Is your company or organization part of the Defense Industrial Base (DIB) or planning to join the Department of Defense (DoD)’s supply chain? If yes, you’ll need to attain full CMMC (Cybersecurity Maturity Model Certification) compliance as a precondition for securing lucrative defense contracts.
Previously, the emphasis on CMMC certification was placed on principal defense vendors. However, after publishing the newly revamped CMMC cybersecurity framework, all DIB companies (including small businesses and subcontractors) will be obligated to satisfy all control measures under the relevant CMMC certification levels.
The first step in obtaining CMMC certification is getting your organization evaluated by professionally authorized cybersecurity auditors known as C3PAOs (CMMC third-party assessor organizations).
According to estimates, just over 50 C3PAOs had been authorized to conduct CMMC assessments as of November 2024. That was significantly low compared to the 80,000+ DIB companies present at the time.
As an Organization Seeking Certification (OSC), it’s imperative to act swiftly and get your cybersecurity architecture audited to remain competitive. More importantly, you should understand the key features to look for in a C3PAO auditor.
We’ve taken the liberty of putting together the 10 critical factors when scouting for a C3PAO agency.
Identifying your CMMC level is the first (and most important) step before engaging a CMMC third-party assessor organization, as it enables you to establish whether you need a C3PAO in the first place.
The new CMMC framework has three maturity levels, down from five in the previous iteration. They include Levels 1, 2, and 3.
Level 1 certifications don’t require third-party assessors. Instead, OSCs can self-affirm and report their compliance status to the DoD annually.
However, the subsequent levels have no such privilege.
Companies seeking Level 2 or Level 3 CMMC compliance must enlist third-party assistance. C3PAOs are specifically required for Level 2 certifications, while Level 3 compliance audits are conducted by assessors appointed directly by the government.
CMMC Level 2 comprises 110 security controls aligned with the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171.
To determine whether you need a C3PAO, scope your company’s cybersecurity architecture to uncover any CMMC assets. Then, establish whether those assets handle Controlled Unclassified Information (CUI) – the primary target for Level 2 certifications.
CMMC AB, short for the CMMC Accreditation Body, is the official agency tasked with accrediting C3PAOs. It’s alternatively known as Cyber AB.
The Cyber AB maintains an online marketplace highlighting approved C3PAOs. Scour the website and ensure you select a C3PAO that has been fully authorized, not one whose application is still under review.
The CMMC AB imposes strict standards that C3PAOs must satisfy to achieve full authorization. Those include having ISO 9001 and ISO 27001 certifications and proof of in-depth understanding of CMMC maturity Levels 2 and 3.
Besides, aspiring candidates must meet several administrative requirements, such as proof of insurance and implementation of a robust dispute resolution mechanism. Therefore, hiring a Cyber AB-authorized C3PAO provides peace of mind, knowing you’re engaging an industry-trained professional.
The technicality of CMMC Level 2 audits requires the joint effort of multiple assessors. As such, prioritize C3PAO agencies that maintain a larger workforce.
A staff of at least three certified assessors is the minimum requirement for any C3PAO to undertake robust audits. Ensure the workforce includes at least one lead assessor, an assistant auditor, and a quality assurance (QA) professional.
Obviously, this excludes auxiliary staffers like customer support.
The lead assessor oversees the audit process while their assistant does much of the legwork. Meanwhile, a QA is critical in validating the efficiency of a CMMC compliance assessment by ensuring every procedure is followed to the letter.
Picking a C3PAO listed on the CMMC AB marketplace isn’t enough. The agency must provide evidence of technical experience for its staffers, especially the three personnel mentioned above.
Professional C3PAO assessors should possess several types of DoD clearance, including the Homeland Security (DHS) Suitability clearance.
It’s even better if your preferred C3PAO possesses additional credentials, such as the Certified Information Systems Security Professional (CISSP) and the Microsoft Certified Professionals.
This proves the agency prioritizes ongoing training and is in tune with the latest CMMC news and trends.
CMMC doesn’t operate in isolation; neither is it the only federal cybersecurity framework available. Several other programs include the Federal Risk and Authorization Management Program (FedRAMP®) and the State Risk and Authorization Management Program (StateRAMP).
Look out for a C3PAO with expertise in all major cybersecurity frameworks. This enables the agency to leverage its diverse expertise in guiding you through all the 110 controls required for unconditional CMMC Level 2 certification while ensuring your business complies with related cybersecurity programs.
