CMMC NUGGET #17

Finding the Right Fit

Understanding the Role of a C3PAO
A C3PAO is an organization authorized by the CMMC Accreditation Body (CMMC-AB) to conduct formal assessments of organizations seeking certification. The C3PAO will evaluate your cybersecurity practices and processes against the specific CMMC level requirements, ultimately determining whether your organization meets the necessary criteria.

Do you need a C3PAO?

• Are you currently or do you anticipate that you will be handling controlled unclassified information (CUI)?
• Do you have or anticipate having FAR or DFARS flow downs requiring your company have a third-party compliance assessment?
• Are you ready for an assessment or are looking for consulting services? Consider one of the CMMC Ecosystem’s other roles to support with consulting. While a C3PAO can provide both consulting and assessment services, they can’t provide both to the same OSC.

Are they guaranteeing certification?

• If the C3PAO you are engaged with or have been communicating with is telling you about an all-in-one solution, be wary. While solutions exist that can support your environment’s policy and procedure documentation, there is no one size fits all solution for a guaranteed certification.
• Until CFR 32 and DFARS 48 are final, no C3PAO (or any other assessment organization) can provide you with a CMMC Level 2 Certification. If a C3PAO is telling you they can provide you with a certification before that happens, it may be time to re-evaluate your C3PAO.

Their knowledge of the CMMC Assessment Process (CAP):

• What is the C3PAO’s level of understanding of the CAP?
• Seeking knowledge, either beforehand or during engagement with a C3PAO, can help you gauge the understanding of the C3PAO.
• Inquire if the C3PAO offers any pre-assessment guidance, GAP analysis or readiness reviews.
• Understand the C3PAO’s approach to conducting the assessment, including the use of tools, checklists, and processes.

Credentialed by the Cyber-AB:

• Are they really an Authorized C3PAO?
• Before selecting a C3PAO, verify that the C3PAO is listed as an active and authorized entity on the CMMC Marketplace. This listing is updated regularly in an effort to maintain a running list of authorized C3PAO’s recognized by the Cyber-AB.

Assess Experience and Expertise:

• Research any available information on the C3PAO’s past assessments, client feedback, and past performance.
• Request a summary of their past accreditation work as evidence of competence.
• Experience matters when it comes to conducting assessments. A C3PAO with a track record of assessments in your industry or for similar organizations is likely to deliver a smoother process.
• Evaluate the C3PAO’s understanding of the technical aspects of the CMMC model, particularly in areas relevant to your organization.
• Ask about the qualifications and experience of the assessors who will be conducting your assessment.

Consider Availability and Scheduling:

• CMMC assessments can be time-sensitive, especially if your contracts or bids depend on certification. Ensure that the C3PAO’s availability aligns with your timeline.
• Confirm the C3PAO’s availability and willingness to work within your required timeframe.
• With the limited number of authorized C3PAOs, assessors, and additional assessment personnel, aligning a C3PAO’s availability with project timelines can pose challenges. Ensure to engage early and often.

Compatibility and Cultural Fit:

• It is important to find a C3PAO that aligns with your organization’s culture, values, and goals. A lack of compatibility and cultural fit can hinder effective communication, collaboration, and understanding during the assessment process.
• Trust is a crucial element in any business relationship. Consider the C3PAO’s reputation, track record, and references from previous clients. Look for indicators of professionalism, integrity, and a commitment to delivering high-quality assessments.
• Assess whether the C3PAO’s values and culture align with those of your organization. Consider factors such as their approach to teamwork, communication, and problem-solving. A compatible organizational culture can foster a positive working relationship and enhance collaboration.

Understand the Cost Structure:

• C3PAO assessments can be a significant investment. Understanding the cost structure upfront will help you budget appropriately and avoid surprises.
• Request a detailed breakdown of costs, including any potential additional fees.
• Consider whether the C3PAO’s services and expertise justify their pricing.

Selecting the right C3PAO is a crucial step in your CMMC journey. By carefully evaluating their credentials, experience, communication practices, and pricing, you can ensure a smooth and successful assessment process. By picking a C3PAO that fits your needs, you’ll be a step closer to achieving CMMC certification.