CMMC Assessments: What to Expect

CMMC Assessments: What to Expect and How to Succeed

Preparing is not just important for companies navigating this process, it’s essential. On this page and in the webinar, we break down the CMMC assessment process, provide actionable preparation tips, and outline strategies to succeed.

Understanding the CMMC Framework

The CMMC model is designed to improve the cybersecurity resilience of organizations handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). It consists of three maturity levels:

Level 1: Basic Cyber Hygiene (17 Practices)

Level 2: Intermediate Cyber Hygiene (110 Practices aligned with NIST SP 800-171)

Level 3: Advanced Cybersecurity Practices

While Level 1 may suffice for some contracts, most organizations targeting sensitive DoD work must aim for Level 2. Certification is achieved through an extensive CMMC assessment process conducted by a C3PAO.

What are the Four Phases of a CMMC Assessment?

CMMC assessments are methodical and consist of four major phases:

1. Plan and Prepare

The groundwork for the assessment is established here:

• • Scope Definition: Boundaries, systems, and the CMMC level are agreed upon.
  • Readiness Review: A pre-assessment check ensures evidence, policies, and implementations are in place.
  • Evidence Collection: The Organization Seeking Certification (OSC) gathers documentation, such as system configurations and security policies.

Preparation Tip: Conduct mock assessments and identify gaps early for remediation.

2. Conduct the Assessment

The C3PAO team evaluates adherence to the 110 practices of NIST SP 800-171 through various activities:

• • Interviews: Staff demonstrate knowledge and implementation of security practices.
  • Observations: Assessors review physical and technical security controls.
  • Evidence Validation: Systems, logs, and documentation are analyzed.

This phase typically lasts 3-5 days, depending on the organization’s size and scope.

Example:

An assessor might ask your IT administrator to demonstrate the process of revoking access to a system, ensuring the correct procedures and tools are used.

3. Report Findings

The assessors consolidate their findings into a comprehensive report:

• • Practice Evaluation: Practices are marked as “Met” or “Not Met.”
  • Scoring and Recommendations: The report includes detailed scores, gaps, and actionable advice.
  • Quality Check: Results are submitted to the CMMC eMASS system after review.

4. Close-Out and POAM

For any practices marked as “Not Met,” organizations create a Plan of Action and Milestones (POAM) to address deficiencies:

• • Remediation: Organizations correct gaps and provide evidence of compliance.
  • Reassessment: The C3PAO validates the corrective actions.
  • Final Decision: If successful, the OSC will receive its CMMC certification.

How to Prepare for a CMMC Assessment

1. Documentation Readiness

• • Centralize all relevant documents:
  • Security policies, procedures, and incident response plans.
  • Technical configurations, such as firewall rules and encryption settings.

2. Staff Training and Awareness

Ensure staff can articulate security processes:

• • Conduct regular training sessions.
  • Role-play scenarios like data breaches or access revocations.

3. Conduct Mock Assessments

Simulate the assessment to identify weaknesses:

• • Review technical controls and processes.
  • Test data protection, monitoring, and incident response mechanisms.

4. Remediate Gaps

Address any vulnerabilities identified during preparation:

• • Update documentation.
  • Enhance physical and technical controls.

5. Physical Security Validation

Don’t overlook physical protections:

• • Secure server rooms, cameras, and badge access systems.
  • Validate workstation security, document disposal practices, and restricted area access.

What Is Involved In Each Phase Of An Assessment?

Phase 1: Agreement on scoping, readiness review, and objective evidence package review.

• • Scoping Agreement: The C3PAO and the OSC agree on the scope of the assessment, which includes defining the boundaries of the assessment, the systems involved, and the level of CMMC certification sought.
  • Readiness Review: The C3PAO conducts a readiness review to ensure that the OSC is prepared for the assessment, checking for the completeness of documentation and implementation of practices.
  • Objective Evidence Review: The C3PAO reviews the objective evidence package provided by the OSC, which includes documentation, policies, and procedures that demonstrate compliance with CMMC requirements.

Phase 2: Interview phase, lasting 3-5 days, where assessors review each of the 110 practices for NIST 800-171.

• • Practice Review: The assessors conduct a detailed review of each of the 110 practices and 320 assessment objectives outlined in NIST 800-171a, evaluating the OSC’s adherence to cybersecurity standards.
  • Interviews and Observations: Assessors conduct interviews with relevant personnel and observe processes to validate that the practices are consistently and effectively implemented.
  • Evidence Collection: The assessment team collects evidence such as records, logs, and documentation during this phase to validate the OSC’s compliance with the practices.