You can assess an agency’s multi-framework expertise by asking them to explain the interplay between CMMC and, say, FedRAMP.
Pay keen attention to how they define the functions of C3PAOs and 3PAOs (third-party assessment organizations), bearing in mind that your cybersecurity audits may often require both professionals.
The acute shortage of cyber-authorized C3PAOs may have you settle for a recently accredited assessor. However, it’s best to pick someone with extensive industry experience.
While there’s no standard rule on the duration of existence, consider a CMMC C3PAO with at least 5 years in active practice. A more extended industry presence reflects positively on a C3PAO’s stability and reputation.
That said, the request for references validates the agency’s claims.
If they’ve been in business long enough, they must have undertaken CMMC audits for several organizations. Contact these companies and inquire further about their experience working with the C3PAO.
Besides contacting the referrals provided by a C3PAO, check online reviews posted by the organization’s previous clients.
Online testimonials can provide a more objective analysis of a C3PAO’s experience and professionalism. Ensure the feedback is posted on legitimate review platforms like Google Reviews and Trustpilot.
It’s also prudent to check online reviews with an open mind.
Rather than focus solely on the star ratings, carefully read user comments to uncover the specific reasons a CMMC C3PAO received a thumbs-up or thumbs-down.
Does your company use any compliance automation software?
If yes, you’ll require a C3PAO familiar with the tool.
While professional C3PAOs are tech-savvy individuals with extensive knowledge of common cybersecurity automation software, having background knowledge of your stack is critical. It allows the agency to align its audits with existing applications, accelerating the assessment process.
In the same vein, consider a C3PAO with industry-specific experience. The organization must be privy to the common cybersecurity challenges faced by DIBs in your industry to adapt their CMMC audits accordingly.
While experts recommend working with a C3PAO familiar with your stack and industry, the organization must equally possess cross-industry experience.
That’s because the defense supply chain is a network of interconnected businesses.
Assume you’ve been contracted to develop software for the DoD’s aerospace program.
In that case, you’ll require a C3PAO with technical experience auditing software development and aerospace engineering DIBs.
CMMC Level 2 assessment is a rigorous undertaking whose success requires a robust methodology. Therefore, choose a C3PAO who’s happy to provide a detailed breakdown of the audit process.
Ideally, the agency would begin by scoping your organization’s cybersecurity ecosystem for gaps and vulnerabilities. They’ll then help you prepare or update your existing System Security Plan (SSP), given the preliminary findings.
The next step is a thorough cybersecurity audit, which entails scoping all CUI assets in your organization. These could be hardware components like hard disks, software systems like cloud storage, and the human personnel tasked with managing such assets.
Thereafter, a C3PAO will score you based on whether you’ve “Met” or “Not Met” the requirements for Level 2 certification.
Note that you must satisfy at least 88 of the 110 controls to receive at least a partial compliance certificate. If you receive conditional certification, the auditor will prepare a Plan of Action and Milestones (POA&M) detailing the measures your company intends to take to mitigate uncovered risks. There’s a 180-day window to remediate all weaknesses.
Ensure a C3PAO can articulate these critical steps before engaging them.
The cost of CMMC Level 2 assessments typically ranges from $100,000 – $150,000.
Obviously, you want a C3PAO that charges competitive fees without skimping on efficiency. Beware of C3PAOs whose rates are suspiciously lower than the market value.
Fortunately, you can implement certain measures to manage your CMMC assessment costs. Those include performing in-house preliminary cybersecurity audits to uncover risks before engaging a C3PAO for more in-depth evaluations.
Once you’ve agreed on the budget, a C3PAO should get to work immediately and dispense with the audit process as soon as possible. A faster turnaround helps you beat crucial compliance deadlines, avoiding associated penalties.
Getting your organization audited for CMMC compliance isn’t just about checking the boxes. Besides helping achieve mandatory certification, CMMC assessments may provide key insights into your company’s cybersecurity posture.
By addressing the gaps and vulnerabilities uncovered during the audit process, you can secure your supply chain, minimize reputational damage to your company, and maintain operational resilience in the fast-evolving DIB landscape.
However, you can only unlock these benefits by working with an experienced CMMC assessor. Feel free to bookmark this blog for reference whenever you’re looking for a professional C3PAO to audit your firm for CMMC level 2 compliance.
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