With CMMC's finalization, managed service providers (MSPs) will play an important role in defense contractors' ability to achieve and maintain compliance. At Level 2 of the CMMC framework, organizations are required to adhere to additional requirements outlined in NIST SP 800-171 Rev.2 in order to better protect the nations controlled unclassified information (CUI). For many small-medium sized businesses working in the Defense Industrial Base (DIB), these requirements can be expensive and complex. MSPs help reduce the burden of compliance by offering their expertise, services, and resources on a contract basis. Under the most recent ruling, MSPs are no longer required to be certified by a C3PAO at the same level of their client. However, there is a large difference between hiring an MSP that is only self-assessed as opposed to one that has been externally verified. Not all MSPs are equal in their ability to achieve CMMC Level 2 compliance and the difference between a self-assessment and those certified by a third-party assessor organization is significant.
The Self-Assessed MSP
Under the final CMMC rule, organization can achieve either CMMC Level 2 (self) or CMMC Level 2 (C3PAO). While many contractors will have to consult a C3PAO to achieve compliance, as long as an MSP does not have access to CUI, they can pursue compliance through a self-assessment. An MSP that has performed a CMMC Level 2 self-assessment has evaluated their compliance against the 110 practices outlined in NIST SP 800-171. There are several key characteristics of a self-assessed MSP:
- An Internal Evaluation: The MSP has independently reviewed its own policies and procedures and found it is aligned with CMMC Level 2 requirements.
- Self-Attestation: The MSP will have to sign an attestation that they meet the necessary standards. If found to be outside of compliance, the MSP can face heavy penalties.
- Greater Risks: Without external validation, the assessment may overlook certain gaps or misinterpret various requirements.
A C3PAO Certified MSP
A CMMC Third-Party Assessor Organization (C3PAO) is responsible for conducting an audit of the MSPs compliance against CMMC Level 2 standards. This is an independent audit conducted by a professional, with a certification provided by the Department of Defense (DoD). Several key characteristics of a C3PAO-Certified MSP include:
- External Validation: A C3PAO provides an objective, third-party validation of the MSPs compliance. Conversely, the self-assessed MSP relies on its own internal evaluation.
- Pre-Certified Controls: MSPs will provide a customer responsibility matrix (CRM) that outlines the responsibilities of both parties in regard to compliance. Any objectives that the MSP is responsible for are already "pre-certified" and are not scrutinized during your audit.
- Risk Management: The thoroughness of a third-party audit reduces the likelihood of security gaps and ensures robust protections for CUI.
Which Should You Choose?
While both MSPs may show a commitment to cybersecurity and compliance, the better option for defense contractors is to partner with a C3PAO-Certified MSP. A CMMC Level 2 (C3PAO) Certified MSP offers a higher level of confidence and assurance that a self-assessed MSP does not. Contractors must also keep in mind that a self-assessed MSP will still be considered in scope for your third-party audit, meaning that your organization is being held responsible for the compliance of your MSP. Organizations handling CUI or seeking DoD contracts should prioritize MSPs that have undergone the C3PAO certification process. By doing so, they not only enhance their compliance posture but also reinforce trust in their supply chain’s cybersecurity resilience.
CorpInfoTech - Committed to CMMC Level 2 C3PAO Compliance
CorpInfoTech is an MSP dedicated to providing enterprise level cybersecurity and CMMC compliance services to SMBs working in the DIB. We are committed to achieving CMMC Level 2 C3PAO compliance and are likely among the first to do so.
Through TAS for CMMC Compliance, your organization will inherit 200+ of the 320 objectives required by CMMC. This helps increase compliance efficiency and give you greater assurance when it comes to your own third-party audit. Our services are flexible and give you greater control over where your CUI is stored, letting you avoid rigid enclave boundaries.
TAS for CMMC Compliance is the fastest, least expensive, and most flexible way to achieve CMMC compliance!
Contact us today Start Your CMMC Compliance pathway today - CorpInfoTech can help your business achieve and maintain your CMMC Compliance for the long haul.
