Question 2 - How should an organization prepare for a C3PAO assessment?

True readiness for a C3PAO assessment is demonstrated not by plans or partial implementations, but by the ability to withstand an assessment-like evaluation. Organizations that are prepared for certification have completed a formal readiness review and mock assessment that mirrors the structure and rigor of a C3PAO engagement. This includes validating assessment scope, confirming that controls are fully implemented and operating, and ensuring that documentation—particularly the System Security Plan (SSP)—accurately reflects the environment. A mock assessment allows organizations to identify gaps, inconsistencies, and misunderstandings before they become formal findings.

Equally important, readiness assessments test people and processes, not just technology. Through interviews, evidence reviews, and technical walkthroughs, organizations can evaluate whether subject matter experts, leadership, and system users can clearly explain how controls function in practice and how CUI is protected. Mock assessments frequently surface issues such as undocumented workarounds, unclear ownership, or misalignment between policy and operational reality—issues that are difficult to detect through self attestation alone.

Organizations that complete a mock assessment and remediate identified gaps enter the C3PAO assessment with confidence and stability. Scope is locked, evidence is organized, and personnel understand their roles in the assessment process. From an assessor’s perspective, this level of preparedness signals program maturity and significantly reduces assessment friction, delays, and the risk of unsuccessful certification on the first attempt.

Question 3 - What should be completed before the initial C3PAO intake and what if the university is not prepared?

At intake, the C3PAO is validating whether the institution is positioned to proceed with a formal assessment—not identifying gaps or providing guidance. Universities should be prepared to present a finalized assessment scope, including in-scope systems, research environments, and personnel, along with confirmation of the applicable CMMC level. Additionally, the university should demonstrate organizational readiness. This includes identifying assessment points of contact, confirming leadership sponsorship, and ensuring that key subject matter experts can participate in interviews and walkthroughs. If the C3PAO determines during intake or early assessment activities that the university is not prepared, the engagement typically cannot proceed as planned. The C3PAO may recommend postponing the assessment until readiness gaps are addressed, resulting in delays to certification timelines and additional cost. In some cases, if an assessment proceeds and significant deficiencies are identified, the outcome may be an unsuccessful assessment requiring remediation and reassessment. These additional remediation and reassessment activities come with increased cost and hours that are in addition to the agreed upon assessment fees.

Question 4 - What should the university expect during the assessment?

During a C3PAO assessment, universities should expect a structured, evidence-driven evaluation of both technical controls and organizational processes. The assessment is designed to verify that all in-scope systems, personnel, and practices meet the requirements of the applicable CMMC level. It is not a consultative review—the assessor will not provide remediation guidance—and outcomes are based solely on the evidence presented and the demonstration of operational controls. Key elements of the assessment typically include:

• Opening Briefing: An initial meeting with university leadership and key stakeholders to review scope, schedule, and logistics. This sets expectations for interviews, evidence review, and demonstrations.

• Documentation Review: Assessors will examine the System Security Plan (SSP), policies, procedures, network diagrams, asset inventories, and other supporting artifacts. Documentation must align with operational reality.

• Interviews: Faculty, researchers, IT staff, and leadership may be interviewed to confirm understanding of roles, responsibilities, and how CUI is protected. Assessors evaluate whether personnel follow documented procedures and can explain implemented controls.

• Technical Walkthroughs and Demonstrations: In-scope systems and controls will be demonstrated to show they operate as described. This may include access control mechanisms, encryption, logging, monitoring, incident response procedures, and other security practices.

• Observation and Evidence Validation: Assessors may request logs, reports, and other evidence to validate that controls are not only implemented but consistently operational.

• Closing Briefing: At the conclusion of the assessment, the assessor typically summarizes preliminary observations, clarifies evidence gaps, and outlines next steps, although formal findings are documented separately.

Question 5 - What if an objective is not met or disputed? 

A “Not Met” finding does not automatically result in a failed CMMC assessment; however, it affects the overall score and may be eligible for remediation through a Plan of Action and Milestones (POA&M), depending on the specific control. All POA&Ms must be completed and closed within 180 days of the Conditional CMMC Status Date. It is important to note that higher- weight controls, such as those assigned 3- or 5-point values, are not eligible for POA&M remediation and must be fully implemented to achieve certification.

When there is a disagreement with a finding, it is important to address the issue promptly to avoid delays in the assessment process. The best time to address minor disagreements with the assessment team is during daily checkpoints, where the university should be prepared to provide clear, immediate evidence to support its position. During the assessment, any disputed objective can be revisited by presenting supporting evidence and demonstrating how the practice satisfies the requirement. If the issue cannot be resolved through the C3PAO’s review process, the university has the option to submit a formal appeal to the CMMC Accreditation Body.

Question 6 - What happens after the C3PAO Assessment?

Following the completion of a C3PAO assessment, the assessor compiles the results and submits them into the CMMC-related instance of eMASS. Once submitted, the results are transmitted to the Supplier Performance Risk System (SPRS), which serves as the authoritative public reference for the organization’s CMMC status. Most organizations see their status reflected in SPRS within days to a couple of weeks after submission.

The CMMC status is recorded with a “CMMC Status Date,” which serves as the official starting point for certification. If any deficiencies are identified that are eligible for remediation through a Plan of Action and Milestones (POA&M), the university will receive a Conditional Level 2 certification, which initiates a 180-day remediation window. If all requirements are initially met— or once the POA&M is successfully closed within the 180-day period—the organization will be awarded a Final Level 2 certification.

After certification, the university must continue to demonstrate compliance and provide an annual affirmation of continued adherence to maintain its CMMC status. This ensures that controls remain operational, CUI is properly protected, and the institution remains eligible to participate in DoD contracts that require CMMC compliance.