- 1191 Patuxent Greens Laurel Maryland 20708
- +1 (301) 821-7362
- contact@nabayasolutions.com
Governance, Risk & Compliance (GRC)
SOC 2 Readiness & Support
Comprehensive preparation for SOC 2 Type I and Type II audits, ensuring your organization meets Trust Services Criteria.

Our Approach
Readiness assessment and gap analysis
Control framework design and implementation
Policy and procedure development
Evidence collection and management
Vendor and auditor coordination
Pre-audit readiness review
Continuous compliance support
Trust Service Categories We Address
need 24/7 protection from cyber attack?
ISO 27001 Readiness
Structured preparation for ISO 27001 certification, establishing an Information Security Management System (ISMS).
Our Services
- Current state assessment against ISO 27001 requirements
- ISMS framework development
- Risk assessment and treatment planning
- Statement of Applicability (SoA) development
- Internal audit preparation
- Management review facilitation
- Certification audit support
NIST 800-53 / 800-171 Compliance
Implementation support for NIST frameworks commonly required for federal contractors and organizations handling controlled information.
Our Expertise
- NIST 800-53 control implementation for federal information systems
- NIST 800-171 compliance for protecting Controlled Unclassified Information (CUI)
- System Security Plan (SSP) development
- Plan of Action and Milestones (POA&M) management
- Continuous monitoring program establishment
- Assessment and Authorization (A&A) support
Preparation for Cybersecurity Maturity Model Certification required for Department of Defense contractors.
Our Approach
- CMMC level determination based on contract requirements
- Gap assessment against applicable CMMC practices
- Practice implementation and documentation
- Internal readiness assessment
- C3PAO preparation support
- Continuous compliance maintenance


CMMC Levels We Support
- Level 1: Foundational (17 practices)
- Level 2: Advanced (110 practices)
- Level 3: Expert (130 practices)
Policy Development & Program Buildout
Creation of comprehensive security and compliance documentation that reflects actual practices and supports audit requirements.
Our Deliverables
- Information security policies
- Standard operating procedures
- Work instructions and guidelines
- Acceptable use policies
- Incident response procedures
- Business continuity and disaster recovery plans
- Risk management frameworks
- Security awareness training materials
Third Party Risk Management (TPRM)
Systematic assessment and ongoing monitoring of vendor and partner security practices.
Our Services
- Vendor risk assessment framework development
- Security questionnaire design and management
- Vendor security reviews and due diligence
- Contract language for security requirements
- Continuous monitoring processes
- Vendor remediation tracking
- Annual reassessment programs
Data Privacy Compliance
Strategic guidance and implementation support for data privacy regulations.
Frameworks We Support
- GDPR (General Data Protection Regulation)
- CCPA/CPRA (California Consumer Privacy Act)
- State-specific privacy laws
- Cross-border data transfer requirements
- Data subject rights management
- Privacy impact assessments
- Data mapping and inventory
HIPAA Compliance
Comprehensive support for healthcare organizations and business associates handling protected health information (PHI).
Our Services
- HIPAA Security Rule compliance assessment
- Privacy Rule implementation support
- Breach Notification Rule guidance
- Business Associate Agreement (BAA) review
- Risk analysis and risk management plan
- HIPAA Security Awareness training
- Ongoing compliance monitoring
CMS 912 Audit & JSM Audit Support
Specialized support for healthcare organizations undergoing CMS security assessments and Joint Security Management audits.
Our Expertise
- CMS Acceptable Risk Safeguards (ARS) compliance
- Security Risk Assessment (SRA) completion
- JSM audit preparation and support
- Controls Assurance Questionnaire completion
- Evidence collection and documentation
- Remediation planning and execution

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Frequently Asked Questions
NABAYA Solutions is headquartered at 1191 Patuxent Greens, Laurel, Maryland 20708, and serves clients throughout the United States both on-site and remotely. Our Maryland location gives us particular depth in the DC–Maryland–Virginia (DMV) federal contracting corridor. One of the highest concentrations of CMMC-regulated defense contractors, CMS-connected healthcare organizations, and federal agencies in the country.
