Cyber AB CMMC-CCP - Certified CMMC Professional (CCP) Exam

The False Claims Act (31 U.S.C. §§ 3729–3733) imposes liability on companies that knowingly misrepresent compliance in order to receive or retain federal contracts. Penalties include treble damages (three times the government’s losses) plus additional penalties per claim.

Supporting Extracts from Official Content:

False Claims Act: “Any person who knowingly submits false claims to the Government is liable for three times the Government’s damages plus a penalty.”

DOJ Cyber-Fraud Initiative (2021): confirms the FCA is applied to cases of misrepresenting compliance with cybersecurity requirements.

Why Option D is Correct:

The applicable law is the False Claims Act, not a “Cyber Claims Act” (which does not exist).

The FCA specifies treble damages plus penalties, which exactly matches Option D.

References (Official CMMC v2.0 Governance and Source Documents):

False Claims Act (31 U.S.C. §§ 3729–3733).

DOJ Cyber-Fraud Initiative (2021), applied to CMMC-related compliance misrepresentation.

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Understanding the “Verify Evidence and Record Gaps” Activity in a CMMC Assessment

During aCMMC Level 2 Assessment, theAssessment Teamfollows a structured methodology toverify evidenceand determine whether theOrganization Seeking Certification (OSC)has met all required practices. One of the key activities in this process is " Verify Evidence and Record Gaps " , which ensures that the assessment findings accurately reflect any missing or inadequate compliance evidence.

Step-by-Step Breakdown:

✅1. Primary Intent: Identifying Gaps Between Required and Collected Evidence

TheAssessment Teamcompares the evidence provided by the OSC against theCMMC practice requirements.

If evidence ismissing, insufficient, or inconsistent, assessors mustdocument the gapand describe what is lacking.

This ensures that compliance deficiencies are clearly identified, allowing the OSC to understand what must be corrected.

✅2. How This Process Works in a CMMC Assessment

Assessorsreview collected documentation, system configurations, policies, and interview responses.

They verify that the evidencematches the expected implementationof a practice.

If gaps exist, they arerecordedfor discussion and potential remediation before assessment completion.

✅3. Why the Other Answer Choices Are Incorrect:

(A) Map test and demonstration responses to CMMC practices.❌

Incorrect:While mapping evidence to CMMC practices is part of the assessment, theprimary intentof the " Verify Evidence and Record Gaps " step is toidentify deficiencies, not just mapping responses.

(B) Conduct interviews to test process implementation knowledge.❌

Incorrect:Interviews are a method used during evidence collection, but they arenot the primary focusof the verification and gap analysis step.

(C) Determine the one-to-one relationship between a practice and an assessment object.❌

Incorrect:The assessment teamreviews multiple sources of evidencefor each practice, and some practices require multiple assessment objects. The goal isnot a strict one-to-one mappingbut rathera holistic validation of compliance.

Final Validation from CMMC Documentation:

TheCMMC Assessment Process Guidestates that " Verify Evidence and Record Gaps " is the step where assessorscompare expected evidence against what has been provided and document discrepancies. This ensurestransparent assessment findings and remediation planning.

Thus, the correct answer is:

D. Identify and describe differences between what the Assessment Team required and the evidence collected.

In CMMC scoping terminology, an HQ Organization is the entity legally responsible for contract performance and delivery of products or services.

Supporting Extracts from Official Content:

CMMC Scoping Guide: “HQ Organization is the legal entity responsible for the performance and delivery of contract requirements.”

Why Option D is Correct:

The HQ Org is legally accountable, while Host Units (option A/B) are subordinate entities.

Option C refers to shared services, not the HQ.

References (Official CMMC v2.0 Content):

CMMC Scoping Guide, High-Level Scoping Definitions.

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Step 1: Review CMMC 2.0 Reforms (Level 1 – Foundational)

As part ofCMMC 2.0, the DoD announced changes toreduce burden and costsfor companies that only handleFederal Contract Information (FCI):

DoD Statement (CMMC 2.0 Overview):

“Level 1 (Foundational) will only require an annual self-assessment, affirming implementation of the 17 FAR 52.204-21 controls.”

