POAMs and Their Significance in CMMC Assessments

Provincia Government Solutions

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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  • P.O. Box 1685
    Spring Hill, TN 37064
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  • +1 (615) 807-2822 | info@provincia.io

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ABOUT US

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!

 

5 C3PAO Red Flags

Provincia Government Solutions

5 C3PAO Red Flags

By Sese Bennett

November 14, 2022

In this blog, we discuss 5 C3PAO Red Flags that you should look for when interviewing a prospective C3PAO to perform your CMMC assessment.

Choosing the right Certified Third-Party Assessment Organization (C3PAO) for your CMMC assessment will take effort and time. This will be time and effort well spent if you find the right match and avoid companies that don’t have your best interest in mind

The Good, The Bad, and The Ugly C3PAO?

As the cybersecurity world gears up for CMMC, I was reminded not too long ago by a client, not all companies are the same. This includes how they approach CMMC assessments and what “style” of C3PAO works best for them. While it is true that most companies will perform the assessment correctly, the way they assess can feel like everything from a walk in the park to a root canal. Yes, compatibility of the two companies can make a huge difference. Although a company may have stellar recommendations, their approach and personalities may clash with the established culture of your organization.

But what about the bad eggs? As with any project or initiative your organization takes on, diligence is required with selecting a compatible C3PAO. Differing of opinion on implementation and requirements is common and normally not a showstopper. However, poor business ethics and ineptness are signals of future problems that could be major issues if you are not careful.

So how do you identify these bad eggs before they impact the success of your assessment? Awareness is key. Identification of these 5 C3PAO red flags will help you avoid C3PAO’s (or any other organization for that matter) who’s actions put the success of your CMMC certification efforts at risk.

5 C3PAO RED FLAGS

The missing puzzle piece means they are not complete and not a C3PAO.

Red Flag #1 Almost Certified

In the world of CMMC C3PAO’s there is authorized and not authorized.  C3PAO’s that have not officially completed the Cyber-AB authorization process cannot solicit business as authorized C3PAO’s. “As good as authorized” or “Almost Authorized” only means one thing – Not Authorized! There are so many things that could happen to delay or even prevent them from becoming authorized. If you make a “gentleman’s agreement” based on the expectation they will someday be authorized, this could leave you high and dry and place you in the back of the assessment queue.

Hiring a C3PAO with no Action plan feels like being lost in a maze.

Red Flag #2 No Action Plan

If your interview with a potential C3PAO leaves you with more questions than answers, that C3PAO may not have an adequate plan to execute your assessment. Coming up with a plan on the spot is not reassuring and could delay your assessment. Experienced C3PAO’s should be confident on what needs to be done. Although we are still in the early stages of rolling out CMMC, most experienced C3PAO have already allocated resources and created plans for executing successful CMMC assessments. You should leave any C3PAO preliminary discussion feeling confident that they can handle the assessment and the right fit for your organization.

Some CMMC questions are more important than others.

Red Flag #3 Not Asking the Right Questions

An interview with a C3PAO should be filled with questions from both sides of the table. The C3PAO most certainly should be asking questions about the size and scope of the assessment. They should be asking about System Security Plan’s and the maturity of your documentation process. How can anyone give a fair proposal without knowing how much work is involved? If they are underbidding, they may become frustrated, and the quality and integrity of the assessment could suffer. If they are overbidding, you are eating the cost of their poor calculations. Neither of these possibilities is a win for your organization.

Having a C3PAO you can trust is key to a successful CMMC assessment.

Red Flag #4 Promises, Promises, Promises

C3PAO’s should always be realistic in what they can deliver. Statements that over promise and under deliver will cause friction and frustration during an assessment. Promises such as “We will have you done in 10 days”, or “we guarantee that you will be at the front of the early assessment queue” sound great but are empty because C3PAO’s can’t guarantee what they don’t control such as how long an assessment takes, or which order the Department of Defense selects applicant organizations to be assessed.

Capable C3PAO’s present realistic documented expectations up front so that everyone is aware of engagement deliverables, activities, and timelines. If you start to hear promises that sound too good to be true, ask your C3PAO to back it up with facts and document it in your contract. If they cannot (or will not), run for the door!

Having little or no experience equates to more mistakes with your CMMC assessment.

Red Flag #5 Little or No Cybersecurity Assessment Experience

When hiring a C3PAO, it can be hard to gauge experience since CMMC 2.0 is relatively new for C3PAO’s performing assessments. However, CMMC 2.0 is based in NIST 800-171, which easily translates to the CMMC practices. This knowledge can come in handy when assessing the experience level of a potential C3PAO partner.

Basic questions you can ask to gauge the level of experience include:

  • What type of assessments have they done in the past?
  • Do these assessments include NIST based assessments such as 800-171, 800-53, FISMA, or similar?
  • What size organization have they work with in the past?
  • How many years have they been in the cybersecurity assessment field?

 The last question is a very important one. Managing cybersecurity and assessing cybersecurity are two very different skill sets. Just because an organization is experienced in supporting cybersecurity, it does not mean they know how to assess cybersecurity. Experience in assessment work is invaluable when it comes to CMMC assessments because it gives the experienced assessor the advantage in knowing what to look and what to ask.

Summary

As a certified C3PAO, Provincia Government Solutions prides itself in the straightforward honest approach we take towards each and every client. We welcome vetting questions and want you to feel confident in selecting us to participate in your CMMC journey. Feel free to reach out to us and ask any questions that will help you make the best decision.

In our next article, we will address POAM’s and the role they play in the CMMC ecosystem. Be sure to subscribe to this blog so you do not miss out on any of the great articles coming up!

Upcoming Blog

We will discuss the significance of POAM’s in the next article. This article will help navigate this precarious aspect of CMMC.

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!

Subscribe to our Blog!

Be The First

to Know

When New Blog Content is Published

Contact Information

  • P.O. Box 1685
    Spring Hill, TN 37064
    United States
  • +1 (615) 807-2822 | info@provincia.io

Social Networks

Links List

ABOUT US

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!