During an assessment, the OSC person being interviewed explains the process for escorting visitors. The individual states that while all visitors are escorted, occasionally a vendor may need access to a small room with only one door and limited standing room. In these cases, the escort sits outside the room and observes the vendor completing the work. Is this practice in line with the escort policy?
While onsite conducting a CMMC Level 2 assessment at a small architecture firm that handles DoD construction contracts, the client offers a list of personnel for interviews. To answer questions regarding visitor access controls, which personnel would be MOST appropriate for interviewing?
An OSC has a minimal physical footprint consisting only of network equipment, workstations, and a centralized domain environment. File storage is centralized in a third-party vendor’s FedRAMP Moderate authorized cloud environment, and employees access files using the cloud integration with their workstations. Since CUI is stored in the FedRAMP Moderate authorized environment, the OSC should prepare to have which environment(s) assessed?
A company is seeking Level 2 CMMC certification. During the Limited Practice Deficiency Correction Evaluation, the Lead Assessor must decide whether the company can move to a POA&M review. Which condition will result in the Lead Assessor recommending that the OSC’s practice deficiencies move to a POA&M review?
A Lead Assessor is preparing to conduct a Level 2 Assessment for an OSC. During the planning phase, the Lead Assessor and OSC have:
Developed evidence collection approach;
Identified the team members, resources, schedules, and logistics;
Identified and managed conflicts of interest;
Gained access to the OSC’s relevant documentation.
Based on the information provided, which would be an additional element to be discussed during the planning phase of the assessment?
To meet AC.L2-3.1.5: Least Privilege, the following procedure is established:
All employees are given a basic (non-privileged) user account.
System Administrators are given a separate System Administrator account.
Database Administrators are given a separate Database Administrator account.
Which steps should be added to BEST meet all of the standards for least privilege?
An OSC has a large multi-building facility. One building is used as the OSC’s data center. A guard is stationed at the entrance to the data center. A vendor engineer comes onsite to perform maintenance on the storage array in the data center. The guard knows the engineer well and has the engineer fill out the visitor log with the contact person’s name and phone number, the reason for the visit, and the date and time. Since the guard has known the engineer for many years, what is the BEST step the guard should take?
Phase 2 of the CMMC Assessment Process specifies that the Assessment Team shall generate the final recommended assessment results. The status and recommended scores of the implemented CMMC practices are collected throughout the assessment and are reviewed with the OSC during the final daily review.
What are the key sequential subphases that support the generation of final recommended assessment results?
A CCA is assessing the implementation of SC.L2-3.13.7: Split Tunneling control via the examine method. Which scenario MUST be correct to determine if the practice is MET?
A company employs an encrypted VPN to enhance confidentiality over remote connections. The CCA reads a document describing the VPN. It states the VPN allows automated monitoring and control of remote access sessions, helps detect cyberattacks, and supports auditing of remote access to ensure compliance with CMMC requirements.
What document is the CCA MOST LIKELY reviewing to see how these VPNs are controlled and monitored?
A Lead Assessor is conducting an assessment for an OSC. The Lead Assessor is collecting evidence regarding the OSC’s network separation techniques. Which technique would be considered a logical separation technique and would fall within the scope of the assessment?
What should the Lead Assessor do to BEST ensure the evidence supplied effectively meets the intent of the standard for a practice?
While examining the customer responsibility matrix submitted by the OSC for one of its Cloud Service Providers (CSPs), the Assessor notes that the matrix was substantially completed by the OSC’s RPO. In fact, there is a statement from the RPO that the CSP has met the requirements for FedRAMP MODERATE.
In order to accept that this CSP is qualified to perform some of the practices on behalf of the OSC, what should occur?
FIPS-validated cryptography is required to meet CMMC practices that protect CUI when transmitted or stored outside the OSC’s CMMC enclave. What source does the CCA use to verify that the cryptography the OSC has implemented is FIPS-validated?
When preparing for an assessment, the assessor determines that the client’s proprietary data resides within an enclave. However, the assessor is unable to review policies containing proprietary data onsite and plans to have the policies copied on removable media by the client’s IT staff, whom they are scheduled to interview. What should the assessor consider as part of their planning?
A company has a server in its own Virtual Cloud used as a CUI enclave. There is a point-to-point VPN between the OSC’s office and the cloud environment. Designated users have direct access to the enclave when in the office. When working remotely, those users must establish a VPN connection between their company laptop and the cloud server.
During the assessment, the CCA asks the IT manager about external connections.
How many external connections are within the boundary for this assessment?
The OSC POC has supplied all of the procedures, policies, and plans at the start of the assessment. One of the assessors notes that some of the documents have very recent approval dates, while others have been in place for several years based on the document history.
In order to ensure the review of this evidence is sufficient, what is the BEST step to validate the sufficiency of these documents?
A CCA is assessing the concept of least functionality in accordance with CM.L2-3.4.6: Least Functionality.
Which method is the LEAST LIKELY to be useful as an assessment technique?
While examining controls on the use of portable storage devices, an assessor conducts an interview with a mid-level internal system administrator. The administrator describes the process to check out portable storage devices, which includes a user emailing IT staff directly, verifying that the media classification label matches the data classification, and limiting use of the device to a specified external system.
What is a MISSING element for the assessment of AC.L2-3.1.21: Portable Storage Use?
The assessment team is discussing the pre-assessment scope with an OSC. The OSC would like to limit the scope of the security requirements in environments that contain FCI and/or CUI. In this case, the OSC should:
During an assessment, the Lead Assessor determines certain assets to be in-scope which the OSC had considered out-of-scope.
