Pass the Cyber AB CMMC CMMC-CCP Questions and answers with CertsForce

According to the CMMC Model and Assessment Guides, specifically the rules governing Plan of Action and Milestones (POA & M) and the remediation period, an Organization Seeking Certification (OSC) is allowed a limited opportunity to remediate certain "Not Met" practices to achieve a "Met" status without failing the assessment entirely.

Here is the breakdown based on CMMC Ecosystem protocols:

The 180-Day POA & M Rule: CMMC Level 2 allows for the use of POA & Ms for specific practices, provided they are not high-priority items (typically 5-point values in the scoring methodology). If an OSC has "Not Met" practices that are eligible for a POA & M, they have up to 180 days to remediate them.

The Remediation Period (Assessment Closeout): During the assessment process itself, there is a "remediation period" (often referred to within the 1-90 day window depending on the specific C3PAO methodology and the CMMC assessment process) where an OSC can fix minor issues identified by the assessor before the final report is submitted.

Eligibility Criteria: The question states there are 15 practices "Not Met." While this is a high number, the CMMC rule does not automatically disqualify an OSC based solely on thequantityof practices, but rather thetype(weight) of the practices and the resulting score. To be eligible for a conditional "Met" (via POA & M), the OSC must achieve a minimum score (often 80% of the total points) and none of the "Not Met" practices can be those designated as mandatory "Met" (no POA & M allowed) in the CMMC rule.

Why "C" is correct: Because we do not know the specific weights of the 15 "Not Met" practices or the total score, we cannot definitively say theywillbe remediated (A) or that they areineligible(B). However, under the CMMC assessment framework, the OSC may be eligible to enter a remediation phase or utilize a POA & M to bridge the gap, provided they meet the scoring threshold and the specific practices allow for it.

Reference Documents:

CMMC Assessment Process (CAP): Defines the phases of assessment including the "Remediation Period."

32 CFR Part 170 (CMMC Program Rule): Outlines the specific requirements for POA & Ms, the 180-day timeline, and the scoring parameters required to be eligible for a Conditional Certification.

DFARS clause 252.204-7012 establishes the safeguarding of Covered Defense Information (CDI), which aligns with CUI categories. The clause specifies that the DoD is responsible for determining whether information is Controlled Unclassified Information (CUI) and marking it accordingly before sharing it with contractors. Contractors do not make determinations about what constitutes CUI; they are responsible for safeguarding information once it is received and marked as CUI.

Reference Documents:

DFARS 252.204-7012,Safeguarding Covered Defense Information and Cyber Incident Reporting

CMMC Model v2.0 Overview, December 2021

Who Determines the Assessment Method for Each Practice?

In aCMMC Level 2 Assessment, theLead Assessorhas thefinal authorityin determining theassessment methodused to evaluate each practice.

Key Responsibilities of the Lead Assessor

✅Ensures theCMMC Assessment Process (CAP) Guideis followed.

✅Determines whether a practice is evaluated usinginterviews, demonstrations, or document reviews.

✅Directs theCertified CMMC Professionals (CCPs)and other assessors on themethodologyfor gathering evidence.

✅Works under aCertified Third-Party Assessment Organization (C3PAO)to ensure proper assessment execution.

Why "Lead Assessor" is Correct?

CCP (Option A) assists in the assessment but does not make final decisionson methods.

OSC (Option B) is the Organization Seeking Certification, and they do not control assessment methodology.

Site Manager (Option C) may coordinate logistics but has no authority over assessment decisions.

Breakdown of Answer Choices

Option

Description

Correct?

A. CCP

❌Incorrect–A CCPassistsbut doesnot determine assessment methods.

B. OSC

❌Incorrect–The OSC is beingassessedand does not decide assessment methods.

C. Site Manager

❌Incorrect–The Site Manager handles logistics butdoes not control assessment methods.

D. Lead Assessor

✅Correct – The Lead Assessor has the final say on the assessment method used.

Official References from CMMC 2.0 Documentation

CMMC Assessment Process Guide (CAP)– Defines theLead Assessor’s rolein determining assessment methods.

Final Verification and Conclusion

The correct answer isD. Lead Assessor, as they havefinal decision-making authority over the assessment methodology.

Who Should Be Interviewed During a CMMC Assessment?

During assessment planning, theOrganization Seeking Certification (OSC)may suggest personnel for interviews. However, the person interviewedmustbe someone who:

✅Implementsthe practice (directly responsible for executing it).

✅Performsthe practice (carries out day-to-day security operations).

✅Supportsthe practice (provides necessary resources or oversight).

Why "Implements, Performs, or Supports That Practice" is Correct?

Theassessor needs direct insightsfrom individuals actively involved in the practice.

Funding (Option A)does not providetechnical or operationalinsight into practice execution.

Auditing (Option B)focuses on compliance checks, but auditorsdo not implementthe practice.

Supporting, auditing, and performing (Option C)includesauditors, who arenot necessarily the right interviewees.

Breakdown of Answer Choices

Option

Description

Correct?

A. Funds that practice.

❌Incorrect–Funding is important but doesnot mean direct involvement.

