CMMC Level 2 Practice 3.2.1: Ensure that managers, systems administrators, and users of organizational systems are made

CMMC Level 2 Practice 3.2.1 requires you to make managers, system administrators, and users aware of security risks and their security responsibilities before they access or manage organizational systems, and to keep proof that this awareness happens and is maintained. Operationalize it by defining role-based training, delivering it at onboarding and on a recurring cadence, and retaining completion and content records aligned to your CUI environment. ¹

Key takeaways:

• Define “made aware” as role-based security awareness plus rules of behavior that cover CUI-handling systems. ¹
• Evidence matters as much as training; keep rosters, completions, content versions, and exceptions. ²
• Scope to the CMMC boundary and the people who touch it, including IT admins, supervisors, and privileged users. ³

For CMMC Level 2, auditors will not accept “we have a training program” as proof of meeting cmmc level 2 practice 3.2.1: ensure that managers, systems administrators, and users of organizational systems are made requirement. You need a tight, role-aware mechanism that shows three things: (1) who is in scope, (2) what they were told, and (3) when they acknowledged it and completed the required training. This practice maps to NIST SP 800-171 Rev. 2, and assessors commonly test it by sampling a cross-section of users (including privileged accounts) and walking evidence backward from current access to prior training and acknowledgments. ¹

The fastest path is to treat 3.2.1 as an access precondition for the CMMC boundary: no account activation (or no privileged elevation) until the person completes baseline awareness and signs rules of behavior. Then you build depth with role-based modules for managers and system administrators, because those roles introduce different failure modes (approval override, misconfiguration, log tampering, poor incident handling). Keep your artifacts clean, versioned, and easy to produce in an assessment package. ²

Regulatory text

Requirement (excerpted from your source pack): “CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.2.1 (Ensure that managers, systems administrators, and users of organizational systems are made).” ¹

Operator meaning: You must ensure that the people who manage, administer, and use your organizational systems are made aware of the security risks and made aware of their security responsibilities for those systems. “Made aware” must be demonstrable in records, not informal tribal knowledge. This is part of CMMC Level 2’s adoption of NIST SP 800-171 Rev. 2 security requirements for protecting CUI in contractor environments. ⁴

Plain-English interpretation

3.2.1 is your “people control” for baseline cyber hygiene in the CUI environment:

• Users must know acceptable use, CUI handling basics, and how to report issues.
• System administrators must know how their privileged actions can create security impact (misconfigurations, patching, access control, logging, remote admin, backups).
• Managers must understand their responsibilities to enforce policy (approvals, exceptions, resourcing, disciplinary actions for repeated violations).

Assessors look for a repeatable process that reaches everyone in scope and is refreshed, plus proof that it happened. ²

Who it applies to (entity and operational context)

Entities: Defense contractors and other federal contractors handling CUI and pursuing CMMC Level 2. ⁵

In-scope people:

• Employees, interns, and temporary workers with access to the CMMC boundary
• Privileged users (domain admins, cloud admins, M365/GCC High admins, firewall admins)
• Engineering and program staff who handle CUI
• Managers who approve access, exceptions, and process deviations
• Third parties operating systems in your boundary (MSPs, SOC providers, consultants) when their accounts touch your environment

In-scope systems: Organizational systems in the CMMC assessment scope/boundary, especially those that store, process, or transmit CUI. ¹

What you actually need to do (step-by-step)

1) Define scope and roles (so you can prove coverage)

• Pull an authoritative user list from your IdP/HRIS and map each person to one of three role buckets: Manager, System Administrator, User.
• Define what counts as “system administrator” in your environment (AD/Azure, endpoint management, network, cloud, security tooling).
• Identify third-party accounts and classify them by role as well.

Deliverable: Role mapping spreadsheet or GRC register with owner, role, systems accessed, and boundary membership.

2) Define “security awareness” content requirements per role

Build a short control statement that ties training to the risks and responsibilities relevant to your environment. Keep it concrete:

• All users: phishing/social engineering, password/passphrase and MFA expectations, data handling and labeling for CUI, removable media rules, reporting suspected incidents, physical security basics.
• Managers: access approval responsibilities, exception process, enforcing completion, reporting obligations, protecting CUI in business processes (meetings, travel, printing).
• Sysadmins: privileged access hygiene, secure configuration baselines, change control linkage, patch expectations, logging and monitoring expectations, remote administration rules, backup handling, least privilege.

Deliverable: Role-based training standard with module titles, learning objectives, and required acknowledgments. ¹

3) Make it an access gate (operational control, not a memo)

• Require training completion and rules-of-behavior acknowledgment before granting initial access to the CMMC boundary.
• For privileged roles, require completion before privileged group membership or role assignment.
• Put the gate in the joiner/mover workflow (ITSM ticket templates, HR onboarding checklist, IdP automation where possible).

Deliverable: Documented joiner/mover process showing the training/acknowledgment checkpoint.

4) Deliver training and capture attestations

• Use an LMS or equivalent system that records completion, date, and the content version.
• Require acknowledgment of key policies (acceptable use, CUI handling rules, incident reporting path).
• Ensure remote and onsite staff receive the same baseline coverage.

Deliverable: Completion reports and policy acknowledgment records, tied back to the user list. ²

5) Handle exceptions explicitly (avoid silent noncompliance)

You will have edge cases: long-term leave, contractors who cannot access your LMS, or emergency privileged access.