✅Step 2: Intent of “Reduced Assessment Costs”

The move to allowself-assessments at Level 1was explicitly designed toeliminate the costof hiring third-party assessors for organizations that only handle FCI.

Level 1 self-assessments are:

Conductedinternally by the OSC,

Affirmed annuallyby a senior company official,

Submitted via SPRS(Supplier Performance Risk System).

❌Why the Other Options Are Incorrect

B. Opt out of CMMC Assessments

✘Incorrect. Organizations must still perform aself-assessmentannually — they cannot opt out entirely.

C. Have assessment costs reimbursed by the DoD

✘No such reimbursement mechanism exists.

D. Pay no more than $500.00…

✘No such fixed cost is set or guaranteed in CMMC documentation.

UnderCMMC 2.0, all companies atLevel 1 (Foundational)are permitted toconduct self-assessmentsannually to demonstrate compliance, supporting the DoD’s goal ofreducing assessment costsfor low-risk contractors.

1. Understanding the Role of Assessment Objectives in CMMC 2.0

Theassessment objectivesfor each CMMC practice define thespecific criteriathat an assessor uses to evaluate whether a practice is implemented correctly. These objectives break down each control into measurable components, ensuring a structured and consistent assessment process.

To determine where these objectives are best documented, we need to consider theofficial CMMC documentation sources.

2. Why Answer Choice " D " is Correct – CMMC Assessment Guide Levels 1 and 2

TheCMMC Assessment Guide (Levels 1 & 2)is theprimary documentthat provides:

✅The detailedassessment objectivesfor each practice

✅A breakdown of the expectedevidence and implementation details

✅Step-by-stepassessment criteriafor assessors to verify compliance

Each CMMC practice in the Assessment Guide is aligned with the correspondingNIST SP 800-171 or FAR 52.204-21 control, and the guide specifies:

How to assess compliancewith each practice

What evidenceis required for validation

What stepsan assessor should follow

📌 Reference from Official CMMC Documentation:

CMMC Assessment Guide – Level 2 (Aligned with NIST SP 800-171)explicitly states:

" Each practice is assessed based on defined assessment objectives to determine if the practice is MET or NOT MET. "

CMMC Assessment Guide – Level 1 (Aligned with FAR 52.204-21)provides similar objectives tailored for foundational cybersecurity requirements.

Thus,CMMC Assessment Guide Levels 1 & 2 are the BEST sources for assessment objectives.

3. Why Other Answer Choices Are Incorrect

Option

Reason for Elimination

A. CMMC Glossary

❌The glossary only defines terminology used in CMMC but does not provide assessment objectives.

B. CMMC Appendices

❌The appendices contain supplementary details, but they do not comprehensively list assessment objectives for each practice.

C. CMMC Assessment Process (CAP)

❌While the CAP document describes the assessmentworkflow and methodology, it does not outline the specific objectives for each practice.

4. Conclusion

To locate thebest reference for assessment objectives, theCMMC Assessment Guide Levels 1 & 2are the most authoritative and detailed sources. They contain step-by-step assessment criteria, ensuring that practices are evaluated correctly.

✅Final Answer:

D. CMMC Assessment Guide Levels 1 and 2

Understanding the Phases of the CMMC Assessment Process

TheCMMC Assessment Process (CAP)consists of multiple phases, with each phase focusing on a different aspect of the assessment.Developing the assessment planoccurs inPhase 1, which is thePre-Assessment Phase.

Key Activities in Phase 1 – Pre-Assessment Phase

Engagement Agreement: TheOSC (Organization Seeking Certification)and theCertified Third-Party Assessment Organization (C3PAO)formalize the assessment contract.

Developing the Assessment Plan: TheLead Assessorand the assessment team create anAssessment Plan, which outlines:

Scope of the assessment

CMMC Level requirements

Assessment methodology

Timeline and logistics

Initial Data Collection: Review of system documentation, policies, and relevant security controls.

Why is the Correct Answer " Phase 1 " (A)?

A. Phase 1 → Correct

Phase 1 is where the assessment plan is developed.

It ensuresclarity on scope, methodology, and logistics before the assessment begins.

