C3PAOs and Their Role in CMMC

C3PAOs and Their Vital Role in CMMC Compliance

By Heather Bennett

October 2, 2023

Cybersecurity Maturity Model Certification (CMMC) has ushered in a new era of cybersecurity standards for U.S. Department of Defense (DoD) supply chain organizations. As companies strive to meet CMMC requirements, they must navigate a complex landscape, and one critical aspect is working with Certified Third-Party Assessment Organizations (C3PAOs). In this blog post, we will demystify the role of C3PAOs in CMMC compliance and explore their significance in the certification process.

Who Are C3PAOs?

C3PAOs, or Certified Third-Party Assessment Organizations, are independent entities authorized by the CMMC Accreditation Body (CMMC-AB) to conduct assessments of organizations seeking CMMC certification. These organizations play a pivotal role in the CMMC ecosystem, serving as assessors that evaluate an organization’s adherence to the CMMC framework.

The Role of C3PAOs in CMMC Compliance

1. Objective Assessment: C3PAOs objectively assess an organization’s cybersecurity practices. They evaluate whether an organization’s policies, procedures, and controls align with the CMMC requirements.

2. Impartial Evaluation: C3PAOs are neutral third parties, which means they are not vested in whether an organization passes or fails the assessment. This impartiality ensures the integrity of the certification process.

3. Certification Determination: After conducting an assessment, the C3PAO provides a report that details the organization’s compliance with CMMC requirements. Based on this report, the CMMC-AB makes the final determination regarding certification.

4. Compliance Guidance: C3PAOs can offer guidance and recommendations to organizations seeking certification. They can identify areas where improvements are needed and provide insights into achieving compliance.

5. Assessment Expertise: C3PAOs employ cybersecurity professionals with expertise in the CMMC framework and related cybersecurity practices. Their assessors have undergone rigorous training to conduct assessments effectively.

The C3PAO Assessment Process

The assessment process conducted by C3PAOs typically involves the following steps:

– Pre-Assessment Preparation: Organizations seeking certification work to prepare their cybersecurity practices and documentation.

– Assessment: C3PAOs conduct on-site or remote assessments to evaluate the organization’s cybersecurity controls and practices.

– Report Submission: After the assessment, the C3PAO submits a report detailing the organization’s compliance status to the CMMC-AB.

– Certification Decision: The CMMC-AB reviews the report and makes a certification determination.

– Ongoing Compliance: CMMC certification is not a one-time event. Organizations must maintain compliance continuously, and periodic assessments are part of the process.

Why C3PAOs Matter

C3PAOs are integral to the CMMC certification process for several reasons:

1. Expertise and Objectivity: Their expertise and impartiality ensure a fair and accurate assessment of an organization’s cybersecurity practices.

2. Certification Credibility: C3PAO involvement enhances the credibility of CMMC certification, as qualified, independent entities conduct assessments.

3. Guidance and Improvement: C3PAOs can provide valuable guidance to organizations, helping them improve their cybersecurity posture.

4. Consistency: C3PAOs follow standardized assessment processes, ensuring consistency in evaluating organizations.

C3PAOs are key players in the CMMC certification journey. Their role in assessing and verifying an organization's cybersecurity practices is vital for achieving compliance with the CMMC framework. By working with C3PAOs, organizations can navigate the complex landscape of CMMC more effectively and contribute to the overall enhancement of cybersecurity in the defense supply chain.

As organizations strive for CMMC compliance, partnering with a trusted C3PAO becomes a strategic move toward achieving and maintaining certification, bolstering cybersecurity practices, and securing valuable DoD contracts.

Provincia Government Solutions, LLC is a Nashville based security and risk assurance firm with advanced expertise in government regulatory and compliance cybersecurity requirements including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E and ZTA (Zero Trust Architecture) solutions. Our client base includes  government agencies, contractors, and commercial organizations affiliated with government entities. Whether you are seeking audit preparedness, compliance and assurance assessments,  security consulting, or CMMC certification, we have the expertise to help.  Contact us at (615) 807-2822 or at info@provincia.io to discuss your security needs today. Consultations are free of charge and we look forward to speaking with you!