Phase 3: Reporting phase, where the formal report is provided, indicating met or not met practices.

• • Compile Findings: The assessors compile their findings, including details on practices that are met or not met, and prepare a detailed report.
  • Recommendations and Scores: The report includes recommendations, scores for each practice, and a summary of the findings. Clear traceability is maintained between each finding, score, and practice status.
  • Submission to C3PAO: The results and findings summary are submitted to the C3PAO for review and further quality checks before being submitted to CMMC eMASS.

Phase 4: POAM (Plan of Actions & Milestones) phase, where organizations work to address items not met.

• • Deficiency Correction: The company works on addressing and correcting the practices that were marked as “NOT MET” during the assessment, providing evidence for the corrections.
  • POAM Review: The C3PAO Assessment Team reviews the updated POAM and any accompanying evidence to validate that deficiencies have been addressed.
  • Final Certification Decision: Depending on the successful correction of deficiencies, the Lead Assessor may recommend the OSC for a Final CMMC Certification or advise reapplication if compliance is not achieved.

What Are the Main Types of Evidence Assessors Collect During an Assessment?

Assessors rely on multiple forms of evidence to ascertain compliance:

• • Documents like policies, plans, and records.
  • Examination of systems and infrastructure.
  • Interviews with personnel at all levels.
  • Observation of processes.
  • Results from tools and testing procedures.

What Are Some Examples of Physical And Technical Evidence?

• • On the physical side, assessors will look for things like properly configured firewalls, server racks with lockout procedures, and secure areas to store sensitive data.
  • On the technical side, an assessor may review scan reports that validate patch levels, examine audit log settings, or inspect code repositories to verify secure coding practices.

How Do Interviews And Demonstrations Play A Role?

Interviews allow assessors to verify that policies are known and followed consistently across the organization.

Staff members may be asked to explain or demonstrate certain processes. For example, walking through an incident response scenario or showing how access controls are implemented. This confirms real-world understanding and application.

The Role of Evidence and Interviews in CMMC Assessments

Types of Evidence Assessors Seek

• • Documents: Policies, procedures, and audit logs.
  • System Examination: Tools, configurations, and reports.
  • Interviews: Conversations with personnel at all levels.
  • Observations: Walkthroughs of processes.

Why Interviews Matter

Interviews validate the real-world implementation of security controls:

Example 1: An assessor asks a team to simulate their response to a data breach. The team walks through incident containment, reporting, and communication.

Example 2: An IT admin demonstrates how user access is revoked from a system.

Tip: Encourage staff to practice explanations and walkthroughs to build confidence.

Tips for Partnering with a C3PAO

• • Communicate Transparently: Share challenges and clarify evidence requirements.
  • Stay Organized: Ensure documentation and access are ready to prevent delays.
  • Be Cooperative: Work as a team; assessors are partners in your compliance journey.

Common Pitfalls to Avoid

• • Lack of Preparation: Underestimating the process can lead to compliance failures.
  • Disorganization: Frustrating assessors with missing or incomplete documentation.
  • Ignoring Physical Security: Digital controls alone won’t suffice; secure physical areas, too.
  • Combative Attitude: Adopt a collaborative mindset to foster a positive assessment process.

Post-Certification: The Journey Continues

Achieving CMMC certification isn’t the finish line—it’s the start of a long-term commitment to cybersecurity maturity:

• • Conduct Regular Reviews: Stay proactive by performing internal assessments.
  • Adapt to New Threats: Cyber threats evolve; your processes should, too.
  • Foster Cyber Awareness: Keep security ingrained in your organizational culture.

Final Thoughts

Rick’s Advice: Start early, document thoroughly, and train your team. Collaboration with your C3PAO is key to success.

Scott’s Perspective: View assessments as opportunities to grow. The process ultimately strengthens your cyber maturity and resilience—embrace it!

Conclusion:

Preparing for a CMMC assessment may feel daunting, but with careful planning, diligent preparation, and a collaborative mindset, organizations can achieve certification and build a foundation for stronger cybersecurity. The investment you make today not only ensures compliance but positions your organization as a trusted partner in safeguarding sensitive information.

This comprehensive approach to CMMC assessments ensures you’re not just ticking boxes but building a sustainable and resilient cybersecurity posture. Start your journey today—prepare, collaborate, and succeed.