Key markets we serve:
— Maryland, Northern Virginia, and Washington DC (federal and defense contractor stronghold)
— National, all 50 states for remote engagements
— International compliance requirements including GDPR and cross-border data transfer regulations
If you are a DoD contractor, healthcare organization, or government-adjacent entity in the mid-Atlantic region, NABAYA Solutions is uniquely positioned to serve you, with local knowledge of the DMV regulatory environment and established relationships with regional C3PAOs and auditors.
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SOC 2 (System and Organization Controls 2) is an auditing framework developed by the AICPA that evaluates how a service organization protects customer data. It has become the baseline compliance requirement for SaaS companies, cloud service providers, and technology vendors serving enterprise customers — particularly in the US.
You need SOC 2 if:
— Enterprise customers or prospects require it as a condition of doing business
— You handle sensitive customer data (financial, health, personal, or regulated data)
— You are in a competitive market where compliance is a sales differentiator
— Your contracts include security or compliance obligations to customers
SOC 2 Type I is a point-in-time assessment confirming your controls are designed appropriately. SOC 2 Type II evaluates that controls operated effectively over a defined period (typically 6–12 months) and is the standard required by most enterprise customers. NABAYA has delivered SOC 2 Type II certification for a Fortune 500 healthcare organization within a 6-month deadline, unlocking $50M+ in new enterprise sales.
SOC 2 timelines depend on your current security maturity and the scope of required controls.
SOC 2 Type I (point-in-time): 3 – 4 months from initial gap assessment to completed audit report for organizations with basic controls already in place. Organizations starting from minimal documentation may need 4–6 months.
SOC 2 Type II (period of coverage): 6 – 12 months total, typically 2–3 months of readiness work followed by a 6-month observation period before the audit is completed.
NABAYA's SOC 2 readiness process:
1. Readiness assessment and gap analysis against your required Trust Services Criteria
2. Control framework design and implementation
3. Policy and procedure development
4. Evidence collection and management systems
5. Vendor and auditor coordination
6. Pre-audit readiness review and final preparation
7. Ongoing managed compliance support to maintain certification year-over-year
If you have a specific deadline, a contract requirement, an enterprise RFP, or a funding milestone, NABAYA Solutions works backward from your deadline to build an accelerated plan. Tell us your timeline and we will tell you whether it is achievable.
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GRC — Governance, Risk, and Compliance, is the integrated framework through which organizations establish security governance structures, systematically identify and manage operational and cyber risk, and demonstrate compliance with applicable regulations, standards, and contractual obligations.
Governance defines who owns security decisions, accountability structures, and board-level oversight. Risk Management identifies threats, quantifies their business impact, and implements controls to reduce risk to acceptable levels. Compliance ensures those controls satisfy the specific requirements of applicable frameworks: SOC 2, CMMC, HIPAA, NIST, ISO 27001, and others.
Every organization that handles sensitive data, operates in a regulated industry, holds government contracts, or serves enterprise customers needs a formal GRC program. Without one, organizations face regulatory fines, audit failures, contract loss, and the reputational damage of a preventable breach. NABAYA builds GRC programs designed not just to pass audits but to genuinely reduce risk and create lasting security value.
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SOC 2 is built around five Trust Services Criteria (TSC). Security is the only mandatory category; the other four are selected based on your services and customer requirements:
Security (CC): Required for all SOC 2 audits. Covers protection of systems against unauthorized access, both logical and physical. This is the foundation of every SOC 2 engagement.
Availability (A): Required if your customers depend on your system being operational. Covers uptime commitments, performance monitoring, and incident response.
Processing Integrity (PI): Required for organizations processing financial transactions or data that must be accurate and timely (payroll, e-commerce, financial reporting).