B. Phase 2 → Incorrect

Phase 2 is theAssessment Conduct Phase, where assessorsexecutethe plan by examining evidence and interviewing personnel.

C. Phase 3 → Incorrect

Phase 3 is thePost-Assessment Phase, which involvesfinalizing findings and submitting reports, not developing the plan.

D. Phase (Incomplete Answer) → Incorrect

The question requires a specific phase, and the correct one isPhase 1.

CMMC 2.0 References Supporting this Answer:

CMMC Assessment Process (CAP) Document

DefinesPhase 1as the stage where the assessment plan is developed.

CMMC Accreditation Body (CMMC-AB) Guidelines

Specifies thatplanning and pre-assessment activities occur in Phase 1.

CMMC 2.0 Certification Workflow

Outlines the assessment planning process as part of theinitial engagementbetween theC3PAO and the OSC.

Understanding SI.L1-3.14.2: Provide Protection from Malicious Code

The CMMC Level 1 practiceSI.L1-3.14.2is based onNIST SP 800-171 Requirement 3.14.2, which requires organizations to:

Implement malicious code protection(e.g., antivirus, endpoint security software).

Ensure coverage across all appropriate locations(e.g., workstations, servers, network entry points).

Keep protection mechanisms updated(e.g., regular signature updates, policy enforcement).

Assessment Criteria for a " MET " Rating:

To determine whether the practice isMET, the Lead Assessor must confirm that:

✔Antivirus or endpoint protection software is installedon all workstations and servers.

✔The solution is centrally managed, ensuring consistent policy enforcement.

✔Signature updates are current, meaning systems are protected against new threats.

✔Logs or reports demonstrate active monitoring and updates.

Why is the Correct Answer " A. It is sufficient, and the audit finding can be rated as MET " ?

The provided evidenceconfirms all necessary requirementsfor SI.L1-3.14.2:

✔All workstations and servers have antivirus installed→Meets installation requirement.

✔A centralized management console is in place→Ensures consistent enforcement.

✔Records show antivirus signatures are up to date→Confirms system protection is current.

Because the evidencemeets the requirement, the practice should berated as MET.

Why Are the Other Answers Incorrect?

B. It is insufficient, and the audit finding can be rated NOT MET → Incorrect

The evidence providedmeets all necessary requirements, so the practiceshould not be rated as NOT MET.

C. It is sufficient, and the Lead Assessor should seek more evidence → Incorrect

Ifadequate evidence already exists,additional evidence is unnecessary.

D. It is insufficient, and the Lead Assessor should seek more evidence → Incorrect

The evidence providedmeets the control requirements, making itsufficient.

CMMC 2.0 References Supporting This Answer:

CMMC Assessment Process (CAP) Document

Specifies that a practice can be marked asMET if sufficient evidence is provided.

NIST SP 800-171 (Requirement 3.14.2)

Defines the standard formalicious code protection, which ismet by antivirus with active updates.

CMMC 2.0 Level 1 (Foundational) Requirements

Clarifies that basic cybersecurity measures likeantivirus installation and updatesmeet compliance forSI.L1-3.14.2.

Final Answer:

✔A. It is sufficient, and the audit finding can be rated as MET.

Understanding CMMC Asset Categorization

TheCMMC 2.0 Scoping Guidedefines how assets are categorized based on their involvement withFederal Contract Information (FCI)andControlled Unclassified Information (CUI).

In this scenario:

Thegovernment services divisioninteracts withfederal clientsandreceives FCI, making its assetsin-scopefor CMMC Level 1.

Thecommercial services divisioninteractsonly with non-federal clientsanddoes not handle FCI—this means its assets arenot subject to CMMC Level 1 requirementsand should be classified asOut-of-Scope Assets.

CMMC 2.0 Definition of Out-of-Scope Assets

As per theCMMC Scoping Guide, assets that:

✅Do not store, process, or transmit FCI/CUI

✅Do not directly impact the security of in-scope assets

✅Are completely segregated from the FCI/CUI environment

are classified asOut-of-Scope Assets.

