The term “C3PAO” is a key phrase for defense industrial base (DIB) contractors and subcontractors preparing to comply with the finalized Cybersecurity Maturity Model Certification (CMMC) Program.
Under the Department of Defense’s (DoD) final ruling, most DIB organizations that handle Controlled Unclassified Information (CUI) must obtain a CMMC Level 2 certification assessment.
The meaning of C3PAO is CMMC Third Party Assessment Organization. C3PAOs are authorized by The Cyber AB — the official CMMC accreditation body — to perform CMMC assessments on behalf of the DoD.
Ensuring CMMC success requires a whole community of security professionals. There are several different professional roles in the CMMC ecosystem in which C3PAOs play a vital part. It’s important to know what each of those roles can and can’t do to ensure you partner with the right people on your CMMC journey.
Key roles within the CMMC ecosystem include the following:
A Registered Practitioner Organization (RPO) is authorized by The Cyber AB to provide consulting services on CMMC implementation. Registered Practitioners (RPs) are the individuals who actually provide consulting as contractors or members of an RPO.
RPOs or RPs are not authorized to conduct official CMMC assessments. The goal of an RPO is to help organizations understand and prepare for a CMMC assessment.
Approved Training Providers (ATPs) are organizations approved by the Cybersecurity Assessor and Instructor Certification Organization (CAICO) — a subsidiary of The Cyber AB — to train and certify CMMC assessors. CMMC Certified Instructors (CCIs) are the individuals who are qualified to deliver this training as members of an ATP organization.
C3PAOs are authorized to perform official CMMC assessments. These organizations employ CMMC Certified Professionals (CCPs) and CMMC Certified Assessors (CCAs) to conduct the assessments.
CCPs and CCAs must complete training courses provided by an ATP and pass an exam, among other requirements, to be qualified to perform assessments. Also, individuals must be CCPs before they can pursue CCA training. While CCPs can participate in a Level 2 assessment, they cannot make any final decisions — that’s up to the CCA.
It’s important to note that assessors your organization consults on CMMC cannot provide an official assessment due to the DoD’s conflict of interest rules. So, if you wish to work with a particular C3PAO for an assessment, make sure you do not use them for consulting services. (C3PAOs can consult and many do. But if you consult with a C3PAO, that same C3PAO cannot assess your organization.)
Becoming a C3PAO is a rigorous process. Companies that wish to become C3PAOs must demonstrate to The Cyber AB that they are competent, objective, and committed to robust cybersecurity practices.
The process begins by applying to become a C3PAO through The Cyber AB website. Then, the organization must pass a multistep screening process. For example, each applicant must undergo a risk assessment and receive a particular score before moving forward.
Next, the organization must pass a Foreign Ownership, Control, or Influence analysis to prove a foreign entity does not influence it. A prospective C3PAO must then achieve CMMC Level 2 itself and meet documentation requirements, like providing proof of insurance.
You can learn more about becoming a C3PAO on The Cyber AB’s FAQ page.
A CMMC assessment usually can’t be done in a day. Depending on your organization’s needs, completing the certification process could take several weeks or months. Therefore, it’s crucial to choose an experienced, knowledgeable C3PAO that will streamline the process and save your company time and resources.
Take these steps to find a reputable C3PAO:
Consider the type of government information your organization handles and the level of security it requires. For example, if your organization handles highly sensitive CUI, look for a C3PAO authorized to access high-sensitivity data. Likewise, if your organization organization does business in the US Intelligence Community, consider C3PAOs who are familiar with Intelligence Community practices.
Evaluate your cybersecurity needs as well, considering your organization’s size, complexity, and business processes. You’ll want to choose a C3PAO with the experience and technical skills necessary to ensure a smooth, efficient assessment.
The Cyber AB Marketplace is an online directory that lists official C3PAOs. The Cyber AB posts C3PAOs on its marketplace once they become authorized. If you’re interested in a company claiming to be a C3PAO but cannot find them listed in The Cyber AB Marketplace, run the other way.
Did you find a great C3PAO on The Cyber AB Marketplace? Your work’s not over yet. Read reviews or ask for references to learn more about the C3PAO’s reputation and past experiences. Also, find out if they have experience in your particular industry or with the technology you use.
Ideally, you’ll want to select a C3PAO with a solid record of successful CMMC assessments and expertise with your industry and business systems for the best outcomes.
You will spend some time with your CMMC assessors, so it’s important to choose partners you enjoy working with. Your C3PAO should communicate complex requirements clearly, offer a tailored and flexible approach, and make you feel supported throughout the assessment process.
At Business Transformation Institute, Inc. (BTI), we understand the complexities and nuances of CMMC — including what it takes to be an effective, efficient C3PAO. We’ve offered CMMC services since the DoD developed the program and have written components of the model and its assessment methods.
Additionally, our team has real-world experience handling highly sensitive information and implementing CMMC, with extensive backgrounds in cybersecurity, systems engineering, and process improvement methodologies. As a company, we are authorized to handle the most sensitive classified information. You can have absolute confidence in our ability to provide CMMC insights and services.
Finding a reputable C3PAO is a necessary step in achieving CMMC Level 2 compliance. Save your organization the hassle of searching for a trustworthy, experienced C3PAO when you contact BTI.
We’re an official C3PAO authorized by The Cyber AB to conduct Level 2 CMMC assessments. Our team members are qualified to work at the highest levels of information sensitivity and support businesses that partner with U.S. Intelligence Community.
We also care about the success of your organization and helping you achieve your objectives. We’ll help you determine the assessment method that is the most effective and practical for your business and provide expert support throughout the process.
If you’re ready to schedule your CMMC assessment, contact us today.
