The CMMC ecosystem is filled with various acronyms and terms that many defense contractors may find confusing. However, understanding these concepts is crucial to effectively protecting CUI and maintaining compliance. One of the most fundamental aspects of the CMMC compliance process is the third-party audit conducted by a C3PAO. This blog will explain the importance of a C3PAO and what contractors need to know before choosing one to partner with.
What is a C3PAO?
A "Certified Third-Party Assessment Organization" or "C3PAO" is an organization that is approved by the Cyber-AB to conduct official CMMC audits on defense contractors. These assessment organizations, in contract with an organization seeking certification (OSC), are qualified to determine whether or not a contractor has implemented the necessary requirements for CMMC level 2. A C3PAO consists of several CMMC Certified Assessors (CCA's) that are approved and certified by the DoD after extensive training and examination.
It's important to note that C3PAO's do not act as both consultants and assessors. C3PAO's that consult and offers advice to contractors are not permitted to perform their audit as well. C3PAO's are intended to operate in an unbiased manner, determining with specificity whether or not the OSC has accomplished what is necessary to become CMMC compliant.
Why are C3PAO's Important?
C3PAO's are an integral part of protecting CUI and the U.S. warfighter. They are the only organizations authorized to conduct CMMC compliance assessments and are the determiners of whether or not an organization is allowed to compete for contracts.
Becoming a C3PAO
There are several requirements that must be met for an organization to achieve C3PAO status. These include:
- An organization must be 100% U.S. citizen owned or pass a Foreign Ownership Control or Influence (FOCI) background check.
- A potential C3PAO must achieve CMMC level 2 compliance and pass an audit conducted by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC).
- C3PAO's must have an ISO 17020 accreditation
- C3PAO's must undergo a risk assessment conducted by Dunn and Bradstreet (D&N) and past with an overall score of "moderate".
To learn more about the process of becoming a C3PAO, visit the Cyber AB website
Choosing the Right C3PAO
Similar to choosing any business partner, there are several key factors in choosing a C3PAO that you can trust with your compliance needs. Firstly, is the organization listed on the Cyber AB marketplace? If the answer is "no", then you should not move forward with that company. The Cyber AB is the official agency in charge of certifying C3PAO's. You should also be concerned with how long the C3PAO has been in business and what experience they have in conducting CMMC assessments. The CMMC rule is new, and many businesses may see it as an exciting new business venture. Make sure that you trust your C3PAO as they will be your partner throughout the entire process. Understand also that your C3PAO cannot provide consulting or remediation for your organization. It is against the rules for a C3PAO to do both the consulting and assessing of an OSC.
For consulting or remediation, many OSC's will seek the help of a certified MSP to prepare them for their audit.
Partnering with a Certified MSP
While a C3PAO cannot prepare your organization for the audit, a certified managed service provider (MSP) can help your organization achieve and maintain compliance pre and post audit. Under the CMMC final rule, MSPs (known as ESPs under CMMC documentation) are not required to be CMMC L2 compliant, however an MSP that has undergone the audit process brings with it a number of benefits.
Self-Assessed vs C3PAO Certified
Under the final CMMC rule, many MSPs will claim to be "self-certified". While this is permitted, utilizing a self-assessed MSP may incur more risk than necessary. For starters, an MSP that is self-certified is still within scope of the OSC's audit. This means that if your MSP fails to meet the stringent requirements of the CMMC model, the failure reflects on your organization. Additionally, if your MSP changes tools, this will trigger a reaudit, costing your important money and time. A C3PAO certified MSP has undergone the audit process and understand what it takes to become compliant. Additionally, a certified MSP has the ability to flown own their own pre-certified controls to the OSC. This saves time, money, and gives the OSC confidence in their ability to pass an audit.
CorpInfoTech, a C3PAO L2 Certified MSP
CorpInfoTech is an MSP that offers IT, cybersecurity, and CMMC compliance solutions to SMBs. We are among the first to achieve level 2 CMMC compliance via a third-party audit. Through TAS for CMMC Compliance, contractors will inherit 200+ of the 320 assessment objectives required by CMMC, ensuring that the compliance process is efficient and cost effective. CorpInfoTech also allows for flexible implementation and security of on-premises technology without restricting you to rigid enclave boundaries. CorpInfoTech not only reduces your compliance workload but also strengthens audit outcomes, reduces risks, and enhances long-term compliance efficiency—making it a strategic choice for any organization pursuing or maintaining CMMC Level 2 certification.
CorpInfoTech can assist your organization in identifying compliance gaps and resolving compliance issues.
To learn more about how TAS for CMMC Compliance can benefit your organization, contact us!
