The Role of Third-Party Assessors in CMMC Audits

In the evolving cybersecurity landscape, the Cybersecurity Maturity Model Certification (CMMC) has emerged as a pivotal framework for organizations engaged in defense contracting. Any organization that is a part of the Defense Industrial Base and falls in the level 2 category with critical data will need a third-party assessment (similar to the traditional audit function). Third-party assessment only applies to prioritized acquisitions (sensitive) data involving Controlled Unclassified Information (CUI) as per CMMC level 2 criteria. An annual self-assessment is mandated for CMMC compliance for non-critical CUI data, while critical CUI data necessitates a third-party assessment every three years. In this blog post, we will delve into the details of third-party assessors and their crucial role in CMMC audits.

What are Third-party Assessors?

The Cybersecurity Maturity Model Certification Accreditation Body (Cyber-AB) defines third-party assessors as independent entities authorized to evaluate an organization’s adherence to the various cybersecurity practices and processes outlined in the CMMC framework. At the heart of this framework is the role of third-party assessors, officially known as CMMC Third Party Assessment Organizations (C3PAOs). These independent entities are authorized by the Cybersecurity Maturity Model Certification Accreditation Body (Cyber-AB) to evaluate an organization’s adherence to the cybersecurity practices and processes outlined in the CMMC framework. However, not all levels of CMMC certification require a C3PAO assessment. For instance, self-assessment may be sufficient at the lower levels of the CMMC (e.g., Level 1). However, for higher levels that involve handling CUI, a formal third-party assessment by a C3PAO is mandatory. This ensures that contractors handling sensitive information undergo a more stringent evaluation process. In this blog, we’ll explore the critical role of CMMC Third Party Assessment Organizations (C3PAOs) in conducting formal assessments that ensure compliance with the rigorous cybersecurity standards set forth by the CMMC framework.

1. Formal Assessment and Documentation:

Central to the role of CMMC assessors is conducting a formal assessment, a meticulous process where a C3PAO thoroughly evaluates an organization’s cybersecurity practices against specific CMMC criteria. The Key steps in this process include:

Systematic Evaluation: Assessors methodically review the organization’s cybersecurity protocols, ensuring they align with the designated CMMC-level requirements.
Evidence Collection: They gather evidence of compliance, such as security policies, incident response plans, employee training records, etc., for compliance review.
Document Findings: Assessors meticulously document their findings throughout the assessment, noting compliance and improvement areas.
Final Report Compilation: The documented evidence and evaluations culminate in a comprehensive assessment report, an official record of the organization’s CMMC compliance status.
SPRS Submission: Following the assessment, the organization must submit its Cybersecurity Maturity Model Certification (CMMC) compliance information to the Supplier Performance Risk System (SPRS). This step is crucial as it allows the Department of Defense (DoD) to access and review the company’s compliance status and cybersecurity readiness.

This structured approach ensures a thorough and transparent assessment, essential for validating the organization’s cybersecurity maturity per CMMC standards.

2. Reporting and Documentation:

After the CMMC practice/control assessment, assessors provide a comprehensive report that shows the compliance status and offers insights and recommendations for improvement. Throughout the assessment, the C3PAO meticulously documents their findings. This documentation includes details on areas where the contractor complies with the CMMC standards and identifies areas that need improvement.

3. SPRS Score Grading and Update:

In the CMMC assessment process, a crucial component is the grading and updating of the Supplier Performance Risk System (SPRS) score. This score, ranging from -203 to 110, represents a contractor’s compliance with the 110 controls in the CMMC standard, where higher scores indicate better compliance. The SPRS score entered into the DoD SPRS application is a major factor in the DoD’s evaluation of a supplier’s cybersecurity posture. As part of the assessment, the C3PAO may assist in evaluating or verifying the contractor’s SPRS score. This score is crucial as it reflects the contractor’s cybersecurity posture and compliance with CMMC standards.

4. Certification Facilitation:

If the organization meets the CMMC requirements, third-party assessors are pivotal in facilitating the certification process, which is essential for securing DoD contracts. The C3PAO’s assessment process consists of four steps:

Pre-assessment: The C3PAO reviews the contractor’s documentation and assesses its cybersecurity posture.
Assessment Planning Meeting: The C3PAO discusses the assessment with the contractor and plans the on-site assessment.
On-site Assessment: The C3PAO evaluates the contractor’s cybersecurity practices and procedures.
Post-assessment Review: The C3PAO reviews the assessment findings with the contractor.

5. Choosing a Competent Third-Party Assessor:

Selecting the right third-party assessor is critical for organizations. Factors to consider include:

Accreditation Status: Verifying the assessor’s accreditation with the CMMC Accreditation Body (CMMC-AB) is essential.
Industry Experience: Assessors with experience in the organization’s specific industry can provide more tailored and insightful assessments.
Track Record and Client Testimonials: Assessors with a proven track record and positive client feedback are more likely to provide reliable and effective services.

The role of third-party assessors in CMMC audits is more than a regulatory requirement; it’s a strategic approach to enhance cybersecurity defenses in the national defense supply chain. Their expertise and guidance are vital for organizations seeking to comply with CMMC standards and secure DoD contracts. As cyber threats evolve, these assessors become increasingly integral to ensuring that organizations are compliant and secure in an ever-changing cyber landscape.

As a Cyber-AB Registered Practitioner Organization (RPO), iQuasar Cyber boasts extensive knowledge of CMMC, NIST 800-171 regulations, FedRAMP, NYDFS, HIPAA, PCI, and more. We specialize in helping organizations like yours prepare for CMMC compliance, providing recommendations for both self-assessments and external evaluations. Additionally, our close relationships with Certified Third Party Assessment Organizations (C3PAOs) position us uniquely to facilitate a smoother, more informed path toward compliance.