In the context of the Cybersecurity Maturity Model Certification (CMMC) 2.0, the remediation review process is a critical phase where identified deficiencies from an initial assessment are addressed. The Lead Assessor, representing a Certified Third-Party Assessment Organization (C3PAO), plays a pivotal role in this process.
Role of the Lead Assessor in Remediation Reviews:
Validation of Remediation Efforts:
Objective:Ensure that the Organization Seeking Certification (OSC) has effectively addressed and corrected all deficiencies identified during the initial assessment.
Process:The Lead Assessor reviews the evidence provided by the OSC to confirm that each previously unmet practice now meets the required standards. This involves examining updated policies, procedures, system configurations, and other relevant artifacts.
Delta Assessment Remediation Package Submission:
Definition:A delta assessment focuses on evaluating only the components or practices that were previously found non-compliant or deficient.
Responsibility:After validating the remediation efforts, the Lead Assessor compiles a remediation package that includes:
Detailed documentation of the deficiencies identified in the initial assessment.
Evidence of the corrective actions taken by the OSC.
Findings from the reassessment of the remediated practices.
Internal Quality Review:This remediation package is then submitted for the C3PAO's internal quality review process. The purpose of this review is to ensure the accuracy, completeness, and consistency of the assessment findings before finalizing the certification decision.
Rationale for Selecting Answer C:
Alignment with CMMC Assessment Process:The submission of a delta assessment remediation package for internal quality review is a standard procedure outlined in the CMMC Assessment Process. This step ensures that all remediated items are thoroughly evaluated and validated, maintaining the integrity of the certification process.
Clarification of Incorrect Options:
Option A:"Help OSC to complete planned remediation activities."
Explanation:The Lead Assessor's role is to assess and validate the OSC's compliance, not to assist in the implementation or completion of remediation activities. Providing such assistance could lead to a conflict of interest and compromise the objectivity of the assessment.
Option B:"Plan two consecutive remediation reviews for an OSC."
Explanation:The standard process involves conducting a single remediation review after the OSC has addressed the identified deficiencies. Planning multiple consecutive remediation reviews is not a typical practice and could indicate a lack of proper remediation planning by the OSC.
Option D:"Validate that practices previously listed on the POA&M have been removed on an updated Risk Assessment."
Explanation:While it's essential to ensure that deficiencies are addressed, the primary focus of the Lead Assessor during a remediation review is to validate the implementation of remediated practices. Updating the Risk Assessment is the responsibility of the OSC's internal risk management team, not the Lead Assessor.
[References:, CMMC Assessment Process v2.0, CyberAB, CMMC Assessment Guide – Level 2, Defense Innovation Unit, These documents provide detailed guidelines on the roles and responsibilities of assessors, the remediation review process, and the procedures for submitting assessment findings for quality review within the CMMC framework., , ]
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