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CMMC 2.0 Submission in OIRA is Moving Forward

CMMC 2.0 Submission to OIRA is Moving Forward

By Heather Bennett

September 23, 2023

The CMMC 2.0 submission to OIRA is moving forward, according to the OMB website. The site lists three meetings taking place on September 6th, September 8th, and September 13th. These meetings are labeled as the “Proposed Rule Stage”. This is creating a stir among the CMMC evangelicals. This is the first major step after the official submission.

 

On July 24, 2023, the DoD officially submitted CMMC 2.0 to the Office of Information and Regulatory Affairs (OIRA) for review. This is a major step that many in the cybersecurity sphere have been waiting for. Why is it such a big deal? What does this mean?

What is Everyone Talking about?

Let’s start with the significance of this news. CMMC has been a buzzword in the DIB and cybersecurity community for over three years at the time of writing. Three years of debate, revision, speculation, and preparation are one step closer to reality. “Under EO 12866, OIRA has up to 90 days (which can be extended) to review a rule. This review helps to promote adequate interagency review of draft proposed and final regulatory actions so that such actions are coordinated with other agencies to avoid inconsistent, incompatible, or duplicative policies.” (https://obamawhitehouse.archives.gov/omb/oira/) After 90 days, if there are no revisions, the next step is publishing the proposed rule in the Federal Register. Once the rule is registered, there will be a 60-day comment period. This puts us into 2024 before the rule goes into effect. This means that CMMC requirements could appear in contracts by early 2025.

The Importance of OMB Submission in CMMC Compliance

So, why is the submission of CMMC requirements to OMB so critical? Here are several key reasons:

 

  1. Alignment with Government Policies: OMB review ensures that CMMC requirements align with government policies and standards, ensuring a unified approach to cybersecurity across government contracts.

 

  1. Legitimacy and Standardization: OMB approval adds legitimacy and standardization to the CMMC framework. It signifies that the cybersecurity practices mandated by CMMC are recognized and endorsed at the highest levels of government.

 

  1. Contract Eligibility: Without OMB approval, organizations may not be eligible to bid for or engage in DoD contracts. Compliance with CMMC, including the OMB submission, is often a prerequisite for participation.

 

  1. National Security: Given the sensitive nature of information involved in defense contracts, OMB ensures that the cybersecurity measures mandated by CMMC are robust, protecting national security interests.

 

  1. Consistency and Accountability: OMB oversight ensures that CMMC compliance remains consistent and that organizations are held accountable for adhering to cybersecurity best practices.

Waiting in CMMC the Wings

What does this mean for DIB contractors and C3PAOs that have been preparing for the official rule? It’s game time. There is no denying that this requirement is going to go into effect. Any DIB contractor that has been dragging their feet regarding compliance will have to step up their game. Many CMMC evangelists have been warning the community for the past three years that it’s time to get ready or get left behind.

 

PGS has spent the last three years learning, securing its certification, and preparing clients for the inevitable. We have developed strong CMMC service offerings, from CMMC workshops to full certification assessments. To learn more about how you can be ready for CMMC, we invite you to attend a webinar we will host on October 17, 2023. This interactive session will focus on document preparation specific to CMMC. This webinar is free and open to anyone interested in preparing for CMMC. You can sign up below.

Register for this Webinar Below

Don't miss this opportunity to master CMMC documentation and bolster your organization's cybersecurity efforts. Register now to secure your spot!

Provincia Government Solutions, LLC is a Nashville based HUBZone certified security and risk assurance firm with advanced expertise in government regulatory and compliance cybersecurity requirements including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E and ZTA (Zero Trust Architecture) solutions. Our client base includes  government agencies, contractors, and commercial organizations affiliated with government entities. Whether you are seeking audit preparedness, compliance and assurance assessments,  security consulting, or CMMC certification, we have the expertise to help.  Contact us at (615) 807-2822 or at info@provincia.io to discuss your security needs today. Consultations are free of charge and we look forward to speaking with you!

