What DoD Suppliers Need to Know About CMMC 3PAOs (C3PAOs)

Cybersecurity remains a priority in cloud-based systems, where vulnerabilities are more significant than traditional on-premise infrastructures. Service providers such as DoD contractors maintain heavy responsibilities in ensuring top security of their cloud-based services due to their access and ability to send and store Controlled Unclassified Information (CUI). 

As such, the government continually keeps a watchful eye on security standards through national cybersecurity policies. The process of ensuring data is sufficiently protected involves FedRAMP (Federal Risk and Authorization Management Program), a federal program that provides consistent security evaluations for commercial cloud-based organizations collaborating with the government.

CMMC (Cybersecurity Maturity Model Certification) is the latest governmental policy which unifies DoD cybersecurity standards. The maturity model involves routine audits conducted by certified third-party assessment organizations (3PAOs) to evaluate and regulate DoD contractors’ standards.

Understanding FedRAMP 3PAOs for CMMC

FedRAMP 3PAOS are private companies specialized in performing regulated audits and quality checks to ensure that CSPs (cloud service providers) contracted to the government adhere to the latest cybersecurity guidelines.

While previous DFARS regulations enabled DoD contractors to self-certify their compliance, the process proved inadequate in safeguarding confidential cloud data. The newly implemented CMMC accreditation strategy ensures that experienced and vetted organizations, 3PAOs, conduct standardized procedures for optimized security outcomes.

Getting Certified by 3PAOs

CMMC 3PAOs, or C3PAOs, are organizations that provide systematic audits depending on the needs of a contractor. C3PAOs can fulfill two roles: that of an assessor, that of an advisor, or both. CSPs may discuss and negotiate the best strategies with C3PAOs to determine the best steps for authorization. 

Advisory offerings may include:

  • Baseline Audits: A preliminary assessment of current cloud security systems that identifies the changes required according to FEDRamp guidelines. 
  • Corrective Action Period: A time frame concession provided to CSPs so they may make necessary amendments before an actual audit process. 

In the capacity of assessors, C3PAOs provide a complete audit that involves a series of processes, which include:

  • Security Assessment Plan (SAP): The comprehensive security assessment of a CSP’s cloud service offering covers a broad range of security controls such as encryption and access control.
  • Security Assessment Reports (SAR): FedRAMP 3PAOS will collate assessment findings in a detailed report with other supporting documents required in the authorization.
  • Follow-up Assessments: 3PAOs will also perform future assessments to ensure that certified CSPs remain compliant with CMMC guidelines.

Qualifications of C3PAOs

CMMC 3PAOs undergo a series of training in technical training and familiarization with international cybersecurity standards before qualifying for the role.

To be certified to perform audits, an organization must be accredited by CMMC-AB. The prerequisite program includes reviews on the organization’s competence in ISO/ISE17020/2012 standards (conformity assessment for various inspection bodies) and other technical program requirements. Accredited FedRAMP C3PAOs receive routine audits to keep them updated and effective in their roles.

Because of these stringent criteria, DoD contractors and other CSPs can have trust and assurance in the quality of C3PAO assessments.

How DoD Suppliers Can Prepare

There are not currently any organizations certified as C3PAOs, as CMMC is still being rolled out and the assessment process is only beginning. According to Tim Brennan of SysArc, a Managed Security Service Provider that helps DoD contractors prepare for CMMC, “This doesn’t mean that DoD suppliers can hesitate, however, because the DFARS regulation is still in play.” The DFARS regulation requires all government contractors to have implemented NIST 800-171 if they are holding contracts with the Department of Defense.