What Is a CMMC C3PAO and What Do They Do?
EXECUTIVE BRIEF
A key change to the revised CMMC program, CMMC 2.0, is the introduction of third-party assessments by CMMC 3rd-Party Assessment Organizations (C3PAOs). Here's what defense contractors need to know about C3PAO:
- The only entities capable of assessing and certifying defense contractors for CMMC Level 2.
- Contractors choose the C3PAO to conduct their assessment. The C3PAO then puts together an assessment team consisting of at least a Lead Certified CMMC Assessor (CCA), a secondary CCA, and an individual conducting Quality Assurance.
- C3PAOs can also consult or conduct mock audits for organizations during their compliance journey. However, the C3PAO consulting your organization is not allowed to conduct your official CMMC assessment.
Dig deeper and continue reading below!
The Cybersecurity Maturity Model Certification (CMMC) program was developed to standardize cybersecurity practices throughout the defense supply chain to protect sensitive information. Specifically, the program aims to protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI).
On December 16, 2024, the revised CMMC program, CMMC 2.0, was launched. One of the key features of the revised program was the addition of CMMC 3rd-Party Assessment Organizations (C3PAOs) to verify compliance for Level 2 contractors, the maturity level handling CUI.
This article will further explain the role of C3PAOs and what their role is within the CMMC ecosystem.
What is a C3PAO?
One of the lessons learned from the original CMMC program was an over-reliance on self-assessments. Nearly 3/4s of the Defense Industrial Base (DIB) are contractors classified as small or medium-sized businesses (SMBs). These contractors are essential in developing cutting-edge technology to enhance our national security, but they often lack expertise in complex regulatory requirements.
The CMMC 3rd-Party Assessment Organizations (C3PAOs) were introduced to the CMMC program to provide a true representation of a contractor’s compliance posturing. The C3PAO is responsible for assessing and certifying compliance, a new prerequisite for accepting award of a defense contract.
ISI INSIGHT: ISI has vetted a select number of C3PAOs, providing our customers with the benefit of working with C3PAOs familiar with our process and approach. By ensuring a predictable environment and scope for the C3PAOs, our customers can anticipate more consistent outcomes, shorter evaluation timeframes, and cost savings.
C3PAO Roles and Responsibilities
As the entities designated to certify organizations seeking Level 2 certification, C3PAOs are critical to the CMMC ecosystem. Their key responsibilities include:
Pre-assessment: Your C3PAO’s assessment team will schedule a pre-assessment meeting to confirm the Organization Seeking Certification’s (OSCs) scope, ensure access to required artifacts and documentation, and verify the OSC is ready to undergo the assessment.
Conducting the Assessment: The team of at least two CMMC-Certified Assessors (CCAs) will assess your environment via three assessment methodologies: interview, examine, and test. The time required to complete the assessment depends on the size of your scope and the complexity of your environment. We are advising our customers to expect the assessment to take about five-full business days.
Post-assessment: Meet with the team of the OSC to discuss their findings and inform you of your certification status. If conditional certification is determined, review what controls need to be placed on the Plan of Action & Milestones (POA&M) document and describe the POA&M closeout process. If you fail or receive conditional certification the C3PAO cannot offer advice or guidance on remediation efforts.
Qualifications and Certification Process for C3PAOs
The first step to becoming a CMMC Third Party Assessment Organization (C3PAO) is to apply through the Cyber AB website. Applicants undergo a multi-step screening process that includes a risk assessment by Dunn and Bradstreet, a Foreign Ownership, Control, or Influence (FOCI) analysis, and an interview with senior management. This process ensures that C3PAOs are reputable organizations with minimal risk of foreign influence.
Once they pass the screening process, C3PAO applicants become C3PAO Candidates. They are then assessed by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) at Capability Maturity Model Integration Level 2. Upon successful completion of the assessment, meeting administrative requirements, and receiving authorization from the Cyber AB, C3PAOs become authorized to conduct CMMC assessments for the Department of Defense.
C3PAO Services
CMMC Assessments
Only a Cyber AB-approved C3PAO can certify your organization for CMMC Level 2 (C3PAO). They have demonstrated their expertise in the CMMC assessment process, including:
- Pre-assessment: Collecting documentation, artifacts, and validating scope
- Conducting the assessment: Trained on how to use interview, examination, and testing methodologies
- Post-assessment and certification: Submitting findings into eMass, hold post-assessment meeting, issue conditional or final certification
Gap Analysis and Remediation
In addition to assessing organizations, C3PAOs can also be enlisted to assist in a contractor’s CMMC preparation journey. However, the C3PAO that is consulting your organization cannot perform your official assessment.
Working with a C3PAO during your assessment preparation is like hiring a teacher as your tutor. They can:
- Identify deficiencies in cybersecurity controls and documentation
- Help develop a remediation plan ahead of a CMMC assessment
- Provide recommendations for compliance service providers to work with
Tailored Support
A certified C3PAO knows exactly how to scope and assess an organization no matter its size and complexity. Working with a C3PAO during your CMMC preparation will provide you with expert, tailored solutions to navigate regulatory changes.
Benefits of Working with a CMMC C3PAO
Enhanced Security
The CMMC program is designed to standardize and enhance the security posture of the entire defense supply chain. Enlisting a C3PAOs guidance during the preparatory stage not only sets your business up for a successful assessment but also gives you insights into how to best protect your business from threat actors attempting to steal or access the sensitive information you handle.