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Discover the Top 10 CMMC FAQs

Top 10 CMMC FAQs

By Heather Bennett

September 18, 2023

Top 10 FAQs for CMMC (Cybersecurity Maturity Model Certification)

The Cybersecurity Maturity Model Certification (CMMC) continues to be a hot topic in the world of cybersecurity compliance. As organizations strive to meet the requirements set by the Department of Defense (DoD) and protect sensitive information, it’s no wonder that CMMC generates numerous questions. In this blog post, we’ve compiled the top 10 frequently asked questions (FAQs) about CMMC to provide clarity and insight into this vital certification process.

1. What Is CMMC, and Why Is It Necessary?

CMMC, or Cybersecurity Maturity Model Certification, is a framework developed by the U.S. Department of Defense (DoD) to ensure that organizations in the defense supply chain maintain robust cybersecurity practices. It’s necessary to protect sensitive DoD information and enhance national security.

2. Who Must Comply with CMMC?

CMMC compliance is mandatory for any organization or contractor that handles controlled unclassified information (CUI) or wishes to engage in contracts with the DoD. This includes both prime contractors and subcontractors at various tiers.

3. How Many CMMC Levels Are There, and What Are They?

CMMC consists of three levels, each representing a different tier of cybersecurity maturity. These levels are Level 1 (Foundational), Level 2 (Advanced), and Level 3 (Expert), with each level building upon the requirements of the previous one.

4. How Can My Organization Get CMMC Certified?

To achieve CMMC certification, organizations must undergo assessments conducted by accredited third-party assessment organizations (C3PAOs). These assessments evaluate your organization’s adherence to the CMMC framework’s requirements, and successful completion results in certification at the appropriate level. See our blog on C3PAO Red flags (https://provincia.io/5-c3pao-red-flags/)

5. What Types of Documentation Are Required for CMMC Compliance?

CMMC compliance requires thorough documentation. Key documents include the System Security Plan (SSP), Plan of Action and Milestones (POA&M), policies and procedures, incident response plans, and security assessment reports. The specific documentation you need depends on your CMMC level.

CMMC Webinar

Register for our upcoming webinar on CMMC Documentation.

6. Can I use Existing Cybersecurity Frameworks for CMMC Compliance?

Yes, you can leverage existing cybersecurity frameworks like NIST SP 800-171 or ISO 27001 to help meet CMMC requirements. However, you’ll need to ensure that your practices align with the specific controls outlined in the CMMC framework.

7. What Are the Penalties for Non-Compliance with CMMC?

Non-compliance with CMMC can lead to consequences such as the loss of DoD contracts, reputational damage, and potential legal actions. It’s crucial to take compliance seriously to protect your organization.

8. Is CMMC Compliance a One-Time Effort?

No, CMMC compliance is an ongoing process. Regular assessments and updates are necessary to maintain compliance as threats evolve and your organization’s cybersecurity practices adapt.

9. How Long Does It Typically Take to Achieve CMMC Certification?

The timeline for CMMC certification varies depending on your organization’s current cybersecurity posture and the level you aim to achieve. It’s essential to allocate sufficient time for preparation and assessment.

10. Where Can I Find More Resources and Guidance on CMMC?

To access official CMMC resources, guidance, and updates, visit the official CMMC website. Additionally, consider consulting with CMMC experts and certified assessors to navigate the certification process effectively. (https://dodcio.defense.gov/CMMC/  https://cyberab.org)

 

In conclusion, CMMC is a pivotal certification for organizations in the defense supply chain. These FAQs provide valuable insights into its purpose, requirements, and implications. As CMMC evolves, staying informed and seeking expert guidance will be crucial for achieving and maintaining compliance.

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5 Tips To Prepare for CMMC Assessments

5 Tips to Prepare for CMMC Assessments

By Heather Bennett

February 7, 2023

Many OSCs (Organizations Seeking Certification) and C3PAOs eagerly await the final ruling on CMMC. In their CMMC Certification Overview, the CyberAB has stated that “organizations can and should be implementing the CMMC standard.” (https://cyberab.org/CMMC-Ecosystem/Ecosystem-roles/DIB-Companies-OSCs) Many OSCs are signing or have already signed agreements with C3PAOS for their assessment in anticipation of the final ruling. As a certified C3PAO, we want to share some insight and advice on getting ready for your CMMC Assessment while there is still time to prepare.

