The Role of C3PAOs and MSPs in CMMC Compliance
Achieving Cybersecurity Maturity Model Certification (CMMC) is essential for organizations in the Defense Industrial Base (DIB), yet diving into certification without adequate preparation can lead to costly setbacks. Many organizations rush to hire a CMMC Third-Party Assessor Organization (C3PAO) prematurely, often bypassing essential preparatory steps. This post highlights how leveraging a qualified Managed Service Provider (MSP) with Registered Practitioner (RP) status, like CyberSheath, can help organizations prepare for certification with compliance-driven IT and security services.
CMMC roles and responsibilities: Qualified MSP/RPs and C3PAOs
To understand the CMMC compliance process, it’s essential to recognize the distinct roles of MSPs, RPs, and C3PAOs:
- Qualified MSPs with Registered Practitioner (RP) status: Not every RP is equipped to support CMMC compliance with an operational approach, but those that are also MSPs bring a unique advantage. MSPs like CyberSheath, with strong CMMC experience and RP credentials, offer not only advisory support but also the practical, day-to-day compliance services that meet CMMC standards. Unlike RPs who may only advise, an MSP that also functions as a Registered Practitioner operates in alignment with CMMC requirements through compliance-driven IT and security services—supporting clients’ CMMC compliance goals by maintaining continuous operational alignment.
- C3PAOs: CMMC Third-Party Assessor Organizations (C3PAOs) are authorized by the Cyber Accreditation Body (Cyber-AB) to conduct official CMMC certification audits. C3PAOs must maintain strict separation of duties to ensure an objective audit—they cannot provide advisory or compliance services as this would compromise the independence required for certification. C3PAOs are limited to performing formal CMMC assessments and mock assessments, helping organizations understand what a real audit entails without impacting the certified environment.
Common pitfalls in CMMC compliance preparation
Rushing into the certification process without sufficient preparation can lead to costly missteps. Here are some common mistakes to avoid:
1. Engaging a C3PAO prematurely
Hiring a C3PAO before your organization is fully prepared can lead to failed assessments and unnecessary expenses. Organizations sometimes assume they’re ready simply because they’ve implemented certain cybersecurity controls. However, without thorough preparation and understanding of CMMC requirements, critical compliance gaps are often overlooked. This is why many organizations find that working with a qualified MSP/RP like CyberSheath is beneficial, as it allows them to address compliance needs with operational IT and security services before undergoing the formal assessment.
2. Skipping the gap assessment
A gap assessment is a foundational step for effective CMMC preparation. While it’s possible to conduct a self-assessment, qualified MSPs with RP status, such as CyberSheath, provide gap assessments that evaluate an organization’s practices against CMMC requirements, identifying critical areas for improvement. MSPs that serve as RPs not only perform assessments but support day-to-day compliance operations, distinguishing themselves from RPs who only advise. This operational involvement enables MSPs to support clients in maintaining the specific security standards necessary for certification.
3. Underestimating the importance of compliance-focused operational services
Organizations sometimes overlook the value of compliance-focused operational services in preparing for CMMC certification. A qualified MSP/RP like CyberSheath offers more than advisory support—it provides ongoing compliance IT and security services that are fundamental to daily operations and directly aligned with CMMC requirements. This goes beyond checklist guidance, as MSP/RPs are responsible for helping DIB clients maintain a compliant environment in their routine operations, embedding compliance into every aspect of IT and security.
4. Blurring the boundaries between compliance services and certification
Ensuring separation between compliance services and certification is crucial for an unbiased audit. Leveraging a qualified MSP/RP for compliance support ensures readiness without compromising the objectivity of the C3PAO certification process. Once prepared, engaging an independent C3PAO for the official audit not only meets Cyber-AB’s requirements but also ensures a fair, unbiased certification process.
Preparing for a successful CMMC audit
To prepare effectively for CMMC certification, follow these steps:
- Start with a gap assessment by a qualified MSP/RP: Begin with a comprehensive gap assessment to identify areas of noncompliance. Working with an MSP/RP provides additional insight into how operational compliance can be embedded into daily activities, minimizing the risk of unexpected issues during the formal audit.
- Implement compliance-focused operational services: Compliance services offered by an MSP/RP go beyond basic advisory—they encompass IT and security operations that meet CMMC standards day-to-day. This ensures the organization’s environment is consistently aligned with CMMC requirements, making them better prepared for certification.
- Begin C3PAO assessment: Due to timing and a backlog of available assessors, it is recommended to contract with a C3PAO early in the audit process. Then, once implementation and remediation are complete, organizations will be ready to begin the certification audit. Remember, CMMC certification is a three-year cycle, and you’ll need to reassess if any significant changes impact your certified environment.
Rushing into CMMC certification without sufficient preparation can lead to costly delays. By leveraging the operational compliance services of a qualified MSP/RP like CyberSheath, organizations can ensure their environment meets CMMC requirements before engaging a C3PAO for the formal audit. This strategic approach optimizes resources and maximizes the chances of a successful CMMC certification, establishing a compliant foundation for the three-year certification cycle ahead.
