Preliminary Proceedings
Before a formal assessment can begin, the C3PAO must confirm the legal identity of the OSC by requesting this identifier, which is issued by the Department of Defense and ties directly to the OSC’s in-scope information systems.
What is the Commercial and Government Entity (CAGE) code?
These regulatory standards must be met by the C3PAO when a quality assurance individual conducts a quality assurance review of the Pre-Assessment Form upon completion by the CMMC Assessment Team, ensuring proper oversight and compliance before the form can be uploaded into the CMMC instantiation of eMASS for DoD program management purposes.
What are 32 CFR §170.9(b)(13) requirements?
This formal meeting convened by the Lead CCA prior to commencing security requirements assessment serves to establish common understanding of assessment objectives, procedures, roles, responsibilities, and schedule while introducing team members and confirming the CMMC Assessment Scope with all stakeholders present.
Why is an In-Brief Meeting conducted?
This process involves gathering all evaluative activities from Phase 2 and structuring them into a required format, often for eventual upload into the CMMC instantiation of eMASS, and can utilize a specific template or a compliant tool generating JSON files, signifying the initial compilation of all assessment findings.
What is “Compiling and Composing Assessment Results”?
This official, who must be on file with The Cyber AB, is the only person authorized to approve and sign all C3PAO-generated Certificates of CMMC Status.
Who is an Authorized Certifying Official?
If the OSC has performed a previous self-assessment, the C3PAO may request this unique identifier from SPRS, which mirrors the format and function of the CMMC eMASS UID but is not mandatory for a Level 2 assessment.
What is the SPRS unique identifier (UID)?
When composing its Assessment Team in Phase 1 of the CMMC Assessment Process, the C3PAO shall have implemented the comprehensive personnel procedures—covering assessor selection, qualification, training, conflict-of-interest management, and impartiality controls—established in Section 6.15 and Section 6.16 of this international standard prior to beginning Phase 2.
What are ISO/IEC 17020 personnel procedures?
This comprehensive measurement system established in 32 CFR §170.24 evaluates OSC implementation of NIST SP 800-171 R2 security requirements through three possible findings, with point values of one, three, or five subtracted from maximum scores based on basic versus derived requirement classifications and potential security impact.
What is the CMMC Level 2 Scoring Methodology?
If all security requirements are fully implemented with no gaps, the Lead CCA will recommend this outcome, indicating that the OSC qualifies for full certification based on Phase 3 assessment findings and reporting.
What is a “Final Certificate of CMMC Status”?
The C3PAO must deliver an electronic copy of the Certificate of CMMC Status to The Cyber AB through this specific organizational email account as part of the required notification and documentation process for maintaining program oversight and records.
What is the certificates@cyberab.org account?
The C3PAO and OSC collaboratively determine purview and planning details, including schedule, organization size, personnel, logistics, and prospective scope. They agree on personnel, evidence, and documentation availability, plus assessment duration, timing, and location considerations for specific security objectives.
How is a CMMC L2 Assessment Framed?
Upon collecting all requisite pre-assessment and planning information—including CAGE code, SSP title, contact information, and assessment dates—the C3PAO shall complete the document according to CMMC eMASS standards, preparing JSON-compliant data for submission into the DoD’s oversight system prior to quality assurance review.
What is a Pre-Assessment Form?
The Assessment Team must host these regular coordination sessions with the OSC POC and personnel at the conclusion of each assessment day to summarize progress, identify challenges, discuss coordination items, and maintain communication throughout the evaluation process ensuring transparency and addressing issues promptly.
What are Daily Checkpoint Meetings?
These comprehensive duties include conducting formal quality assurance reviews of certification assessment results, uploading results into CMMC eMASS, ensuring OSC hashing data incorporation, managing Assessment Appeals processes, performing quality reviews of appeals templates, and maintaining independence from original Assessment Teams while ensuring accuracy and completeness of all evaluation documentation.
What are responsibilities or roles of a Quality assurance individual in Phase 3 of the CMMC Assessment Process?
While the Assessment Team has the discretion to offer this type of meeting to the OSC following POA&M closeout activities, it is not mandatory, though the team must still convey results in writing and communicate remaining administrative next steps to the organization.
What is a POA&M Out-Brief Meeting?
After confirming entity identity, resolving conflicts of interest, framing the assessment parameters including scope, location, and resource availability, and once both parties have agreed on financial and professional terms, the C3PAO and the OSC must formally execute this critical written document that should incorporate a mutual NDA, and ensuring it comports with the CMMC Code of Professional Conduct.
What is the contractual agreement?
This outcome is achieved when the Lead CCA verifies the OSC's CMMC Level 2 Assessment Scope according to 32 CFR §170.19(c) requirements, resolves any disagreements or differences of opinion between the C3PAO and OSC, and confirms proper scoping before the assessment may proceed to Phase 2 activities.
What is Assessment Scope Validation?
If an OSC asserts their Cloud Service Provider's environment meets security requirements of FedRAMP Moderate equivalency without formal authorization, the Assessment Team must meticulously review this specific collection of documentation comprising System Security Plan (SSP), Security Assessment Plan (SAP), Security Assessment Report (SAR) and Plan of Actions and Milestones (POA&M) for completeness, intactness, and established periodicity, without conducting a qualitative examination of its contents.
What is a CSP’s FedRAMP Moderate Equivalency body of evidence (BOE)?
Should the OSC oppose the C3PAO's adjudication decision on their Assessment Appeal, they may elevate their appeal to this organization within fifteen business days, and all decisions rendered by this entity are considered final with no further appeal options available.
What is The Cyber AB?
For an Organization Seeking Certification that has received a CONDITIONAL Level 2 Certificate, this specific process allows them to engage a C3PAO, potentially different from the original assessment team, to rectify deficiencies identified in a Plan of Action & Milestones, ultimately aiming for a FINAL Level 2 Certificate.
What is closing out a Plan of Action & Milestones (POA&M)?
When executing the contractual agreement, this CMMC Code of Professional Conduct stipulation strictly forbids this entity from offering any "guarantees" or "promises" regarding the assessment results, or including incentives contingent on achieving a Certificate of CMMC Status.
What specific prohibitions apply to the C3PAO within the contractual agreement regarding assessment outcomes?
This occurs when the Lead CCA determines insufficient OSC preparation for CMMC Level 2 certification assessment and is formally communicated to the OSC Affirming Official in writing with explanations for suspension recommendations, while prohibiting any remedial advice, implementation assistance, or recommendations that would conflict the C3PAO from eventually resuming assessment activities.
What is Adverse Determination of Assessment Readiness?
The Assessment Team must adhere to these three specific evaluation approaches outlined in NIST SP 800-171A when assessing the OSC's implementation of security requirements, ensuring comprehensive coverage through document review, personnel questioning, and functional verification of security controls and procedures.
What are examine, interview, and test assessment methods?
This presentation must be developed within common presentation applications and include specific elements such as C3PAO logo, Lead CCA name, assessment dates, OSC name, CAGE codes, final determinations, POA&M status, and certificate determination while excluding any remedial action recommendations.
What is the Assessment Results Briefing?
Should the C3PAO dispute the findings of the CMMC Assessment Team during the POA&M closeout, they retain the right to initiate this formal recourse, with the process and timelines for resolution mirroring those established in Phase 3, ensuring a consistent approach to resolving disagreements.
What is appealing the POA&M closeout findings?