Here are five tips to prepare for a CMMC assessment. Considering these tips will help make the assessment process smoother and more likely to succeed.

TIP #1. Documentation Review

Outdated or misaligned documents can lead to confusion and even failure. Your processes and procedures should be living documents that show ongoing development and change. This is especially true for your SSP (System Security Plan). Your SSP should be solidly built upon your supporting documents. All wording in your SSP should match your process and procedure documents. This shows continuity and maturity in your environment, which is paramount to CMMC.

The CAP (CMMC Assessment Process) Version 1.0, section 1.5.6 supplies a list of items that the C3PAO will require:

  • Results of most recent OSC self-Assessment or any pre-Assessment conducted by an RP or Registered Practitioner Organization (RPO)
  • A preliminary list of the anticipated evidence
  • The System Security Plan and other relevant documentation; and
  • A list of all OSC personnel who play a role in the procedures in scope.

The Assessment Team then collaborates and coordinates with the OSC to correlate all of the above information to each CMMC practice. The purpose of this procedure is to do a preliminary “triage” of all of the available evidentiary materials and “map” or “cross-walk” each item to their respective CMMC practices to establish the mutual understanding that the OSC has, at a minimum, addressed each of the CMMC practices with some evidentiary basis. This inventory does not establish that any or all CMMC practices have been implemented adequately or sufficiently in accordance with the CMMC standard, but rather that no “gaps” exist with regard to a particular CMMC practice. This ensures that the practice was neither neglected, ignored, or dismissed.

Having these key documents polished and ready is vital to obtaining a CMMC certification.

TIP #2. Prepare Evidence and Logs

As you begin the CMMC assessment process, you will be required to provide evidence that you meet the requirements for each control. This means all supporting artifacts must be ready. You will need to have all evidence items in versions that can be shared safely and securely. As mentioned above, these documents and logs should show a history and level of maturity that is expected for their corresponding control.

Section 1.5.7 of the CAP version 1.0 clearly defines the evidence requirements. “Adequate and sufficient Evidence will be required to determine if the OSC is ready for the assessment.”

Adequate Evidence is the correct artifact, response, demonstration, or test that proves that the organization is implementing the CMMC practice. You should ask the question: Is this the appropriate evidence for this practice?

Sufficient evidence is the correct amount of evidence to verify that the CMMC practice is implemented correctly. This prompts the question: Are we providing enough proper evidence?

Applying these two questions to each piece of evidence will reduce the time wasted providing additional or correct evidence after the assessment has begun.

TIP #3. Resolve Existing POAMs

Currently, CMMC 2.0 rules do not allow pre-existing POAMs (which is different from NIST 800-171 High conducted as part of the DIBCAC Joint Surveillance Assessments). If pre-existing POAMS are discovered, it will result in an automatic failure. Any pre-existing POAMs must be resolved before your CMMC assessment begins. For more detailed information on POAMs and CMMC, check out our blog at https://provincia.io/poams-and-their-significance-in-cmmc/

The CAP version 1.0 section 2.3.2.1 lists criteria for items that are ineligible for a POAM:

  • Practices that could lead to significant exploitation of the network or exfiltration of CUI, aslisted in Appendix K, paragraphs (e) and (f);
  • Any practice(s) listed on the OSC’s Self-Assessment Practice Deficiency Tracker (validatedin paragraph 1.4.2);
  • Practices that were not implemented by the OSC prior to the current CMMC Assessment;
  • Any practice that changes and/or limits the effectiveness of another practice that has beenscored as “MET”

If any of these scenarios is found, it will render any applicable CMMC practice ineligible. The OSC will not qualify for the “Limited Practice Deficiency Correction Program”.

TIP #4. Prepare for Interviews

Preparing for interviews may seem daunting, especially for personnel who have never been through an assessment. Prepare in advance so that your assessment is kept on schedule.

To help you do this, here are four things you can practice before your formal interviews.

With a bit of planning, communication and practice, preparing for interviews can significantly influence the outcome of the CMMC Assessment.

