Military contractors gearing up for CMMC 2.0 compliance may need to work with an official C3PAO to secure certification. C3PAOs play a critical role in the CMMC ecosystem by preparing Level 2 CMMC organizations for DoD compliance. As such, finding a quality partner is critical.
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What is a C3PAO, and How Can You Find One?
Certified third-party assessment organizations (C3PAO) are managed security service providers (MSSPs) that are authorized to conduct audits for Cybersecurity Maturity Model Certification (CMMC). In practical terms, Department of Defense (DoD) contractors may need to work with a C3PAO to achieve and maintain compliance and secure lucrative DoD contracts long-term.
In terms of finding one, C3PAOs are listed on the Cyber AB’s website. However, picking the right assessment partner is a critical process that requires an in-depth understanding of:
- The role C3PAOs play in the CMMC ecosystem
- What qualities to seek out in a C3PAO partner
- Other regulatory compliance considerations
Organizations seeking CMMC 2.0 compliance should reach out to potential C3PAO partners ASAP to lock in their assessment logistics and ensure preferred contractor status with the DoD.
Understanding C3PAOs’ Role in the CMMC Ecosystem
Organizations that meet the criteria for CMMC 2.0 Level 2 need to work with a C3PAO to secure CMMC compliance. There are three Levels in the CMMC 2.0 framework; Level 2 corresponds roughly to Level 3 in earlier versions of CMMC. It is required for DoD contractors who process both Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
With respect to overall scoping, organizations at Level 1 implement 15 unique Practices, while those at Level 2 implement 110. The full scope of deployment at Level 3 is not yet finalized, but Level 3 organizations will require government-led assessments while Level 1 can self-assess.
For many organizations at Level 2, a third-party assessment is required to ensure compliance.
The Cyber AB (formerly the CMMC Accreditation Body) is the only entity capable of qualifying assessors with C3PAO status. C3PAOs are the only third-party organizations that entities at Level 2 who require third-party assessments can work with to ensure CMMC compliance.
There are DoD contractors at Level 2 who qualify for self-assessments. However, that status could change at scale. Working C3PAOs helps lower-Level entities future-proof themselves.
The Cyber AB’s Qualification and Listing Process
The rigorous C3PAO certification process ensures that third-party assessors are qualified and capable of assessing organizational security at the scale and stakes necessary. Candidates complete an application and pay a fee schedule, then submit to multiple rounds of testing.
First, the Cyber AB works with Experian to conduct a background check. Then, citizenship and loyalty to the US government and armed forces are vetted through Foreign Ownership, Control of Influence (FOCI) and SF-328 analyses. Then, the organization needs to pass a CMMC 2.0 assessment through the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
Moving forward, ISO 17020 Accreditation will also be a key requirement for C3PAOs.
Another element of the broader requirements of an assessor organization is how individual assessors must be vetted, as well. Assessor organizations Certified CMMC Assessors (CCA), who must first become qualified as Certified CMMC Professionals (CCP). Part of the process of achieving qualification is administering CMMC Level 2 assessments, to prove their capabilities.
All CMMC C3PAO listed by the Cyber AB’s have gone through the same process, but firms seeking DoD compliance should seek out assessment partners that will cater to their needs.
What to Look for in a C3PAO Partner
As noted above, C3PAOs are listed on the Cyber AB’s website. However, not all CMMC third party assessment organizations are created equal. When comparing providers, organizations should prioritize assessors who are willing and able to cater services to their needs and means.
When comparing C3PAOs, make sure to consider the following qualities:
- Capacity alignment – Some assessor organizations employ bigger teams of assessors and advisors than others.Candidates with larger and more complex IT deployments may need to seek out bigger teams, whereas smaller systems may not necessitate them.
- Certification and status – All C3PAOs have been registered, but candidates should confirm how recent or current the assessor’s status is. An assessor with a longer track record of successful qualification and a longer timeline to re-qualification may be better.
- Logistical conveniences – All things equal, DoD contractors may prefer to work with C3PAOs that are geographically closer to them. Easier on-premise support is a major benefit, and another consideration is time zone management for communication.
The best CMMC compliance partnerships come from well-aligned candidate-C3PAO pairings where the assessors are attentive to the needs of the DoD contractor. Proximity is by no means a requirement, but it can help with communication cadence, availability, and on-site support.
Spotlight: Readiness Assessments and Support
The best C3PAO CMMC partners offer more than just authorized audits for certification. They work with CMMC candidates to ensure that all requirements are met prior to the official audit, reducing the likelihood of failure and resultant costs of remediation and re-implementation.
As the name implies, readiness assessments are mock audits that determine whether or not a DoD contractor is prepared for their official, authorized assessment. Organizations can conduct self-assessments en route to their official assessment, or they can work with a C3PAO to unlock greater insights about what the full-blown audit will look like. For instance, beyond checking if all required controls are collected, C3PAOs can apply proper scrutiny and emulate other specific details of an authorized Level 2 assessment. In the most advanced scenarios, they can also incorporate elements of penetration testing and simulate suboptimal conditions as a stress test.
When seeking out an assessment partner, you should consider both the official assessment itself and other preparatory best practices that facilitate a seamless authorized audit.
Other Regulatory Compliance Considerations
When shopping around for C3PAOs, it’s also critical to understand the broader context in which they—and CMMC—operate. First, you should appreciate how CMMC 2.0 is a composite of two other governmental frameworks, with some adjustments made to the terminology and other considerations to account for DoD-specific risks. CMMC comprises controls from the National Institute of Standards and Technology’s (NIST) Special Publications (SP) 800-171 and 800-172.
More specifically, CMMC expanded and replaced NIST SPs 800-171 and 800-172. The upshot is that assessors with a track record in those frameworks are often uniquely qualified for CMMC.
Second, CMMC candidates should appreciate how CMMC relates to other common regulations.
If your organization also needs to assess for Payment Card Industry Data Security Standards (PCI DSS) compliance, for example, you may need to work with a Qualified Security Assessor (QSA). An assessor who is both a C3PAO and a QSA (like RSI Security) would be ideal.
Prepare for CMMC Assessments Today
Ultimately, organizations seeking DoD contracts and with moderate to large IT infrastructures may need to work with a third-party assessor. Given the unified qualification processes for these assessors, it’s imperative to know what you’re looking for across CMMC and other regulations.
RSI Security has achieved full C3PAO qualification and is currently listed by the Cyber AB; our experts include both CCPs and CCAs equipped to facilitate all parts of CMMC 2.0 compliance.
We have also been helping DoD and other government contractors achieve compliance long before CMMC 2.0 was even developed. We have a track record of service and are committed to helping all DoD contractors rethink their security to achieve and maintain DoD certification.
To learn more about our C3PAO and broader CMMC services, contact RSI Security today!
