Your choice of a certified third-party assessor organization (C3PAO) could have a significant effect on the future of your business. That's why it’s critical that you do your due diligence in selecting a provider to conduct your Level 2 assessment for Cybersecurity Maturity Model Certification (CMMC) compliance.
Under CMMC 2.0 Final Rule, all prime and subcontractors within the Defense Industrial Base (DIB) must now satisfy stringent security controls and perform an assessment to prove they've implemented the necessary cybersecurity controls to protect federal contract information (FCI) and controlled unclassified information (CUI).
Most Level 2 businesses will need to get assessed by a C3PAO.
Passing your assessment is required to become certified. It also allows you to remain in good standing with the Department of Defense (DoD), enabling you to maintain your Department of Defense (DoD) contracts and bid on new ones.
That's why the process of evaluating and picking an auditor shouldn't be taken lightly.
In this article, we’ll outline the key factors you should consider when evaluating possible C3PAOs to hire for your CMMC assessment.
This will allow you to gain a more thorough understanding of important considerations when evaluating C3PAOs to help ensure you pick the best assessor that’s right for your business.
How The CMMC C3PAO Assessor You Choose Could Impact Your Business
In college, it’s well-known that students will often seek out professors with a reputation for being lenient to try to get an “easy A.”
The same could be said of organizations seeking assessment (OSA). While it may be tempting to try to find an “easy” C3PAO, that approach could end up doing more harm than good.
For instance, you may get an auditor who does a cursory review of your controls and rubberstamps your certification. But what happens if you’re then hit with a major data breach or ransomware attack due to a security gap in your infrastructure?
Related Article: CMMC Step 3: How Defect Implementation Support Can Fix Security Gaps
The reputational damage, financial loss, and even legal consequences to both you and the auditor could be staggering.
In addition, the risks of CMMC non-compliance are high.
You could get hit with substantial fines, as much as $10,000 per control for each of the 110 NIST 800-171 controls, for misrepresenting compliance under the federal False Claims Act (FCA).
The FCA also allows the government to recoup three times its damages, plus a penalty that’s linked to inflation—the total financial impact of which could skyrocket into the millions.
What’s more, a failed audit disqualifies you from bidding on or executing DoD contracts, which could result in a crippling financial blow to your business.
Given the potentially devastating consequences for non-compliance, it’s even more critical that you choose your CMMC auditor wisely.
7 Key Factors To Consider When Choosing a C3PAO
What is a C3PAO in CMMC?
All businesses seeking an official C3PAO designation must undergo a rigorous, multi-step approval process that includes proving their impartiality, integrity, and cybersecurity competencies through The Cyber AB accreditation.
The Cyber AB is the official governing body with C3PAO oversight to determine eligibility, authorization, and accreditation.
When it comes to choosing an assessor to perform your critical CMMC audit, there is currently a limited pool of approved C3PAOs from which to choose.
Related Article: How To Find An Approved C3PAO For Your CMMC Level 2 Assessment
Before picking an auditor, there are several considerations you should keep in mind.
1. Are they qualified?
Certified third-party assessor organizations must achieve CMMC Level 2 compliance themselves before they’re allowed to perform any CMMC Level 2 assessments.
Before signing on with a C3PAO, independently verify that the company has met the required Level 2 compliance requirements and that they’re on the official, government-sanctioned list of approved C3PAOs.
If not, you will essentially be throwing money out of the window and wasting valuable time working with a company that isn’t authorized to conduct your assessment.
What expertise does the assessor organization and the individual assessment team members possess?
Be sure you thoroughly research prospective C3PAOs and interview the team members who would be conducing your assessment.
You can gather some pertinent information during their intake/quote process in which they spell out their assessment process, deliverables, timelines, and costs.
2. Are their audits consistent?
Another important consideration, particularly if your business has multiple sites, is whether the C3PAO hires contractors to conduct the assessments or uses its own internal staff.
The use of short-term contractors could mean inconsistencies in your CMMC assessments.
This can become particularly problematic if, for instance, you have multiple locations and the C3PAO sends a different assessment team to each site.
Verify that the company has a uniform assessment and scoring process when evaluating your compliance controls, policies, and procedures for the parts of your business that handle CUI and FCI.
