# Contractors Assess FedRAMP Scope for CUI Software

A practitioner discussion on tenant-installed UI software concludes that local installation alone does not trigger a separate FedRAMP authorization solely because the software is used with CUI. The key procurement and security question is whether a cloud service provider’s service stores, processes, or transmits CUI. Under the cited DFARS cloud-computing requirements, a service may need FedRAMP Moderate authorization or an accepted equivalent if CUI reaches a vendor cloud or the vendor remotely manages a service handling it.

- Contractors should verify telemetry, licensing, synchronization, and remote-management data flows to determine whether a vendor cloud service handles CUI.
- Document relevant data flows in the system security plan and data-flow diagram; the authorization question concerns the service handling CUI, not simply where the UI software is installed.
- This distinction can inform software reviews and CMMC assessment preparation by helping teams identify which cloud services may require authorization or an accepted equivalent.

**Jurisdictions:** federal
**Industries:** Information Technology
**Topics:** Cybersecurity, Regulatory Compliance
**Published:** November 05, 2026

### Government Entities
- U.S. Department of Defense (DoD)

### Vendors
- Kailash Consult (CMMC assessment-preparation consultant)

### Key Quotes
> That changes if the software phones home, syncs data to the vendor's cloud, or the vendor manages it remotely. In those cases CUI is being stored or processed in their service, and that service needs FedRAMP Moderate or equivalency.
> — Community commenter (username not provided)

> If CUI is PSTed on that laptop it's a CUI asset.
> — Community commenter (username not provided; self-identified CMMC Certified Professional)

### Sources
- [Do tenant-installed UI software need its own FedRAMP authorization?](https://www.reddit.com/r/CMMC/comments/1xohocu/do_tenantinstalled_ui_software_need_its_own) - reddit-cmmc