Since thecommercial services divisiononly processespublicly available information and has no interaction with FCI, its assets areout-of-scopefor CMMC Level 1 assessment.

Why the Other Answers Are Incorrect

A. FCI Assets

❌Incorrect. FCI assets areonly those that store, process, or transmit FCI. The commercial services division doesnothandle FCI, so its assets donotqualify.

B. Specialized Assets

❌Incorrect. Specialized assets refer toInternet of Things (IoT), Operational Technology (OT), and test equipment. These donot applyto a general commercial services division.

D. Operational Technology Assets

❌Incorrect.Operational Technology (OT) Assetsinvolveindustrial control systems, SCADA, and manufacturing equipment—which are not relevant to this scenario.

CMMC Official References

CMMC 2.0 Scoping Guide – Level 1 & Level 2

CMMC Assessment Process (CAP) Document

Thus,option C (Out-of-Scope Assets) is the correct answerbased on official CMMC scoping guidance.

Who is Responsible for Marking CUI?

According toDoDI 5200.48 (Controlled Unclassified Information (CUI)), the responsibility for marking CUI falls on theauthorized holder of the information.

Step-by-Step Breakdown:

Definition of an Authorized Holder

PerDoDI 5200.48, Section 3.4, anauthorized holderis anyone who has beengranted accessto CUI and is responsible for handling, safeguarding, and marking it according toDoD CUI policy.

The authorized holder may be:

ADoD employee

Acontractorhandling CUI

Anyorganization or individual authorizedto access and manage CUI

DoD Guidance on CUI Marking Responsibilities

DoDI 5200.48, Section 4.2:

The individual creating or handling CUImust apply the appropriate markings as per the DoD CUI Registry guidelines.

DoDI 5200.48, Section 5.2:

Themarking responsibility is NOT limited to a specific positionlike an Information Disclosure Official or a high-level DoD office.

Instead, it is theresponsibility of the person or entity generating, handling, or disseminatingthe CUI.

Why the Other Answer Choices Are Incorrect:

(A) DoD OUSD (Office of the Under Secretary of Defense):

The OUSD plays apolicy-setting rolebut doesnot directly mark CUI.

(C) Information Disclosure Official:

This role is responsible forpublic release of information, but marking CUI is the duty of theauthorized holdermanaging the data.

(D) Presidential authorized Original Classification Authority (OCA):

OCAs classifynational security information (Confidential, Secret, Top Secret), not CUI, which isnot classified information.

Final Validation from DoDI 5200.48:

PerDoDI 5200.48, authorized holders are explicitly responsible for marking CUI, making this the correct answer.

Anorganization seeking helpto address security gaps—such asphysical access control deficiencies—needs acertified professional who can provide implementation supportwithoutbeing involved in the actual CMMC assessment.

Role of a Registered Practitioner (RP)

A Registered Practitioner (RP)is a CMMC-certified individualwho provides consulting and implementation supportto organizations butdoes not perform assessments.

RPs work independently from C3PAOsand canassist in fixing gapsin security controlsbeforeorafteran assessment.

Since RPs are not assessors, they can provide direct remediation supportwithout any conflict of interest.

Why " B. RP of an Organization Not Part of the Assessment " is Correct?

The OSC needs assistance in implementing security controls(not assessment).

An RP is trained and authorized to provide remediation and advisory services.

Conflict of interest rules prevent the assessing C3PAO from providing implementation support.

Why Other Answers Are Incorrect?

A. CCA of the C3PAO performing the assessment (Incorrect)

ACertified CMMC Assessor (CCA)is responsible for conducting the assessmentonly.

TheC3PAO performing the assessment cannot also provide remediationdue to aconflict of interest.

C. Practitioner of the Organization Performing the Assessment LTP (Incorrect)

The assessmentLead Technical Practitioner (LTP)cannot provide remediation support for an OSC they are assessing.

D. DoD Contract Official of the Organization Performing the Assessment (Incorrect)

DoD Contract Officialsoversee contract compliance butdo not provide cybersecurity implementation support.

Conclusion

The correct answer isB. RP of an organization not part of the assessment, asonly independent RPs can assist with remediation and implementation support.