B. Audits that practice.

❌Incorrect–Auditors check compliance but donot implementpractices.

C. Supports, audits, and performs that practice.

❌Incorrect–Auditing isnot a requirementfor interviewees.

D. Implements, performs, or supports that practice.

✅Correct – The interviewee must have direct involvement in execution.

Official References from CMMC 2.0 Documentation

CMMC Assessment Process Guide (CAP)– Requires that interviewees bedirectly responsiblefor implementing, performing, or supporting the practice.

Final Verification and Conclusion

The correct answer isD. Implements, performs, or supports that practice, as the interviewee mustactively contribute to the execution of the practice.

Understanding the False Claims Act (FCA) and Whistleblower Protections

TheFalse Claims Act (FCA)(31 U.S.C. §§ 3729–3733) is aU.S. federal lawthat allowswhistleblowers (also known as "relators")to sue on behalf of the federal government if they believe a company issubmitting fraudulent claimsfor government funds.

The FCA includes a"qui tam" provision, which:

✅Allows private individuals to file lawsuits on behalf of the U.S. government.

✅Provides financial rewards to whistleblowersif the lawsuit results in recovered funds.

✅Protects whistleblowers from employer retaliation.

In the context ofCMMC and cybersecurity compliance, theFCA has been used to hold companies accountableformisrepresenting their cybersecurity compliancewhen working with federal contracts.

For example:

If a companyfalsely claimscompliance withCMMC, NIST SP 800-171, or DFARS 252.204-7012butfails to meet security requirements, it could beliable under the FCA.

TheDepartment of Justice (DOJ)has pursued cases under theCyber-Fraud Initiative, using theFCA against defense contractorsfor cybersecurity noncompliance.

Thus, the correct answer isC. False Claims Actbecause it specifically allows whistleblowers tosue on behalf of the federal government.

Why the Other Answers Are Incorrect

A. NIST SP 800-53

❌Incorrect.NIST SP 800-53provides security controls for federal agencies butdoes notcontain whistleblower provisions.

B. NIST SP 800-171

❌Incorrect.NIST SP 800-171outlines security requirements for protectingCUI, but itdoes not have legal mechanismsfor whistleblower lawsuits.

D. Code of Professional Conduct

❌Incorrect. TheCMMC Code of Professional Conductapplies toC3PAOs and assessorsbut doesnot provide a legal basis for whistleblower lawsuits.

CMMC Official References

False Claims Act (31 U.S.C. §§ 3729–3733)– Establishes whistleblower protections and qui tam lawsuits.

DOJ Cyber-Fraud Initiative– Uses the FCA to enforce cybersecurity compliance in government contracts.

DFARS 252.204-7012 & CMMC– Require accurate reporting of cybersecurity compliance, which can lead to FCA violations if misrepresented.

Thus,option C (False Claims Act) is the correct answeras per official legal guidance.

Federal Contract Information (FCI) is defined in FAR 52.204-21 as information provided by or generated for the government under contract but not intended for public release. Under CMMC 2.0, organizations handling FCI must implement FAR 52.204-21 Basic Safeguarding Requirements, ensuring proper protection in processing, storing, and transmitting FCI.

Analyzing the Given Options

The question involves an email system that is used to send FCI to a subcontractor. Let’s break down the possible answers:

A. Manage FCI → Incorrect

Managing FCI involves activities like organizing, storing, and maintaining access to FCI. Sending an email does not fall under management; it is an act of transmission.

B. Process FCI → Incorrect

Processing refers to actively using FCI for operational or analytical purposes, such as analyzing, modifying, or computing data. Simply sending an email does not constitute processing.

C. Transmit FCI → Correct

Transmission refers to the act of sending FCI from one entity to another. Since the contractor is sending FCI via email, this falls under transmitting the data.

TheCMMC Assessment Guideis the best source for determining the sources of evidence for a given practice because it provides specific guidance on how organizations should implement and demonstrate compliance with CMMC practices. Each CMMC level has its own assessment guide (e.g.,CMMC Assessment Guide – Level 1, Level 2), detailing expected evidence and assessment procedures.

Detailed Justification:

CMMC Assessment Guide (Primary Source for Evidence)

TheCMMC Assessment Guideexplicitly outlines the evidence required to verify compliance with each practice.

It provides detailed instructions on assessment objectives, clarifying what assessors should look for when determining compliance.

The guide breaks down each practice intoassessment objectives, helping organizations prepare appropriate documentation and artifacts.

Other Documents and Why They Are Not the Best Choice:

NIST SP 800-53 (Option A)

WhileNIST SP 800-53provides a comprehensive catalog of security and privacy controls, it does not focus on CMMC-specific evidence requirements.

It serves as a foundational cybersecurity framework but does not define the specific artifacts required for CMMC assessment.

NIST SP 800-53A (Option B)

NIST SP 800-53Aprovides guidance on assessing security controls but is not tailored to the CMMC framework.

It includes general control assessment procedures, but theCMMC Assessment Guideis more precise in defining the evidence needed for CMMC compliance.

CMMC Assessment Scope (Option C)

TheCMMC Assessment Scopedocument outlines which systems, assets, and processes are subject to assessment.

