First, this blog is not about rushing you to select a C3PAO because the sky is falling. This is, however, a blog about choosing the right C3PAO so you don’t feel as if the sky is about to fall on you.
Selecting the correct C3PAO for your CMMC assessment should be as critical as selecting the right sitter for your kids or pets or choosing the right partner for your ERP migration. Choosing the wrong C3PAO can lead to many issues, including dealing with unnecessary paperwork, potentially more than once, and a subpar assessment.
What’s the Big Deal?
The right C3PAO will ensure a thorough and accurate evaluation, streamlining the process, minimizing risks, and ensuring compliance. Don’t underestimate the importance of this decision. Most organizations are required to get proposals from 3-5 C3PAOs, so survey your options with care. Take the time to research and select a C3PAO that aligns with your business needs and objectives. Your organization’s sanity depends on it.
How to Find the Right C3PAO
When searching for a C3PAO, the first thing you want to do is make sure you are ready to engage with them. Ready means having evidence that the security requirements have been implemented, having an approved System Security Plan (SSP), an approved Shared Responsibility Matrix (SRM), and other artifacts listed in the CMMC Assessment Process (CAP).
Ready also means you have precise requirements for what you expect from this engagement, including timeline for the formal assessment and assigning a point person to interact with the C3PAOs. Without a clear understanding of what is required and what you need from them, you’ll likely fall into traps set by sales tactics and fancy presentations.
When it Comes to a C3PAO, What’s Important to You?
This list of priorities should include years of experience in cybersecurity assessments, following NIST standards. Your requirements should go beyond traditional third-party assessment organizations that have been assessing other frameworks. While having a C3PAO experienced in other frameworks is good, it is important to differentiate that experience assessing ISO programs does not equal to experience assessing CMMC programs.
For this reason, you want a Lead Assessor who understands the nuances of the NIST standards. A C3PAO company could be in business for 20+ years, but if the Lead Assessor and assessment team members are new to this business, there can be risks associated with misinterpreted requirements. Look into the Lead Role, not just the C3PAO.
Additionally, does the C3PAO have experience working within your organization’s industry? How quickly would they be able to grasp how your business operates? This is important because you want an assessor who can capture your business model relatively easily, aiding in both effectiveness and efficiency. If you are a defense manufacturer, you want at least the Lead Assessor to have experience in manufacturing.
This experience will benefit the assessment team in that you will not have to explain every minor detail about your asset categories, the flow of your CUI, and the system boundaries. While the assessor will validate these things, you expect them to know what they are, ensuring the assessment is about how you protect your critical processes, avoiding the feeling of a “field day” adventure.
Do you require an on-site assessment for some or most of the controls? If so, your CMMC assessment team should ideally be in your region. If the C3PAO doesn’t have a presence in your region(s) of operations, then you’re looking at additional costs and potential risks with ad hoc contractors. Have a documented requirement for the location of the assessment team and validate that the C3PAO will have someone on-site who’s local or who can help keep costs low, without compromising skills and experience.
Keep Your Budget in Mind
If you are ready for the C3PAO, then you will likely have a budget in mind. If you don’t, then work with your team or consultant to get insight into these costs months ahead. Your budget needs to account for the complexity of your CUI program, which includes the number of locations involved and business units, the number of system security plans (SSPs), the location of your assets, including your CUI assets and security protection assets (i.e. on-premise, in the cloud, or at a colocation).
In addition to your operations, the body of evidence (BoE) can help reduce cost by clearly organizing your complex environment into a succinct package, tracing your SSP to Policies and Procedures, capturing the essence of your CUI/CMMC Program. Avoid going for the lowest bidder, and adhere to your requirements. Don’t compromise the quality of your assessment to save a few dollars.
Biggest Takeaways
The CMMC assessment process is very detailed, involving several steps to ensure your organization has the sufficient and adequate evidence to validate it is meeting the intent of the government security requirements. Having the right C3PAO to guide you through this process is a necessity, ensuring your organization has clarity, throughout the process, leading to a CMMC Certification.