• Define who can grant an exception and for how long.
• Require compensating controls (supervised access, temporary accounts, rapid completion requirement).
• Track exceptions as tickets with closure criteria.

Deliverable: Exception log with approvals and closure evidence.

6) Run a recurring effectiveness check

Assessors may test whether your program is alive:

• Sample completions against current access lists (especially privileged users).
• Confirm terminated users are removed and don’t show as “active but untrained.”
• Validate training content is current to your policy set and boundary tools.

Deliverable: Quarterly (or other defined cadence) internal review record and remediation tickets.

Required evidence and artifacts to retain

Keep evidence in a package you can hand to an assessor without scrambling:

Governance artifacts

• Security awareness and training policy/standard mapped to 3.2.1 ¹
• Role definitions for manager/admin/user
• Rules of Behavior / Acceptable Use acknowledgments

Operational evidence

• Training content outline and version history (slide deck, LMS module export)
• Training completion logs (user, role, date, score if applicable)
• New hire onboarding checklist showing training gate
• Privileged access request tickets showing training prerequisite verification
• Exception tickets and closure evidence

Scoping evidence

• CMMC boundary statement and in-scope user population list (as of assessment date) ²

Tip from practice: store a “point-in-time” export of your user roster near assessment to avoid drift arguments during sampling.

Common exam/audit questions and hangups

Expect questions like:

• “Show me the list of in-scope users and proof they completed training.”
• “How do you ensure sysadmins receive admin-specific training, not just generic awareness?”
• “Prove training happens before access is granted.”
• “How do you cover third-party administrators or MSP personnel?”
• “What happens when someone fails training or refuses acknowledgment?”

Common hangup: teams produce a generic annual training certificate but cannot show (a) role tailoring or (b) linkage to access provisioning. That gap is where 3.2.1 often fails in practice. ²

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating 3.2.1 as “annual HR training only”	Doesn’t prove admins/managers were made aware of role risks	Add role modules and role-based assignments in the LMS 1
No tie to access	People can have accounts while overdue	Add an onboarding/privileged elevation gate in ITSM/IdP workflows
Missing third-party coverage	External admins are still “users” of your systems	Include third-party accounts in the roster and require equivalent training/attestations
No version control on content	You can’t show what people were told at the time	Keep content hashes/versions and archive prior modules
Informal exceptions	Creates silent noncompliance	Use ticketed, time-bounded exceptions with compensating controls

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, the risk is assessment failure or conditional findings if you cannot prove that in-scope personnel were made aware of responsibilities tied to CUI systems, especially for privileged roles. CMMC requirements flow through contracting expectations under the CMMC program framework. ⁵

Practical 30/60/90-day execution plan

First 30 days (establish control and scope)

• Define CMMC boundary user populations and role taxonomy (manager/admin/user). ²
• Publish/update security awareness & training standard mapped to 3.2.1. ¹
• Stand up evidence capture: LMS reporting, acknowledgment tracking, roster exports.

Days 31–60 (implement gating and role-based delivery)

• Implement onboarding gate in ITSM/HR checklist; block access until completion.
• Add privileged elevation gate: no admin roles without admin training completion.
• Roll out role-based modules and collect acknowledgments.

Days 61–90 (prove operation and readiness)

• Run an internal sampling drill: pick users from each role and build an “assessor packet” in under an hour.
• Close gaps: exceptions without tickets, privileged users missing admin module, stale rosters.
• Schedule recurring reviews; assign owners; set a cadence aligned to your access review process.

If you use Daydream to manage control-to-evidence mapping, set 3.2.1 as a recurring evidence control with automated reminders for roster export, LMS completion pulls, and exception log updates, so you always have assessment-ready artifacts. ²

Frequently Asked Questions

Does 3.2.1 require annual training?

The requirement is to ensure managers, sysadmins, and users are made aware of risks and responsibilities. Many organizations meet this through onboarding plus recurring refreshers, but you must define and follow your cadence and retain proof. ¹

Can I satisfy 3.2.1 with a signed policy only?

A signed policy helps, but assessors typically expect training or awareness activities plus acknowledgment records and completion logs that show people were actually informed. Pair policy acknowledgment with assigned training and reporting. ²

How do we handle managed service providers and other third parties?

If third-party personnel access your CMMC boundary, treat them as in-scope users or administrators. Require equivalent awareness content and retain their completion/attestation evidence, or contractually require it and obtain records. ¹

What counts as “manager” for this practice?

Treat anyone who approves access, exceptions, or supervises teams handling CUI as a manager for training purposes. Document your definition and apply it consistently to avoid sampling failures. ¹

What’s the minimum evidence assessors will accept?

Maintain a current in-scope roster, training assignments by role, completion exports with timestamps, and the content version shown to each learner. Add onboarding/privileged access tickets to prove the control operates in daily workflows. ²

We have multiple environments; do we scope training to just the CUI enclave?

Scope must cover the people who can access or administer systems in the CMMC boundary. If staff move between environments or have shared admin tooling, scope training to the access path, not the org chart. ²

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170

4. NIST SP 800-171 Rev. 2; 32 CFR Part 170

5. 32 CFR Part 170; DoD CMMC Program Guidance