Related Article: CMMC Step 4: SSP Documentation–What’s Your CMMC Compliance Evidence?
This will allow you to more effectively prepare in becoming CMMC compliant so that you know what controls are acceptable. It will also help ensure consistency in your assessments across multiple sites.
Keep in mind that although The Cyber AB encourages uniformity in the assessment process, the reality is that it is subjective.
This is an important point to understand because it means that different C3PAOs will have different interpretations of the regulations and allowable remediations.
Such disparities in permissible compliance controls could ultimately determine whether you pass or fail your assessment. So, it’s essential that you get clarity on this issue from the start.
To minimize discrepancies, it makes sense to use the same C3PAO across all of your divisions, business units, and locations.
3. Do they have a proven track record?
Although CMMC 2.0 went into effect on December 16, 2024, some C3PAOs got a jump on the competition and have already started completing CMMC assessments. This means there is already a pool of assessors who have started performing CMMC audits.
At the same time, CMMC 2.0 builds upon existing security regulations and frameworks, such as Defense Federal Acquisition Supplement (DFARS) and NIST SP 800-171.
During your preliminary discussion with a prospective C3PAO, ask how long they’ve been approved as a C3PAO and whether they have experience performing other similar assessments, such as NIST 800-171 assessments.
4. Where are they located?
Consider where the C3PAO is located.
As the organization seeking assessment (OSA), you should determine not only where the C3PAO is based, but where its assessment team members are based.
This information is vital to your ability to effectively plan and budget for your assessment.
For instance, say you’re located in Connected but you pick a C3PAO that’s based in California because of their ability to perform the audit ahead of your certification deadline and within budget. This means you now have to factor in a day of travel time for the assessors to reach you.
You should also be aware that just because a company says it’s based in a certain location doesn’t mean that’s where their assessors are located. An assessor could be listed in Connecticut, but its team may be scattered across the country. Many C3PAOs operate entirely remotely.
That said, it may surprise you to learn that you may also be on the hook for the travel, lodging, and related expenses of the individual C3PAO assessors.
Since The Cyber AB generally requires a lead auditor and at least one or two other assessors per CMMC assessment (depending on the size of your business), your costs could grow exponentially.
5. Conflicts of interest
Both you and your chosen C3PAO are obligated to sign an official conflict of interest form. This document is designed to eliminate possible conflicts of interest in the CMMC assessment process.
For example, a C3PAO that handles all or part of your compliance readiness preparation can’t also conduct your CMMC assessment. That would include, for instance, working with a managed IT service provider (MSP) and a C3PAO that operate as separate entities but are actually related businesses.
Such conflicts of interests could lead to hefty fines or even the loss of your certification for both the OSC and the assessor organization.
6. Audit costs
Since every organization seeking assessment (OSA) is different, with different environments and infrastructures, it should come as no surprise that C3PAOs will not have a uniform pay structure.
There can be a huge difference between the most expensive and cheapest assessors. However, just as you shouldn't go for the “easiest” assessor, you should also avoid fixating on the lowest price.
At the same time, higher quotes don’t necessarily equate to better service, professionalism, or qualifications from your C3PAO.
That said, your total assessment costs can vary widely. Price variations may depend on variables such as included services, the size and complexity of your business and defined CUI boundary, along with add-on expenses such as travel and hotel accommodations.
Related Article: What Will The CMMC Certification Process Cost My Business?
7. Do you have multiple business units?
Does your company have multiple business units that handle FCI and CUI?
If so, are those units all housed within the same building or are they geographically spread out across the country?
This factor can significantly impact your total audit costs, as well as the length of time it takes to complete your assessment.
The Bottom Line With What To Consider When Choosing A CMMC C3PAO
After reading this article, you now have a full understanding of how your C3PAO selection could affect your budget, timeline, and compliance process to achieve CMMC certification.
Ultimately, the auditor you choose has to be able to meet your business needs while also fitting into your certification timeline and your budget.
It's important to keep in mind that the C3PAO you hire for your audit cannot also be the same company that prepares you to become compliant. That's where a managed IT service provider (MSP) can help.
Don’t leave your company’s fate to chance.
Reach out to us now if you need help figuring out your next steps in your compliance journey.
