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.
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