Confidentiality (C): Required when you've made contractual commitments to protect specific categories of confidential information.
Privacy (P): Required if you collect, store, use, or share personal information subject to privacy commitments or regulations.
NABAYA addresses all five trust service categories. During the readiness assessment, we help you determine which categories your customers and contracts require, avoiding unnecessary scope expansion while ensuring you meet every contractual obligation.
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NABAYA's CMMC readiness process is structured to leave nothing to chance on audit day:
Step 1: CMMC Level Determination: We review your contracts to confirm the applicable CMMC level, CUI categories, and assessment scope.
Step 2: Gap Assessment: We evaluate your current controls against all applicable CMMC practices (17, 110, or 130+ depending on level), producing a detailed gap analysis with prioritized remediation items.
Step 3: Practice Implementation & Documentation: We implement required technical controls, write your System Security Plan (SSP), develop Plans of Action and Milestones (POA&M), and create the complete evidence library the C3PAO will review.
Step 4: Internal Readiness Assessment: We conduct a simulated C3PAO-style internal assessment to identify any remaining gaps before the official audit.
Step 5: C3PAO Coordination: We coordinate with your selected C3PAO, prepare your team for the assessment process, and provide support throughout the audit.
Step 6: Continuous Compliance Maintenance: Post-certification, NABAYA provides ongoing monitoring to prevent compliance drift and prepare for reassessment cycles.
NABAYA has helped federal contractors protect millions in annual DoD contract revenue through CMMC Level 2 certification. Our Maryland location means we work with C3PAOs and contractors in the DC-area defense corridor routinely.
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Controlled Unclassified Information (CUI) is government-created or government-owned information that requires safeguarding or dissemination controls per law, regulation, or government-wide policy but is not classified. Examples include technical drawings, export-controlled data, personally identifiable information (PII), and certain contract performance data.
Why CUI determines your CMMC level: If your organization creates, processes, stores, or transmits CUI in the performance of a DoD contract, you must achieve CMMC Level 2 at minimum. NABAYA begins every CMMC engagement with a formal CUI scoping exercise mapping where CUI enters your environment, how it flows, where it's stored, and who has access, because the CUI boundary determines the assessment scope and, ultimately, the cost and complexity of achieving certification.
Many contractors are unaware that CUI can exist in email systems, collaboration tools (SharePoint, Teams), and endpoints outside the core IT environment. NABAYA Solutions CUI scoping methodology follows NIST SP 800-171 guidance and DoD CUI policy to establish a defensible, auditable scope boundary.
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HIPAA (Health Insurance Portability and Accountability Act) establishes federal standards for protecting Protected Health Information (PHI) and applies to two categories of organizations:
Covered Entities: Health plans, healthcare clearinghouses, and healthcare providers that electronically transmit health information including hospitals, physician practices, health insurance companies, and state Medicaid agencies.
Business Associates: Any person or organization that creates, receives, maintains, or transmits PHI on behalf of a covered entity including IT vendors, cloud providers, billing companies, EHR developers, and consulting firms with access to PHI systems.
HIPAA compliance requires satisfying three rules:
— Security Rule: Administrative, physical, and technical safeguards for electronic PHI (ePHI)
— Privacy Rule: Standards for how PHI can be used, disclosed, and protected
— Breach Notification Rule: Requirements to notify patients, HHS, and sometimes the media within 60 days of a breach
Penalties range from $137 – $2.06M per violation category per year for willful neglect. NABAYA Solutions HIPAA compliance services cover all three rules for both covered entities and business associates.
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The Statement of Applicability (SoA) is one of the most important documents in an ISO 27001 certification and one that auditors scrutinize closely. It formally documents which of the 93 controls in Annex A of ISO 27001:2022 are applicable to your organization, which are implemented, which are excluded, and the justification for each decision.