Streamlined Processes
A C3PAO can take a lot of the guesswork out of preparing for the CMMC assessment process. Enlisting the help of a C3PAO can provide your business the insights it needs on what to expect during your audit, including:
- What the pre-assessment meetings will look like for your organization
- What artifacts and documentation will need to be prepared and ready, as well as which team members will need to be available
- What the post-assessment meeting will look like and what the timeline could look like for receiving your certified status
Your C3PAO will also be able to guide your team, or Managed IT provider, to ensure you’re on the path to a successful CMMC assessment.
Future-Readiness
Few are more attuned to the potential changes to the CMMC program than a C3PAO. If you’re working with a C3PAO as a consultant and not as your assessor, they will likely be able to keep your organization apprised on upcoming regulatory changes that could impact your compliance posture ahead of your next CMMC assessment.
Finding the Right C3PAO Partner
If you’re going through your CMMC-compliance journey alone, make sure to go to the CyberAb.org website to view the list of certified C3PAOs to perform your assessment. Our advice: Make sure to interview at least three to make sure you are choosing a C3PAO you can build a rapport with and ensure your assessment is being scheduled as close to your timeline as possible.
If you’re working with a Managed IT provider, like ISI, reach out to them and see if they have vetted or recommend any C3PAOs. These C3PAOs may have more familiarity working with your IT provider and understand their process and procedures. This could result in a more streamlined assessment process, ultimately increasing the predictability of the assessment process and outcome and reducing costs.
Challenges and Considerations for Contractors in Engaging a C3PAO
In general, engaging with a C3PAO is a straightforward process. All certified C3PAOs are listed on the CyberAB.org website. A contractor can reach out, set up a call, and get their assessment on the schedule if they wish to. However, that’s probably not the best strategy.
You are investing a lot of time and financial resources into your C3PAO. Additionally, your assessment is the key to unlocking your ability to work on defense contracts. It is critical to work with a C3PAO that:
- You can build rapport with
- Can communicate effectively with you and your team members
- Has availability to conduct your assessment within a timeframe that keeps your business competitive for new defense contracts
C3PAO FAQ
Why Start the CMMC Certification Process Now?
CMMC 2.0 has two parts:
- 32 CFR: Defining the CMMC program including security requirements, certification process, and marketplace (C3PAOs, External Service Providers, … etc.)
- 48 CFR: CMMC-certification contractual requirements to accept award of defense contracts
As of now, the CMMC program is final and live. However, contract requirements are not enforced by the government yet. That said, now that the CMMC program is live, prime contractors can begin flowing these requirements down to their subcontractors ahead of the government’s phased rollout.
What’s the bottom line? Waiting for the government’s rollout of CMMC contract requirements increases your risk of losing out on contracts. There is already evidence of primes asking to see when your CMMC assessment is scheduled. If you can’t provide this information, you won’t work on their contract.
Your compliance journey is likely going to take at least 9-12 months. Starting today is the surest way to ensure your company can achieve compliance by the government’s, as well as your prime contractor’s, timeline.
What Are the 3 Levels of CMMC?
The revised CMMC model has reduced the number of maturity levels from five to three. The three maturity levels of CMMC 2.0 are:
- Level 1 (Foundational): for contractors only handling Federal Contract Information (FCI). Requires adherence to 17 cybersecurity controls listed in NIST 800-53, certification achieved through self-assessment.
- Level 2 (Advanced): For contractors handling Controlled Unclassified Information (CUI). Requires adherence to all 110 controls and 320 objectives outlined in NIST SP 800-171, certification through third-party assessment.
- Level 3 (Expert): For contractors handling CUI requiring additional security safeguards. Requires Level 2 certification as well as 24 additional controls outlined in NIST 800-172. Assessments performed by the government’s Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
The vast majority of defense contractors are going to fall into Level 2 certification,, with the government projecting 80,000 contractors to be adhering to Level 2 requirements.
What If You Fail an Assessment?
Failing your CMMC assessment is not the end of the world - but there are serious consequences to consider:
- It could hurt your reputation with prime contractors
- It will prolong your compliance timeline, denying you the opportunity to accept new contracts
- Failing your assessment essentially doubles your compliance costs as you will have to pay for another assessment
What Impact Does CMMC Have on Subcontractors?
The biggest impact CMMC has on defense subcontractors is that compliance is now a requirement to work on defense contracts. The good news is this enhanced security posture is a net gain for your organization as it not only opens up opportunities for new contracts - but it also defends your business against cyber-attacks.
That said - it comes with a cost. The tools, software, and resources needed to achieve compliance are not free. But there are ways to reduce those costs. The best way to streamline your compliance journey and reduce costs is to enlist the help of a Managed IT provider like ISI. Here’s how we help:
- Provide a vetted security tool stack that achieves 65% compliance during the onboarding phase alone
- Expert support from a Cyber AB certified Registered Provider Organization (RPO), with three Registered Practitioners (RPs) and CMMC-Certified Professionals (CCPs)
- Access to an ecosystem of C3PAOs familiar with and have validated our process and procedures
ISI doesn’t just offer support, we offer predictability.
