Implement the safeguards. Collect the evidence. Explain how everything works. Keep running the business.
CMMC readiness can place a heavy workload on a small team. When one provider offers to handle preparation and the official assessment, the convenience can sound attractive. Before signing, understand which assessment path your contract requires and how conflicts of interest are handled.
Can the same company help us prepare and then certify us?
For a CMMC Level 2 certification assessment, do not assume that separating consulting and assessment into different teams resolves the conflict.
32 CFR 170.8(b)(17)(ii)(G) requires a prohibition on CMMC Ecosystem members participating in a Level 2 certification assessment when they consulted to prepare that organization for any CMMC assessment within the previous three years. Section 170.9(b)(2) requires C3PAOs to comply with the Accreditation Body’s conflict-of-interest, professional-conduct, and ethics policies.
Disclose prior consulting and relevant business relationships to the prospective C3PAO before booking the assessment. A different team name or an internal administrative boundary should not be treated as permission to bypass a prohibited relationship.
CMMC Level 1 and Level 2 follow different paths
| Assessment path | Who performs the assessment? | What this means for readiness support |
|---|---|---|
| CMMC Level 1 (Self) | The contractor conducts an annual self-assessment. | A consultant can assist with preparation; the contractor remains responsible for its results and affirmation. |
| CMMC Level 2 (Self) | The contractor conducts the required self-assessment. | Readiness assistance does not replace the contractor’s responsibilities or satisfy a contract requiring Level 2 (C3PAO). |
| CMMC Level 2 (C3PAO) | An authorized or accredited C3PAO performs the certification assessment. | Plan for an independent assessment and disclose prior consulting and other potential conflicts. |
The assessment path is determined by the applicable solicitation and contract. Confirm it before purchasing services. Official references: Level 1 self-assessment, Level 2 self-assessment, and Level 2 certification assessment.
Level 1 still requires implementation and evidence
Self-assessment does not mean checking boxes without verification. Your team needs to understand the assessment scope, implement the required safeguards, and evaluate supporting evidence. Level 1 requires annual assessment and affirmation, and does not allow POA&Ms for unmet requirements.
A consultant can help organize that work. The authorized company officials remain responsible for reporting and affirmation. Start with our CMMC Level 1 checklist and small-business scoping guide.
If we have a SOC 2 report, will we pass CMMC Level 2?
A SOC 2 report does not establish CMMC Level 2 status. The frameworks have different requirements, assessment scopes, and reporting processes. Relevant records may support preparation, but they must be evaluated against the applicable CMMC requirements and assessment objectives.
For example, an existing access review may be useful evidence. Your team still needs to establish that it covers the relevant users and systems and supports the particular objectives being assessed.
Likewise, an arrangement reviewed for SOC 2 auditor independence should not be assumed acceptable under CMMC’s consulting restrictions. Read our related article on SOC 2 compliance workload and auditor independence.
Make the handoff easier without combining incompatible roles
Build an evidence index before the formal assessment. For each requirement, identify the owner, the implementation, the evidence location, and any open work. Use records that reflect actual operations rather than creating paperwork that employees cannot explain.
Your readiness provider can help your team locate records and prepare demonstrations. The C3PAO independently evaluates the evidence and determines assessment findings.
Before choosing providers, ask:
- Who will implement improvements, and who will perform the certification assessment?
- Has the proposed assessor or assessment organization provided consulting to us?
- What ownership, referral, or financial relationships need to be disclosed?
- Has the C3PAO evaluated those relationships under its applicable policies?
- Can we choose a different C3PAO and retain access to our evidence?
CMMC readiness and implementation support from BCS
Business Communication Solutions helps Austin and Houston businesses with scope reviews, gap assessments, technical remediation, documentation, evidence organization, and assessment preparation. We can work alongside internal IT staff and existing providers.
BCS provides consulting and implementation support. We do not issue CMMC certification or guarantee an assessment outcome. Where your contract requires Level 2 (C3PAO), plan for an independent authorized or accredited C3PAO.
Explore our CMMC consulting and Level 2 gap assessment services.
Austin: 512-257-1433 Houston: 281-815-8784
What do you think?
How would you reduce the workload of CMMC readiness while preserving an independent assessment?
Would you choose your consultant and C3PAO separately from the beginning? And where does your team need the most help: implementation, evidence, or assessment preparation?