With the CMMC 2.0 compliance rules expected to become law, companies registered in the Defense Industrial Base (DIB) need to prepare for the rigorous certification process for Level 2 and Level 3 compliance.
The consequences of not being certified or failing the CMMC assessment when the time comes are to be taken seriously: potentially losing existing DoD contracts, being unable to renew them, or not being allowed to bid on new ones.
In this blog, we do a deep dive into the CMMC audit process, how to choose the right C3PAO organization to perform your assessment, and other important factors to consider — such as partnering with an expert team of CMMC consultants like EXTEND — to significantly improve your chances of achieving certification.
What is a C3PAO? How Do I Know If I Need One?
A C3PAO is an organization that has successfully passed a rigorous series of requirements to become acknowledged by the CMMC Accreditation Body (Cyber AB), on behalf of the DoD, as being objective and competent to perform assessments of organizations seeking certification (OSCs).
C3PAOs are authorized by the Cyber AB to perform CMMC assessments — essentially an audit of an organization’s compliance with NIST 800-171 r2 — for companies within the DIB. If your organization deals with Controlled Unclassified Information (CUI) and intends to work with the Department of Defense (DoD), you will likely need CMMC certification to maintain or win new contracts.
CMMC Level 2 certification audits can only be conducted by a Certified Third-Party Assessor Organization (C3PAO).
CMMC Level 3 certification audits (for organizations with the highest priority, most critical defense programs) first require the OSC to be certified at CMMC Level 2 by an authorized C3PAO. Then, those organizations will face a CMMC Level 3 Conformity Assessment conducted by the government-led Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
Since less than 60 authorized C3PAOs are listed on CyberAB.org (the official marketplace for finding certified consultants and assessors), our team recommends beginning your CMMC program preparation and certification process as soon as possible.
With the expected rollout of CMMC 2.0 in 2025, C3PAOs are already swamped with work. Hence, we recommend being an early bird and booking an assessment appointment sooner rather than later to ensure that your organization has a slot for assessment before the deadlines hit.
Why Should You Prepare for The Audit Before Engaging a C3PAO?
CMMC Level 2 certification requires meeting every single one of the 110 NIST SP 800-171 controls and their 320 granular sub-controls called objectives. It is imperative that you perform an internal audit of your cybersecurity program to verify NIST 800-171 r2 compliance before your scheduled assessment. Furthermore, we recommend that you plan time after the internal audit to make any necessary security improvements and validate their implementation. If you do not meet each applicable CMMC control requirement and document a plan for implementing eligible controls that may remain outstanding, your organization will fail the audit.
If you’re still in the process of implementing controls leading up to your CMMC audit, you may add certain controls to a Plan of Action and Milestones (POA&M) list to be completed soon after an initial assessment. The “POAM,’ as it is commonly referenced among CMMC professionals, is a detailed plan that documents the steps an organization will take to remediate vulnerabilities and meet CMMC requirements.
Before considering using a POAM, organizations should consider several important factors.
- Organizations aiming to pass the audit can receive temporary approval and certification if they are actively working toward compliance with POAM controls.
- Only a minority of objectives are “POAM-able.” Check with your CMMC Registered Practitioner for more details.
- There is a 180-day grace period during which organizations can hold a temporary CMMC certification pending a follow-up audit.
- If an organization fails to pass the follow-up audit within 180 days, it will not receive the certification.
- Leveraging a POAM can increase the overall CMMC assessment process cost.
Regarding timelines and expectations, the CMMC audit process typically involves a team of auditors with specialized experience guided by a lead auditor. Audits can take about five days, depending on the scope. An audit may include remote and in-person assessments to verify compliance with various controls, such as network and physical security.
After successfully completing the audit, the organization will receive a certificate valid for three years. After receiving certification, organizations must perform annual self-assessments in years one and two. They must undergo a complete CMMC audit in year three.
How To Choose the Right C3PAO For Your CMMC Audit
It’s important to remember that availability, costs, and timelines can vary among assessors, so here are some tips for you to consider when selecting one:
- Find your C3PAO in CyberAB’s marketplace: This is the only official source from which you should find your provider. Some C3PAOs include, along with many more that can be found on the CyberAB marketplace.
- Get multiple quotes: C3PAOs are independent entities that set their own service rates. We suggest getting proposals from a few C3PAOs and choosing the one that better fits your timeline and budget.
- Ask for references: Ideally, request references from C3PAOs who have done joint audits with the DoD since they have already been participants in this process.
