On October 15, 2024, the United States Department of Defense (DoD) published the Final Rule for the Cybersecurity Maturity Model Certification (CMMC) in the federal register, signifying the completion of a long-awaited rule-making process. The CMMC program was then subjected to a mandatory 60-day public review, eventually becoming operational on December 16, 2024.  

The new CMMC framework, known as CMMC 2.0, features several improvements from its previous version. A notable update was the reduction of maturity levels from five to three.  

Organizations Seeking Certification (OSCs) for CMMC Level 1 may self-assess and affirm their cybersecurity compliance annually. However, any Defense Industrial Base (DIB) company seeking certification for higher CMMC levels must have its cybersecurity infrastructures audited by agencies known as CMMC third-party assessor organizations (C3PAOs).  

Engaging a C3PAO lets you benefit from professional and unbiased cybersecurity audits. However, C3PAO-led assessments can take several weeks to complete and may significantly impact your operations in the meantime.  

To ensure operational continuity, preparing adequately for these evaluations is essential. This post lists five critical tips for preparing for a seamless C3PAO CMMC assessment.  

 

Who Is A C3PAO?

CMMC third-party assessor organizations are agencies accredited by the CMMC Accreditation Body (CMMC AB) to spearhead CMMC audits on behalf of the Department of Defense. A CMMC C3PAO’s mandate is to ensure that defense contractors implement the necessary controls for safeguarding sensitive information.  

Organizations seeking CMMC certification must pass C3PAO assessments to qualify for defense tenders. Besides, existing vendors who fall short of the CMMC requirements under their maturity levels may have their contracts terminated in addition to other prescribed penalties.  

To become a certified CMMC C3PAO, an organization must meet stringent accreditation requirements by both the Cyber AB and the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). During accreditation, the agency must prove it possesses the relevant expertise and tools to conduct impartial cybersecurity assessments.  

The CMMC AB also stipulates requirements for a duly constituted C3PAO. For instance, the agency must maintain a workforce comprising at least the following professionals; 

• Certified CMMC Assessors (CCAs), who serve as the lead assessors 
• Certified CMMC Professionals (CCPs) who work directly under CCAs 
• CMMC Quality Assurance Professionals, who ensure all CMMC audits adhere to the industry’s best standards 

Now, conducting successful CMMC assessments is just as rigorous as the C3PAO accreditation process. The following section explores the five things to get out of the way before engaging a C3PAO.

1. Scope for Sensitive Information

Scoping your organization’s systems for sensitive information is critical before contacting a CMMC C3PAO.  

CMMC primarily targets two federally designated sensitive information classes: Federal Contract Information (FCI) and Critical Unclassified Information (CUI).  

Federal contract information encompasses information in government contracts but is not necessarily intended for public release. It differs from controlled unclassified information, which may be disseminated to the general public.  

Both FCI and CUI require higher protection. Besides jeopardizing national security, a breach in information may cause massive financial losses and reputational damage to the affected DIB business.  

However, CUI requires an extra layer of protection as it’s typically shareable with the general public.  

Examples of federal contract information include; 

• Maps of critical defense infrastructures, which may be in the custody of janitorial companies or IT firms 
• Diagrams of military training bases, which tactical equipment suppliers may possess 
• Personal details of federal employees, including their names and contact information 
• Invoices generated from federal contracts 
• Contract performance reports 

Meanwhile, controlled unclassified information constitutes the following: 

• Intellectual property materials, such as blueprints 
• Legal contracts and health records of federal employees 
• Findings from federal research programs 
• Sensitive financial information, such as purchase contracts 

To scope for FCI or CUI in your systems, proceed as follows: 

1. Gather all government contract documents. 
2. Review each contract for any of the above information. 
3. Identify the assets where your organization’s sensitive information is stored – manual contracts, USB drives, CDs, the cloud, etc. 
4. Classify the information into FCI or CUI and define all systems affected by either type of sensitive information. 

2. Understand Your CMMC Level

As previously mentioned, the recently unveiled CMMC framework saw a reduction of maturity levels from five to three. It’s important to understand what’s expected at each level, especially with regard to the type of sensitive information handled and whether it requires C3PAO-led certifications. 

Level 1 (Foundational)

CMMC Level 1 aligns with 17 basic cybersecurity controls under the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 and targets DIB entities that handle federal contract information.  

Under this maturity level, organizations can self-assess and report on their cybersecurity compliance status annually.  

Level 2 (Expert)

C3PAO-led assessments are mandatory for defense vendors seeking CMMC Level 2 certifications. The Expert maturity level seeks to safeguard both FCI and CUI. Contractors must meet all 110 controls under NIST SP 800-171, although there’s a provision of conditional compliance for companies that score at least 88%.  