The CCA should reply that for assets to be considered out-of-scope they:
An OSC has built an enclave for its production environment. The enclave sits behind a firewall, with all equipment connected through a switch. There is a shipping workstation and physically connected label printer (used for the sales system, which does not process CUI) that the OSC claims are Contractor Risk Managed Assets (CRMA). Other than showing that the shipping workstation and label printer are not intended to store or transmit CUI, and documenting them in the SSP,
how BEST would the OSC show that the shipping workstation and label printer are Contractor Risk Managed Assets?
An OSC has a hardware and software list used to manage company assets. Which is the BEST evidence to show the OSC is managing the system baseline?
The Lead Assessor is conducting an assessment for an OSC. The Lead Assessor has finished collecting and examining evidence from the assessment.
Based on this information, what is the NEXT logical step?
A company mirrors its FCI/CUI data storage in a cloud environment. Data is managed across multiple virtual machines (VMs). To satisfy requirements for data security of the LOCAL copy using physical controls, what should the OSC do?
During a company’s assessment, the CCA notices that the server room door is kept open with a fan in the entryway because the cooling system is inadequate and the machines are overheating. According to the physical protection policy, the server room’s keypad is the mechanism for managing and controlling access to this equipment, and only the IT team should have access to the server room. However, with the door open, the keypad is not necessary, and anyone can enter the room.
The CCA asks the IT manager how access to this room is protected while the door is open. Which response would allow the company to still meet the physical security requirement?
Does CMMC Level 2 require that a Cloud Service Provider (CSP) hold a FedRAMP HIGH authorization hosted in a government community cloud (GCC)?
An organization’s password policy includes these requirements:
Passwords must be at least 8 characters in length.
Passwords must contain at least one uppercase character, one lowercase character, and one numeric digit.
Passwords must be changed at least every 90 days.
When a password is changed, none of the previous 3 passwords can be reused.
Per IA.L2-3.5.7: Password Complexity, what requirement is missing from this password policy?
While conducting a CMMC Level 2 Third-Party Assessment of a small defense contractor, an assessor discovers that the contractor’s Information Security Policy has no documented change records demonstrating executive approval. The IT director states that they will add change records in the future, but that other evidence exists. Which documentation is MOST able to demonstrate persistent and habitual adherence to CMMC requirements?
A cloud-native OSC uses a vendor’s FedRAMP MODERATE authorized cloud environment for all aspects of their CUI needs (identity, email, file storage, office suite, etc.) as well as the vendor’s locally installable applications. The OSC properly configured the vendor’s cloud-based SIEM system to monitor all aspects of the cloud environment. The OSC’s SSP documents SI.L2-3.14.7: Identify Unauthorized Use, defining authorized use and referencing procedures for identifying unauthorized use.
How should the Certified Assessor score this practice?
What is NOT required for the Lead Assessor to confirm when verifying readiness to conduct an assessment?
While conducting a Level 2 Assessment, the Assessment Team begins reviewing assessment objects. The team identifies concerns with several of the objects presented. Which artifacts would require the MOST verification?
An OSC is a wholly owned subsidiary of a large conglomerate (parent organization). The OSC and the parent organization use ID badges (PKI cards) that contain a PKI certificate and a radio frequency identification (RFID) tag used for building and system access (including systems that process, transmit, or store CUI). The parent organization does not make any decisions on how the OSC runs its security program or other matters of significance. The large conglomerate operates a machine that is used to activate the badges for both itself and the OSC. This machine is isolated in a locked room and has no network connectivity to the OSC.
The badge activation system is:
A C3PAO is conducting a Level 2 assessment of a midsized construction contractor that does both private (commercial) and federal work. The contractor’s documentation states that all CUI flows through a single building on their office campus and is logically, physically, and administratively isolated from the rest of the environment. Why might an assessor request access to assess controls within a building or area not listed as in-scope in the documentation?
AC.L2-3.1.6: Non-Privileged Account Use is being assessed. Which procedure BEST meets all of the standards for non-privileged account use?
While conducting an assessment, an assessor is determining if privileged accounts are used for non-privileged functions. While interviewing a user with a privileged account, the assessor should ask if the person interviewed:
An assessor reviews the OSC’s data protection policy, which requires full disk encryption on company laptops. While interviewing employees, the assessor learns that employees sometimes access data while teleworking on laptops that do not have full disk encryption.
How should the assessor view the implementation of the OSC’s policy?
While examining evidence, a CCA is trying to confirm the claim that the OSC has identified all information system users, processes acting on behalf of users, and all devices.
Which of the following provides the STRONGEST evidence of this practice?
During the assessment of a company, the CCA learns that 50% of employees work from home using remote access. After reviewing the Access Control policy and audit logs, the CCA is unsure how the system ensures only employees with correct privileges can access CUI. The CCA decides a Test of functionality is required. Which question is of the LEAST concern to the CCA?
The Assessment Team is meeting with the OSC team and experiences a situation where some members of the OSC team describe the IT infrastructure differently from others. In some discussions, one person identifies a series of ESPs, while another describes the infrastructure as on-premises. What should the Lead Assessor do to clarify the actual operational environment?
The OSC’s network consists of a single unmanaged switch that connects all devices, including OT equipment which cannot run a vendor-supported operating system. The OSC correctly scoped the OT equipment as a Specialized Asset, listed it in their inventory and SSP, and provided a network diagram showing plans to isolate the OT and apply additional security measures. What information does the Lead Assessor still require to ensure compliance?
An OSC is presenting evidence of its fulfillment of CM.L2-3.4.1: System Baselining. It provides:
System inventory records showing additions/removals of machines,
Software inventory showing installations/removals, and
A system component installation plan with software needs and user specifications.
What other documentation MUST the company present to illustrate compliance with CM.L2-3.4.1?