Optimizing CMMC Compliance: 5 Key Steps to Help Your C3PAO Assessor
Cooperation and collaboration with your CMMC Third-Party Assessment Organization (C3PAO) are of paramount importance when seeking compliance with the pending Department of Defense’s Cybersecurity Maturity Model Certification (CMMC). Achieving CMMC certification is a critical prerequisite for DoD contractors aiming to secure government contracts that may include handling of Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). Your C3PAO validates the organization’s cybersecurity practices you have in place to safeguard sensitive government information. In this context, your first and most important step is to define the boundaries for this information.
Remember: this is not an assessment of your entire environment; it is an assessment of how you handle data shared by the government. The more you can do to reduce and define that footprint, the easier your assessment will go. It is also essential to work closely with your C3PAO and actively support their efforts by collecting and organizing the requested artifacts the best that you can. By doing so, you not only streamline the assessment process but also strengthen your organization’s commitment to cybersecurity, increasing your likelihood of attaining CMMC certification. Let’s explore the five best ways to assist and collaborate with your CMMC assessor during the certification process.
1. Establish Effective Communication Channels:
- Scheduled Meetings: Once the assessment process has begun, regularly scheduled meetings with your CMMC assessment team are crucial. These meetings create a platform for both parties to discuss the assessment’s process, understand requirements, and address any concerns that may arise during the evaluation process.
- Open and Transparent Communication: Ensure that communication is open and transparent. The assessment team will ask as many questions as they can to understand the policies, processes, and other controls you have in place. Their role is to understand everything that they can about your security environment without asking leading questions or advising you. During the assessment process, if you feel that the presented evidence does not adequately describe your control environment, but you are made aware of additional evidence that may be included, volunteer that information during the interview process.
2. Provide Access to Documentation:
- Accessibility of Documentation: It’s imperative to grant your CMMC assessor easy access to your organization’s cybersecurity-related documentation. This includes policies, procedures, incident response plans, and any other materials relevant to your cybersecurity infrastructure.
- Organization and Clarity: Make sure that your documentation is well-organized and clearly labeled. This will save time for the assessor and help them perform a more thorough evaluation. The assessment team will ask you for a ‘traceability matrix’ which is a description of how the evidence maps to each specific control. This saves time and money if the traceability matrix is prepared in advance. Don’t be the company that brings your evidence in a virtual shoebox for the assessors to sift through! It not only costs more time and money but also leaves too much room for potential misinterpretation and miscommunication. The best thing you can do in preparation is to make sure that your evidence is comprehensive and organized in such a way that it tells an honest, compelling story about your control environment.
3. Prepare for Onsite Visits:
- Unrestricted Access: If your CMMC assessment involves onsite visits, ensure that the assessor has unrestricted access to your facilities and IT systems. Remove any obstacles that might hinder the assessment process and/or delay the onsite visit.
- Provide Access Resources: In addition to physical access, make sure that there is a secure, effective means for sharing any necessary access credentials, security codes, and any other resources the assessor might need to conduct a comprehensive assessment.
4. Assist in Identifying Key Personnel:
- Facilitate Interviews: Your CMMC assessor will need to interview key personnel within your organization, such as your IT and security teams, HR, process managers, program managers, etc. It’s your responsibility to work with the C3PAO to identify these resources early, make sure they are available for the assessment process, introduce them, and ensure that the interviews are conducted smoothly.
- Gather Insights: Collaborate with the assessor in gathering insights from these interviews. This step is crucial for the assessor to gain a deeper understanding of your organization’s cybersecurity practices. If you think there is more to the control environment than what the assessor seems to understand, volunteer additional information.
5. Understand Next Steps:
- Not Met Findings: During the assessment, your CMMC assessor may identify areas of non-compliance by indicating that the control is not met. Work closely with the assessor to understand why the control is not met so that you can consider steps to remediate.
- Develop a Remediation Plan: Once not met controls are identified, create a remediation plan. This plan should outline the steps needed to address these issues, making the path to compliance more manageable and efficient.
Preparation will allow you to be better equipped to support your CMMC assessor effectively, ensuring a smoother and more productive assessment process. This collaborative approach demonstrates your commitment to cybersecurity and increases your chances of achieving CMMC certification.
A seamless CMMC assessment process can fast-track your journey to achieving CMMC compliance. Contact us today and learn more about how Coalfire Federal can help you achieve CMMC success.