Funder terms decoder

We keep grant-funded programs funder-ready so you keep the grant. Contract boilerplate is not a certification demand — most of it means verify your vendors or produce an evidence pack.

  • “FedRAMP and GovRAMP are badges for the companies you buy software from — your job is to verify theirs, not earn your own.”
  • “The frameworks that land on your desk are NIST 800-171 flow-down, CMMC if you touch DoD data, and SOC 2 if you handle data for others.”

Federal / DoD pass-through

“Contractor shall comply with NIST SP 800-171”

A written 800-171 program if CUI is in scope — SSP, POA&M, and annual affirmation. Without CUI, this often means a self-attestation, not a 3PAO assessment.

Who is obligated: Your organization

State / federal RFPs

“Offeror must demonstrate FedRAMP-compliant infrastructure”

Your cloud vendors must be FedRAMP-authorized — not you. Your job is to verify and document their status.

Who is obligated: Your vendors (you verify)

SLED contracts

“Vendor must meet state cloud security standards (GovRAMP / StateRAMP)”

Same as FedRAMP, at the state level. Check whether the contracting agency participates in GovRAMP.

Who is obligated: Your vendors (you verify)

Most foundations and many state grants

“Provide evidence of a security program”

A questionnaire or attestation plus an evidence pack (policies, access reviews, training records) — not a certification.

Who is obligated: Your organization

Health / data-handling orgs

“Comply with applicable laws re: data protection”

HIPAA if you are a covered entity or business associate; state breach-notice laws; CCPA-style rules if you hold California resident data.

Who is obligated: Your organization

DoD / GSA

“Subcontractors subject to the same terms”

Flow-down: vendors who touch the same data need the same verification chain (GSA CUI rule, effective Jan 5, 2026).

Who is obligated: Your vendors, documented by you

Federal / state contracts

“Cyber incident notification within 72 hours”

A written incident-response plan with a notification SLA — and a drill in the last 12 months.

Who is obligated: Your organization

Many state agencies

“Maintain cybersecurity insurance”

A policy in force with stated minimum limits, plus renewal proof for the funder.

Who is obligated: Your organization

Which framework actually lands on your desk

FrameworkApplies whenObligated
NIST 800-171CUI is in scope on a federal contract or flow-downYour organization
CMMC 2.0DoD contract with CUI (Level 2) or FCI (Level 1)Your organization; a 3PAO assesses Level 2 (Phase 2 deadline Nov 2026)
SOC 2You act as a service org / data intermediary for partners or beneficiariesYour organization; a CPA audits
GovRAMP / state RAMPYou buy cloud services used in state workYour vendors — not you
FedRAMP 20xYou buy cloud services used in federal workYour vendors — not you
HIPAACovered entity or business associateYour organization

Decoder rules

  • Never read a clause as stricter than it is. Over-reading sells fear; grant budgets are not fear-shaped.
  • Never read it looser than it is. If CUI flows, 800-171 is real and CMMC Level 2 may follow (Nov 2026).
  • Every clause maps to: obligation → who is obligated (org vs vendor) → evidence → deadline.

Paste a clause into the scorecard agent (choose “Decode a clause”) for a draft reading.

Last Myle advises and prepares. We do not certify, authorize, or act as a 3PAO or CPA firm. Agents draft; a named consultant reviews every client-facing deliverable. We do not take custody of your evidence or CUI — data stays in your tenant. Talk to a human.

© 2026 Last Myle LLC.