TIP #5. Pre-Assessment by Certified C3PAO

 

It is highly recommended that all OSCs undergo a preassessment before their CMMC assessment. This process can identify and remediate areas of potential failure while you have time to make corrections. A preassessment can also save time, money, and frustration.  During the preassessment, your assessor should focus on critical areas that will prepare you for a successful CMMC certification assessment.

Some of these areas include:

  • Document Review
  • POAM Resolution
  • Evidence verification
  • Evidence preparation
  • Environment Analysis

Summary

Preparing for a CMMC assessment can feel like a monumental task. With the help of the right professionals, navigating your assessment can be smooth sailing. Contact us today to discuss how Provincia Government Solutions can help you successfully achieve CMMC Certification.

 

Here at Provincia Government Solutions, we believe knowledge is power. We make sure to stay informed regarding all things CMMC and pass this expertise on to you.  We are here to help you earn your CMMC 2.0 certification. Your success is our success.

Upcoming Blog

We will continue our CMMC theme with “Am I ready for CMMC”. We will discuss the most important things to consider before diving in to a CMMC assessment.

Be sure to subscribe to our blog and check out our podcast for more in depth discussion of all things cybersecurity.

Are you ready for Provincia Government Solutions to help you? If so, reach out to our team and let’s talk. We can put you are on the path to success!

Until then, be safe and stay secure!

About Us

Provincia Government Solutions, LLC is a Nashville based HUBZone certified security and risk assurance firm with advanced expertise in government regulatory and compliance cybersecurity requirements including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E and ZTA (Zero Trust Architecture) solutions. Our client base includes  government agencies, contractors, and commercial organizations affiliated with government entities. Whether you are seeking audit preparedness, compliance and assurance assessments,  security consulting, or CMMC certification, we have the expertise to help.  Contact us at (615) 807-2822 or at info@provincia.io to discuss your security needs today. Consultations are free of charge and we look forward to speaking with you!

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Provincia Government Solutions is a SBA certified Small  Business cybersecurity assurance firm and a CMMC Certified Third Party Assessment Organization (C3PAO).  We were the first organization to become a  C3PAO in the Middle Tennessee (Nashville) area and provide a full range of services including CMMC consulting and certification assessments. Our assessment team is trained in CMMC and other government assessment disciplines and we are experienced working with organizations of all sizes. Please reach out with any cybersecurity or CMMC related inquiries. We look forward to speaking with you!

 

POAMs and Their Significance in CMMC Assessments

POAMS and CMMC

By Sese Bennett

December 19, 2022

The use of POAMs are ubiquitous in the world of cybersecurity. As we get closer to the release of CMMC 2.0, many are wondering about POAMs and their significance in CMMC assessments. Providing a clear answer is difficult, but in this article, we will attempt to shed some light on the expected standards regarding POAMs and CMMC.

The National Institute of Standards and Technologies (NIST) defines a Plan of Action and Milestone (POAM) as “A document for a system that “identifies tasks needing to be accomplished. It details resources required to accomplish the elements of the plan, any milestones in meeting the tasks, and scheduled completion dates for the milestones.”

POAMs are used across many different groups in an organization including IT, risk management, governance, risk, and compliance. POAM also applies to the CMMC ecosystem, including Organization Seeking Certification (OSC). As OSCs prepare for a CMMC certification assessment, they must consider any existing POAMs that currently have, understand how CMMC 2.0 defines acceptable POAM criteria, and how POAMs impact certification efforts.

How Does CMMC Define POAM?

CMMC defines a POAM as a document to remediate deficiencies and the respective timeframe for doing so. “The POAMs purpose is to identify, assess, prioritize, and monitor the progress of corrective efforts for security weaknesses found in an organization’s programs and systems.” (CAP)

The legitimacy and validity of a prospective POAM will be decided by the Lead Assessor at the time of assessment closeout. The CAP provides a list of criteria that must be included in a credible and effective POA&M

Why are POAMs So important to CMMC?