While important for defining boundaries, it does not provide details on specific evidence requirements for each practice.

References from Official CMMC Documents:

CMMC Assessment Guide (Level 2) – Section on "Assessment Objectives"

This document details how evidence is collected and evaluated for each CMMC practice.

Example: ForAC.L2-3.1.1 (Access Control – Limit System Access), the guide specifies that assessors should verify documented policies, system configurations, and audit logs.

CMMC Model Overview (Official DoD Documents)

Emphasizes thatCMMC Assessment Guidesare the official reference for determining sources of evidence.

Conclusion:

TheCMMC Assessment Guideis the most authoritative source for determining the required evidence for a given practice in CMMC assessments. It provides detailed breakdowns of assessment objectives, required artifacts, and verification steps necessary for compliance.

According to the CMMC Assessment Process (CAP), the Lead Assessor must use the CMMC Findings Brief to formally present assessment results to the Organization Seeking Certification (OSC). The Findings Brief ensures consistency across assessments and provides the OSC with an official, standardized presentation of results, including observed strengths, weaknesses, and any non-conformities.

Other options are incorrect because:

POA & M Brief is not part of the official CAP presentation.

CMMC Assessment Tracker Tool is an internal tool used by assessors, not for presentation to the OSC.

Recommended Findings template is not a recognized deliverable in CAP.

Reference Documents:

CMMC Assessment Process (CAP), v1.0

Step 1: Define Roles – CCP and CCA

CCP (Certified CMMC Professional):

Entry-level certification in the CMMC ecosystem.

Supports assessment activities under the supervision of a CCA.

May assist in consulting roles outside of formal assessments.

CCA (Certified CMMC Assessor):

Certified tolead assessmentsunder the CMMC model.

Requiredfor conductingLevel 2 formal assessments.

Can be part of a C3PAO assessment team or lead it.

Source: CMMC Assessment Process (CAP) v1.0, Section 2.3 – Assessment Team Composition

“Level 2 assessments must be led by a Certified CMMC Assessor (CCA), who may be supported by one or more CCPs.”

✅Step 2: Citizenship Requirements

CAP v1.0 – Appendix B: Team Composition and Clearance Requirements

“All team members performing Level 2 assessments must be U.S. citizens when handling CUI, regardless of role.”

But forsupporting team members who do not handle CUIor inFCI-only scoping, there is no automatic exclusion based on citizenship.

So:

TheCCA leadsthe team.

CCPs can be team membersregardless of citizenship,unless restricted by contract or CUI handling needs.

❌Why the Other Options Are Incorrect

A. The CCP leads the Level 2 Assessment Team…

✘Incorrect. CCPscannot leadLevel 2 assessments.

B. The CCA leads… includes 3 CCP with US Citizenship.

✘Incorrect. Citizenship is requiredonly when handling CUI, not a universal requirement.

D. The CCP leads…

✘Again, CCPs donot have the authority to leadformal CMMC assessments.

Only aCertified CMMC Assessor (CCA)may lead aLevel 2 Assessment Team, and theymay include CCPs, evennon-U.S. citizens, if citizenship is not a requirement based on contractual or data sensitivity scope.

Understanding the Role of NIST SP 800-171 in CMMC

NIST Special Publication (SP)800-171is the definitive standard for protectingControlled Unclassified Information (CUI)innonfederal systems and organizations. It provides security requirements that organizations handling CUImust implementto protect sensitive government information.

This document isthe foundationofCMMC 2.0 Level 2compliance, which aligns directly withNIST SP 800-171 Rev. 2requirements.

Breakdown of Answer Choices

NIST SP

Title

Relevance to CMMC

NIST SP 800-37

Risk Management Framework (RMF)

Focuses on risk assessment for federal agencies, not directly applicable to CUI in nonfederal systems.

NIST SP 800-53

Security and Privacy Controls for Federal Systems

Provides security controls forfederalinformation systems, not specifically tailored tononfederalorganizations handling CUI.

NIST SP 800-88

Guidelines for Media Sanitization

Covers secure data destruction and disposal, not overall CUI protection.

NIST SP 800-171

Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations

✅Correct Answer – Directly addresses CUI protection in contractor systems.

Key Requirements from NIST SP 800-171

The document outlines110 security controlsgrouped into14 families, including:

Access Control (AC)– Restrict access to authorized users.

Audit and Accountability (AU)– Maintain system logs and monitor activity.

Incident Response (IR)– Establish an incident response plan.

System and Communications Protection (SC)– Encrypt CUI in transit and at rest.

These controls serve as thebaseline requirementsfor organizations seekingCMMC Level 2 certificationto work withCUI.

Official Reference from CMMC 2.0 Documentation

CMMC 2.0 Level 2alignsdirectlywith NIST SP800-171 Rev. 2.

DoD contractors that handle CUImustcomply withall 110 controlsfrom NIST SP800-171.

Final Verification and Conclusion

The correct answer isD. NIST SP 800-171, as this documentexplicitly definesthe cybersecurity requirements for protectingCUI in nonfederal systems and organizations.