Most organizations seeking CMMC compliance fail Level 2 assessments. Therefore, extensive preparation is necessary. While you can maintain operational continuity by scoring 88% during assessments, aiming for the best score possible is recommended.  

Level 3 

CMMC Level 3 is designed for prime defense contractors. Assessments are typically conducted by federal assessors appointed directly by the DoD, although C3PAOs also play a critical role.

3. Conduct a Mock Assessment

Mock assessments are a crucial step in the CMMC assessment and certification process. They let you uncover the types of sensitive information in your systems while using the opportunity to simulate actual C3PAO audits.  

To conduct a mock CMMC assessment, proceed as follows; 

1. Define the audit scope. 

 Common areas to audit include data privacy, network security, and application security. 

2. Identify weaknesses in your cybersecurity practices. 

The best way to uncover gaps and vulnerabilities is to compare your existing cybersecurity policy templates with the CMMC framework. 

3. Gather the necessary policy documents, including those highlighting CMMC controls and procedures. 

4. Mitigate the risks uncovered. 

This is a critical step in passing CMMC C3PAO assessments. Enlist professional cybersecurity experts if necessary. 

5. Update your current cybersecurity templates accordingly. 

NOTE: While you can conduct mock assessments internally using your in-house IT team, engaging an independent auditor provides an unbiased perspective on your CMMC readiness.  

4. Review Your SSP

Every cybersecurity audit, whether independently performed or C3PAO-led, should culminate in an elaborate update of a company’s System Security Plan (SSP).  

A system security plan is the document that a C3PAO will use to evaluate your organization’s cybersecurity posture and CMMC compliance readiness. It contains an overview of the security controls you’ve implemented or are planning to implement to achieve full compliance.  

An SSP should highlight the following issues; 

• Cybersecurity frameworks that your business aligns with, including but not limited to CMMC 
• Scope of the last cybersecurity audit, including audited assets 
• System components where sensitive information is stored in your organization 
• Network configurations and their role in fostering a robust cyber hygiene 
• Roles and responsibilities, which define the teams in charge of the document’s implementation 
• Channels of data flow and how various departments intercommunication  
• Your company’s cybersecurity end goals and the steps towards meeting those objectives 
• References to relevant industry policies and procedures, including contingency procedures and policies on incident response 

If your previous C3PAO audit culminated in a conditional certification, it’s important to consult your POA&M while updating your system security plan.  

POA&M (Plan of Action and Milestones) is a provision in the new CMMC framework, which grants temporary certification for DIBs that score at least 88% during C3PAO-led assessments. The document outlines the gaps uncovered during the previous audit, steps a DIB is taking to remediate those risks, and the timelines required to achieve full compliance (180 days from the assessment date). 

5. Set a Budget

The final step in the preliminaries involves resource allocation. The cost of CMMC assessments varies considerably depending on the CMMC Level.  

Level 1 self-assessments can be free if internally conducted. If you engage an independent assessor, there will be a price to pay, even if that’s not necessarily a C3PAO.  

Level 2 assessments, which C3PAOs must undertake, cost anywhere from $30,000 to $80,000. Finally, Level 3 assessments may hit and even surpass $100,000.  

Numerous factors determine actual C3PAO assessment costs, such as your organization’s size, the complexity of your IT systems, and the nature of assets to scope. Other considerations include the endpoints, the number of subcontractors you partner with, and whether it’s a first or subsequent C3PAO audit.  

Fortunately, you can manage CMMC C3PAO assessment costs by following the steps mentioned above. Scope your system for FCI or CUI, uncover any gaps, remediate the threats, and update your cybersecurity policy templates ahead of the official C3PAO audit.  

Note that you may also need to make provisions for unforeseen disruptions during C3PAO audits. Ensure you allocate a budget for such contingencies. 

Kick-Starting Your CMMC Assessment in Earnest

CMMC third-party assessor organizations are instrumental in accelerating regulatory compliance for defense vendors seeking CMMC Level 2 certification. However, C3PAO-led cybersecurity audits can be time- and resource-intensive.  

The best way to expedite these assessments is to prepare adequately by undertaking all the preliminaries. Remember to insist on a C3PAO accredited by the Cyber AB. Look out for agencies that have actually been authorized to conduct CMMC assessments rather than those merely listed on the Cyber AB marketplace.  

Posing pertinent questions to a C3PAO might also clue you in on their experience and expertise. How long have they been practicing? What’s their turnaround? What are their assessment fees?  

Ultimately, choose a C3PAO that aligns with your budget and niche.