ROSE is a leading provider of Finance as a Service (FaaS – next generation of finance and accounting outsourcing) , helping businesses simplify financial operations by aligning People, Process, Technology, Organization, and Data . Its enterprise-grade AI-enabled automation platform, Easby® , transforms financial data into actionable insights, enabling companies to scale with confidence and agility. With ROSE and Easby, organizations achieve audit readiness, operational efficiency, and data-driven decision-making—redefining the future of finance and accounting. To learn more about how ROSE and Easby® can transform your financial operations, visit www.rosefinancial.com and www.easby.ai . Ready to empower your firm with enterprise-grade financial infrastructure? Contact us today to explore partnership opportunities.

ROSE Report: Transforming Accounting into a Growth Engine

By Ted Rose • August 29, 2025

Issue 98 - Transforming Accounting into a Growth Engine

7 Red Flags It’s Time to Upgrade Your GovCon Accounting Software

By Ted Rose • August 29, 2025

For growing government contractors, an outdated accounting system isn’t just inefficient—it can be a threat to your business. Whether you're using QuickBooks or a legacy ERP, failing to adapt your systems as you scale can lead to compliance failures, cash flow issues, and missed growth opportunities.