The SoA serves as the bridge between your risk assessment results (which risks need treatment?) and your control selection (which controls treat those risks?). It must be maintained as a living document throughout the lifecycle of your ISMS.
Common mistakes organizations make with the SoA:
— Including all 93 controls without genuine applicability assessment (auditors flag this)
— Excluding controls without documented justification
— Not keeping the SoA synchronized with actual control implementation status
NABAYA develops your SoA as part of the ISO 27001 readiness engagement ensuring every inclusion, exclusion, and implementation status is defensible, documented, and auditor-ready.
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CMS 912 refers to CMS's (Centers for Medicare & Medicaid Services) security assessment process under the CMS Acceptable Risk Safeguards (ARS) framework. The CMS ARS is a comprehensive security control catalog derived from NIST 800-53 that governs information security for all systems that connect to, process, or transmit CMS data, including Medicare, Medicaid, CHIP, and ACA Marketplace systems.
Organizations subject to CMS 912 include:
— Health plans and insurers operating in the Medicare/Medicaid space
— State Medicaid agencies and their IT contractors
— Healthcare IT vendors whose systems connect to CMS infrastructure
— Managed care organizations (MCOs) with CMS contracts
— ACA Marketplace issuers and their technology partners
CMS 912 / JSM audit requirements include:
— CMS ARS control implementation and documentation
— Security Risk Assessment (SRA) aligned to CMS requirements
— Controls Assurance Questionnaire (CAQ) completion
— Evidence collection and audit documentation package
— Remediation planning and execution for identified deficiencies
This is a highly specialized compliance area: very few consulting firms have meaningful CMS 912 experience. NABAYA has served healthcare organizations in the Maryland healthcare corridor through multiple CMS 912 audit cycles. Our team knows what CMS assessors look for and where organizations most commonly fail.
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Every major compliance framework requires a documented policy library but the specific policies vary by framework. NABAYA develops a comprehensive policy suite tailored to your applicable frameworks:
Core policies required across most frameworks:
— Information Security Policy (the overarching governance document)
— Acceptable Use Policy (AUP)
— Access Control Policy
— Data Classification Policy
— Incident Response Policy and Procedures
— Business Continuity and Disaster Recovery Plan
— Risk Management Policy and Framework
— Vendor / Third-Party Security Policy
Framework-specific additions:
— HIPAA: Privacy Policy, Breach Notification Procedures, BAA templates
— CMMC / NIST: Configuration Management Policy, System and Communications Protection procedures
— SOC 2: Change Management Policy, Logical Access Policy, Monitoring and Logging procedures
— ISO 27001: ISMS scope document, Risk Treatment Plan, Corrective Action procedures
Every policy NABAYA develops is operationally grounded — reflecting how your organization actually works, not generic templates that fail under auditor questioning. We also provide security awareness training materials to ensure staff understand and follow the policies.
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Third-Party Risk Management (TPRM) is the systematic process of identifying, assessing, and continuously monitoring the security and compliance risks introduced by vendors, partners, subcontractors, and service providers who access your systems or handle your data. Your organization's compliance posture is directly affected by your vendors' security practices and regulators hold you responsible for failures in your supply chain.
TPRM is required by nearly every major compliance framework:
— SOC 2: Vendor management is explicitly required under the Availability and Security criteria
— ISO 27001: Annex A includes supplier relationships as a required control domain
— HIPAA: Business Associate management and BAA requirements are a core obligation
— CMMC: Supply chain risk management practices are embedded throughout Level 2 and Level 3
— NIST 800-53: Supply chain risk management (SCRM) is a dedicated control family
NABAYA's TPRM services include:
— Vendor risk assessment framework development
— Security questionnaire design and management (scaled by vendor risk tier)
— Vendor security reviews and due diligence
— Contract language for security and compliance obligations
— Continuous vendor monitoring processes
— Vendor remediation tracking and annual reassessment programs
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