CMMC’s new program requires periodic cybersecurity evaluations under each of the framework’s three maturity levels. If you’re a Level 2 defense contractor, you’ll need to schedule the mandatory audits triennially.
More importantly, all Level 2 assessments must be conducted by agencies called CMMC third-party assessor organizations (C3PAOs).
This post explores the key services offered by C3PAOs to ensure seamless CMMC Level 2 compliance.
What Is CMMC?
The easiest way to understand the role of a CMMC C3PAO is to familiarize yourself with CMMC first.
The CMMC is a cybersecurity framework created by the United States Department of Defense (DoD) to protect the defense supply chain from cyberattacks.
According to the DoD, CMMC compliance is mandatory for all Defense Industrial Base (DIB) organizations that handle Federal Contract Information (FCI) and/or Controlled Unclassified Information (CUI). Affected entities include prime contractors, subcontractors, and even managed service security providers (MSSPs).
CMMC exists in three maturity levels.
Level 1 applies to defense contractors that only manage FCI, while level 2 targets businesses that handle CUI.
Level 3 is the most sophisticated. It’s designed to protect high-sensitive CUI from aggressive cyber-attacks.
The CMMC framework borrows heavily from the National Institute of Standards and Technology (NIST). Specifically, CMMC Level 2 aligns with 110 controls in NIST 800-171.
Who Are C3PAOs?
CMMC third-party assessor organizations are agencies that conduct Level 2 assessments on the DoD’s behalf.
C3PAOs are totally independent. They answer directly to the Cyber Accreditation Body (Cyber AB), CMMC’s official accreditation organization.
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How Do C3PAOs Ensure Smooth CMMC Level 2 Compliance?
The role of third-party assessor organizations in CMMC compliance mostly relates to assessments. Here’s how these organizations typically undertake Level 2 audits.
1. Preliminary Preparations
Before embarking on CMMC Level 2 assessments, a C3PAO would start by defining the scope of the audit. This entails marking out the specific assets in your organization that handle Controlled Unclassified Information.
C3PAOs are professionally trained to undertake robust cybersecurity scoping.
However, you can expedite the assessment process by pointing them to the distinct assets in your business that interact with CUI. Those include manual contract forms, hard drives, and cloud storage systems.
2. Reviewing Your Cybersecurity Documents
After scoping your system for CUI, a C3PAO will review your organization’s cybersecurity policy documents. One such document is the System Security Plan (SSP).
SSPs outline the security measures your business has implemented to avert and mitigate risks. Since the focus is Level 2 CMMC assessments, those protocols must align with the 110 controls in NIST 800-171.
Other critical documents include asset inventories, incident response policies, and information flow charts. A good practice is to get these documents ready well ahead of C3PAO assessments.
If you’ve conducted multiple self-audits between the mandatory triennial assessments (highly encouraged), ensure you review the existing policy documents accordingly. This allows the C3PAO to narrow their focus to the most recent updates on your organization’s cybersecurity posture.
3. Conducting Objective Interviews
Interviews are a critical part of C3PAO-led audits.
By interviewing your personnel, assessors can better understand your organization’s information structure. It also helps ensure consistency in your compliance claims.
The interviews typically target your in-house cybersecurity team, although other departments may be involved too.
Interviews may also uncover whether your in-house cyber personnel understand the nuances of the CMMC framework. While a C3PAO won’t use this information against you, they can rely on it to gauge your organization’s general attitude towards CMMC compliance.
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4. Validating Compliance
This is perhaps the most critical step in C3PAO assessments.
After gathering extensive evidence, a C3PAO determines if your current cybersecurity protocols align with Level 2 controls.
Note that C3PAOs don’t offer advisory opinions on CMMC compliance. So, don’t go asking if you can implement any changes to meet the minimum compliance threshold.
A C3PAO won’t casually point out your security deficiencies either. Instead, they capture any weaknesses in the final report.
5. Report Compilation
Most C3PAO assessments are spearheaded by a lead assessor. At the end of each audit, the lead assessor reviews the findings and then compiles a detailed report on your compliance status.
Each assessment results in a “Met” or “Not Met” verdict, the latter implying that compliance gaps were found. If the audit uncovered weaknesses, a C3PAO will help you create a Plan of Action & Milestones (POA&Ms).
POA&Ms highlight all the vulnerabilities detected and the remediation measures. The document also spells out the personnel tasked with the threat remediation, as well as the timelines for sealing the security gaps.
You have up to 180 days to address any deficiencies.
If you met all the requirements, the assessment process ends with your C3PAO uploading the findings to the CMMC Enterprise Mission Assurance Support Service (eMASS) system.
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Final Word
Third-party assessor organizations play an instrumental part in facilitating CMMC compliance across the defense industrial base. While Level 1 DoD vendors can self-audit, the Department of Defense mandates C3PAO-led assessments for Level 2 businesses.
C3PAOs can help scope your information storage assets for security vulnerabilities, enabling you to implement controls that adhere to the CMMC framework. You can also leverage their regulatory audits to understand your organization’s cybersecurity posture better.
However, remember that C3PAOs strictly work on the DoD’s behalf. That means their assessments are objective, unbiased, and verifiable.
To pass all C3PAO evaluations, you should prioritize conducting internal audits regularly.
From these routine assessments, you can detect weaknesses in your company’s cybersecurity posture and seal them before scheduling mandatory assessments. They’re your best bet in terms of defending your CMMC certifications.