POA&M’s can make or break an assessment. Understanding a few key requirements will help you navigate the use of POA&M’s during your CMMC assessment. CMMC 2.0 was revised to make accreditation obtainable in situations where certain POA&Ms may be necessary. However, it is important to keep in mind that not all practices will be eligible for a POA&M. According to the CMMC Assessment Plan (CAP) version 1.0 (https://cyberab.org/Portals/0/Documents/Process-Documents/CMMC-Assessment-Process-CAP-v1.0.pdf) the following points must be considered when discussing POA&M’s:

  • CMMC will allow conditional use of Plans of Action and Milestones (POA&M) to remediate practices that are not fully or successfully implemented.
  • POA&Ms will be strictly time-bound with a validity period of no more than 180 days from the Assessment Final Recommended Findings Briefing (Phase 3).
  • POA&Ms will not be allowed for the highest-weighted CMMC requirements (currently understood to be level 5 requirements
  • The Department of Defense has established a minimum-score requirement to support Certification.
  • The Certified CMMC Assessor will validate the following criteria for an OSC to satisfy the requirements for receiving a CMMC Level 2 Conditional Certification:
  • 80% of all CMMC Level L2 practices scored “MET” (Current CMMC L2 scoring would result in 88/110 Practices must be found as “MET”). In addition to that minimum score, “If any, practices on the POA&M Review fail to result in a score of ‘MET’, the Lead Assessor will recommend the OSC NOT be recommended for a CMMC Level 2 Final Certification”.
  • All POA&M items must meet the criteria in Appendix K, “CMMC Scoring with DoD Assessment Scoring Methodology” (Appendix K -TBD)
  • Pre-existing POAM’s are not allowed and can result in a CMMC 2.0 assessment failure.

Summary

Cybersecurity is an ever-evolving organism and POA&M’s can be expected as new procedures and tools are implemented. CMMC will allow POA&M’s on a conditional basis, however, POA&M’s will not be allowed for the highest-weighted CMMC requirements. Also, to qualify for the POA&M process, a minimum score must be met (88/110 or 80%) and all qualified POA&Ms require remediation within 180 days.

 

The CMMC 2.0 POAM process makes CMMC Certification far more attainable than the previous model. This allows OSCs to mitigate less severe issues within their CMMC environment and continue their CMMC certification journey.

 

Other aspects of POAMs are still being finalized. PGS will keep you up to date as these aspects are finalized, but it is safe to say that minor updates and enhancements should be expected until CMMC’s final rulemaking is complete.

 

Here at Provincia Government Solutions, we believe knowledge is power. We make sure to stay informed regarding all things CMMC and pass this expertise on to you.  We are here to help you earn your CMMC 2.0 certification. Your success is our success.

Upcoming Blog

We will continue our CMMC theme with “Am I ready for CMMC”. We will discuss the most important things to consider before diving in to a CMMC assessment.

Be sure to subscribe to our blog and check out our podcast for more in depth discussion of all things cybersecurity.

Next Steps

Are you ready for Provincia Government Solutions to help you? If so, reach out to our team and let’s talk. We can put you are on the path to success!

Until then, be safe and stay secure!

About Us

Provincia Government Solutions, LLC is a Nashville based HUBZone certified security and risk assurance firm with advanced expertise in government regulatory and compliance cybersecurity requirements including NIST, FISMA, CMMC, SCA, 800-171, TRICARE, MARS-E and ZTA (Zero Trust Architecture) solutions. Our client base includes  government agencies, contractors, and commercial organizations affiliated with government entities. Whether you are seeking audit preparedness, compliance and assurance assessments,  security consulting, or CMMC certification, we have the expertise to help.  Contact us at (615) 807-2822 or at info@provincia.io to discuss your security needs today. Consultations are free of charge and we look forward to speaking with you!

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Provincia Government Solutions is a SBA certified Small  Business cybersecurity assurance firm and a CMMC Certified Third Party Assessment Organization (C3PAO).  We were the first organization to become a  C3PAO in the Middle Tennessee (Nashville) area and provide a full range of services including CMMC consulting and certification assessments. Our assessment team is trained in CMMC and other government assessment disciplines and we are experienced working with organizations of all sizes. Please reach out with any cybersecurity or CMMC related inquiries. We look forward to speaking with you!