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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Provincia Government Solutions is a Nashville TN based Authorized CMMC Third-Party Assessor Organization (C3PAO) and SBA Certified small business specializing in Cybersecurity Assurance Services for government agencies, contractors, and commercial organizations affiliated with government entities.

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!

 

5 C3PAO Red Flags

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!

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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!

 

Paying for a CMMC Pre-Assessment can Save Money

Can a CMMC Pre-Assessment Save You Money?

By Sese Bennett

October 31, 2022

As you are reading and preparing for the DoD’s CMMC 2.0 assessment, you more than likely have observed that both assessment and consulting organizations are offering a pre-assessment for those interested in attaining CMMC 2.0 certification. Did you ever think that spending money might actually save money? While there are still some requirements and restrictions that are still unclear, this article will help you determine if paying for a CMMC Pre-Assessment saves money. Likewise, we will discuss what type of pre-assessment is most likely to best prepare your company for the CMMC 2.0 certification assessment.  Paying for a CMMC Pre-Assessment can save money

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.

In this blog, we discuss 5 C3PAO red flags that you should look for when interviewing prospective C3PAO’s to perform your CMMC assessment.

What is a CMMC Pre-Assessement?

To begin with, let’s define what a pre-assessment is and what it is not. In the context of CMMC, pre-assessments are a service that can be provided by anyone with knowledge of the CMMC 2.0 requirements prior to the formal certification assessment. Pre-assessments can be done in several different ways, but we will discuss the three most common options when considering this path for your organization. The value you gain from a pre-assessment greatly depends on the way it is performed and the deliverables you receive. Just remember that a pre-assessment is not the same as the formal certification assessment, and therefore is not a required step for certification. However, it is preferred. Read on to see why.

Shown below is the PGS Cheat Sheet for CMMC Pre-Assessment Guide. We will go discuss each option in more detail in the sections that follow.

Met/Not Met Assessment – Option 1

The first approach to CMMC pre-assessments requires a knowledgeable CMMC resource to assess your CMMC environment for compliance. After accessing your environment, the assessor provides a report specifying the status of each practice reviewed for compliance. This report will specify a status of Met or Not Met (failed) but will not contain remediation advice, details, or steps to correct any issues identified. Although this information can be useful, it can leave companies with more questions than answers. 

This option is typically a less expensive but also a less valuable option when it comes to pre-assessments. This type of pre-assessment can be conducted by Certified Third Party Assessment Organizations (C3PAO) that is or is not conducting your certification assessment, a Registered Practitioner Organizations (RPO’s), an external non-CMMC certified individual knowledgeable about CMMC, or even an existing non-CMMC internal resource with CMMC knowledge. Non-certified CMMC resources can present unique challenges   for an organization. These can include lack of knowledge of revised CMMC requirements, over-familiarity with the environment, lack of management impact due to already being part of the organization (familiarity breeds contempt; no one can be a prophet in their own land, etc.)  – well, you get the point.

Detailed CMMC Pre-Assessment with Recommendations – Option 2

The second approach to CMMC pre-assessments also requires a knowledgeable CMMC resource to assess your CMMC environment for compliance. For this approach, it is recommended that OSC’s (Organizations Seeking Certification) work with a C3PAO to conduct a detailed assessment of the CMMC environment. Output from this assessment should include a detailed report that includes the status of each practice (Met or Not Met) along with the remediation recommendations for correcting and deficiencies identified during the pre-assessment. This in-depth report and associated advice are far more useful than just a Met/Not Met report as discussed previously. The detailed CMMC pre-assessment with recommendations may be the more expensive option, but the return on investment is invaluable. 

With this approach, there are a few additional things to consider. The rules surrounding the CMMC 2.0 assessment process address issues that could arise and be viewed as a “Conflict of Interest”. An example of this would be when a C3PAO performs a pre-assessment for a OSC that includes recommendation or remediation advice or assistance. In this example, that C3PAO cannot perform the certification assessment since they have provided consulting assistance to the OSC. If this is the case, the C3PAO would work with the OSC to identify a different and independent C3PAO to perform the actual certification assessment. C3PAO’s in this scenario do not collaborate or share any information regarding the pre-assessment or certification assessment.

The rule to keep in mind is that if your favorite C3PAO assists you with recommendations, remediation steps or advice, or issue resolution in any way, this is considered consulting and that C3PAO cannot perform your CMMC 2.0 certification assessment.

Do Nothing (a.k.a. – Stick Your Head in the Sand) - Option 3

Of course, there is an option 3. That is to forgo the pre-assessment altogether. From a “likelihood of CMMC success” perspective, this seems to be the riskiest choice The chance of failing the assessment altogether is greatest with this option. Yes, with this option you will save money up front, but the cost of failing, remediation, and a second assessment is far more expense and time consuming in the end.

Summary

The CMMC pre-assessment is a critical part of your preparation process for successfully achieving your goal of CMMC certification. While achieving certification is possible with a pre-assessment, why risk it? Paying for a CMMC Pre-Assessment saves money and time.

Bypassing the opportunity for a pre-assessment significantly reduces your chances of certification on your first try and increases the likelihood that you will spend more on re-assessment activities in the future. Overall, a net loss for your organization.

Here at Provincia Government Solutions, we partner with a network of experienced and knowledgeable C3PAO’s. Whether we are preforming the pre-assessment or the formal certification assessment, we can recommend multiple C3PAO partners for your consideration. We are here to help you earn your CMMC 2.0 certification. Your success is our success.

Upcoming Blog

We will discuss the top 5 questions you should ask any prospective C3PAO in the next article. This article will help you hire the best C3PAO to do the CMMC Assessment for your company.

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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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!