- Prepare for the future: Ensure that the C3PAO has the capacity to accommodate your future audits, particularly if you have a Plan of Actions and Milestones that requires ongoing assessments six months after the initial assessment. The last thing you want is to miss critical timelines due to a lack of assessor availability.
It’s also important to understand that C3PAOs are not consultants; their primary role is to conduct audits — they are not there to help you pass the audit. If you fail, you still must pay for their services. Therefore, working with an expert consultant or implementor such as EXTEND Resources is highly recommended to prepare for the audit.
An experienced team of CMMC registered practitioners can help you prepare for the audit by conducting a comprehensive gap analysis to confirm that every objective is met. They can also help identify which objectives fall under the POA&M process and develop a roadmap for compliance tailored to your organizational context.
The benefits of improving your CMMC program go beyond getting prepared for the audit:
- Support uninterrupted DoD contract renewals, maintaining vital revenue streams.
- Gain eligibility for future DoD contracts, positioning your business for growth.
- Enhance your cybersecurity posture, reducing your risk profile.
- Protect sensitive information, safeguarding national security and your reputation.
- Demonstrate a commitment to security, setting you apart from competitors.
To inquire about professional CMMC readiness services, contact EXTEND.
Have you read?
10 Steps Contractors Can Take to Conquer CMMC
CMMC Compliance: 8 Things DIB Companies Need To Know
CMMC Compliance: Be ready to achieve DoD cybersecurity certification
Documentation Requirements for CMMC Audits
One of the critical elements of a CMMC audit is the System Security Plan (SSP). This extensive document defines the scope of where CUI is controlled, stored, and protected and explains how the organization implements the controls. The SSP must detail the policies, procedures, and processes to safeguard CUI.
Developing and maintaining an SSP is time-consuming, so you should have it ready long before engaging with a C3PAO. Moreover, the assessors will also require documentation of the processes for any controls on the POA&M.
It’s important to note that assessors should not take custody of an SSP or any CUI. Organizations preparing for a CMMC assessment should plan to provide assessors with a secure way to access and view the SSP data so they may verify its existence and compliance. This requirement leads us to the next section, where we explore tools and technologies to support the CMMC assessment process.
Tools and Technologies to Facilitate CMMC Compliance
There are several tools and technologies available to help streamline the compliance process. For instance, information security program management tools such as OnTrack® can help create playbooks to achieve and maintain CMMC compliance by:
- Outlining tasks to be assigned to address gaps
- Mapping DoD controls
- Providing versioning capabilities
- Scheduling and calendaring
- Creating a companion guide on how to accomplish requirements
Technologies like PreVeil assist with email and file sharing and have built-in compliance features that address specific NIST 800-171 controls. Additionally, you can also choose government cloud services from AWS GovCloud and Azure for Government, which are configured with strict controls to facilitate compliance.
What If You Don’t Pass the CMMC Compliance Audit?
Failing to pass or delaying the CMMC audit process can have severe consequences for your organization, including:
- Losing existing DoD contracts
- Inability to renew current contracts
- Being ineligible for bidding on future contracts
- Incurring much higher costs due to repeat audits
To avoid these consequences and position your organization to achieve Cybersecurity Maturity Model Certification, seek outside support to prepare for and improve the odds of passing your audit. EXTEND’s team can help. Led by a team of experts, we offer tailored services that address the unique challenges that DoD contractors and subcontractors face and guide you through the certification process. Here’s how:
Scope Identification
Determine the scope of the CMMC assessment by identifying and assessing systems that handle, process, store, or transmit FCI or CUI.
CMMC Level Assessment
Define your required level based on data handling (Federal Contract Information (FCI) or CUI) and contract requirements.
Asset Identification
Identify CMMC-relevant assets and data flows.
Information Enclaves
Design CMMC-compliant repositories for DoD project data as needed.
NIST 800-171 Conversion
Leverage existing compliance to facilitate meeting CMMC objectives.
CMMC Compliance Platform Implementation
Streamline compliance efforts with an integrated platform.
MSP CMMC Evaluation
Validate that your IT services provider adheres to CMMC requirements.
CMMC Documentation and Preparation
Build your case to demonstrate compliance. Start from a rich library of policy templates.
C3PAO Assessor Selection and Assessment
Guide you through choosing an assessor and completing assessments.
Since CMMC 2.0 is expected to take full effect in Q1 2025 and assessment schedules are filling up, now is the time to start preparing. Take the first step towards securing your place in the defense industrial base and safeguarding our national security.
Contact EXTEND to discover how our CMMC readiness services can help your organization achieve and maintain compliance, no matter your CMMC-level requirements.