CMMC 2.0 FAQs
From the Office of the Under Secretary of Defense for Acquisition & Sustainment
The Office of the Under Secretary of Defense for Acquisition & Sustainment has provided answers to several common questions. You can find these FAQs at https://www.acq.osd.mil/cmmc/i... The following are important answers
Q. Now that CMMC 2.0 is published, will companies be required to comply with CMMC 1.0?
A. The interim DFARS rule established a five-year phase-in period, during which CMMC compliance is only required in select pilot contracts, as approved by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD(A&S)). The Department does not intend to approve the inclusion of a CMMC requirement in any contract prior to completion of the CMMC 2.0 rulemaking process.
Once CMMC 2.0 is codified through rulemaking, the Department will require companies to adhere to the revised CMMC framework according to requirements set forth in the regulation.
Q. When will CMMC 2.0 be required for DoD contracts?
A. The publication of materials relating to CMMC 2.0 reflects the Department’s strategic intent with respect to the CMMC program; however, CMMC 2.0 will not be a contractual requirement until the Department completes rulemaking to implement the program. The rulemaking process and timelines can take 9-24 months. CMMC 2.0 will become a contract requirement once rulemaking is completed.
Q. How will my organization know what CMMC level is required for a contract?
A. Once CMMC 2.0 is implemented, DoD will specify the required CMMC level
Q. How frequently will assessments be required?
A. Once CMMC 2.0 is implemented, self-assessments, associated with Level 1 and a subset of Level 2 programs, will be required on an annual basis. Third-party and government-led assessments, associated with some Level 2 and all Level 3 programs, will be required on a triennial basis.
Q. Who will perform third-party CMMC assessments?
A. Once CMMC 2.0 is fully implemented, DoD will only accept CMMC assessments provided by an authorized and accredited C3PAO or certified CMMC Assessor, and C3PAOs shall use only certified CMMC assessors for the conduct of CMMC assessments.
Q. Will my organization need to be certified if it does not handle CUI?
A. DoD’s intent under CMMC 2.0 is that if a DIB company does not process, store, or transmit Controlled Unclassified Information (CUI) on its unclassified network, but does process, store or handle Federal Contract Information (FCI), then it must perform a CMMC Level 1 self-assessment and submit the results with an annual affirmation by a senior company official into SPRS.
Q. Will the results of my assessment be public? Will the DoD see my results?
A. Once CMMC 2.0 is fully implemented, the DoD will have access to information and data relating to a company’s assessment, including the assessment results and final report. The DoD will store all self-assessment results on SPRS. CMMC certificates and the associated third-party assessment data will be stored in the CMMC Enterprise Mission Assurance Support Services (eMASS) database. CMMC eMASS will automatically post a copy of a company’s CMMC certificate to the Supplier Performance Risk System (SPRS). The detailed results of a CMMC assessment will not be made public.
If a company voluntarily chooses to obtain a CMMC assessment and certification from a third-party assessment organization in the absence of a contractual requirement, the company must provide written consent to allow DoD access to or use of those assessment results. If a company consents to DoD access and use of data relating to the assessment, then DoD intends to store that information on eMASS.
Q. What is the difference between a CMMC self-assessment and a basic assessment required as part of the DoD Assessment Methodology?
A. A CMMC self-assessment will apply to those companies that are only required to protect the information systems on which FCI is processed, stored or transmitted; and a subset of companies that are required to protect CUI. The CMMC self-assessment should be completed using the CMMC Assessment Guide codified in 32 CFR for the appropriate CMMC level. A CMMC self-attestation is a representation that the offeror meets the requirements of the CMMC level required by the solicitation. The CMMC program will require an annual self-assessment and an annual affirmation by a senior company official.
A “Basic Assessment”, as defined in DFARS clause 252.204-7020, NIST SP 800-171 DoD Assessment Requirements, means a contractor’s self-assessment of the contractor’s implementation of NIST SP 800-171 that —
1. Is based on the Contractor’s review of their system security plan(s) associated with covered contractor information system(s);
2. Is conducted in accordance with the NIST SP 800-171 DoD Assessment Methodology; and
3. Results in a confidence level of “Low” in the resulting score, because it is a self-generated score.
The CMMC Final Rule has been published, and it will be effective on 12/16/2024.
Guernsey is the only Oklahoma based company to have achieved the Certified Third-Party Assessment Organization (C3PAO) status, which authorizes the firm to provide CMMC assessments, or “audits,” for clients seeking certification to meet their contractual obligations.
To schedule your company's C3PAO assessment, contact Timothy Fawcett, CISSP, Vice President Director of Cybersecurity Consulting, at Timothy.fawcett@guernsey.us or (405) 416-8182.