Final Interpretation Authority in the CMMC Assessment ProcessDuring aCMMC Level 2 assessment, several entities are involved in the process, including theOrganization Seeking Certification (OSC), Certified Third-Party Assessment Organization (C3PAO), Assessment Team Members, and the CMMC Accreditation Body (CMMC-AB).
* Role of the C3PAO and Assessment Team:
* TheCertified Third-Party Assessment Organization (C3PAO)is responsible for conducting the assessment and makinginitial recommended findingsbased on NIST SP 800-171 security requirements.
* Assessment Team Members(Lead Assessor and support staff) conduct evaluations and submit theirrecommendationsto the C3PAO.
* Final Interpretation Authority - CMMC-AB:
* TheCMMC Accreditation Body (CMMC-AB)is responsible for ensuring consistency and accuracy in assessments.
* If there is any dispute or need for clarification regarding findings, CMMC-AB provides the final interpretation and guidance.
* This ensures uniformity in certification decisions across different C3PAOs.
* Why CMMC-AB is the Correct Answer:
* CMMC-AB has the ultimate authority over thequality assurance processfor assessments.
* It reviewsremediation requests, challenges, or disputesfrom the OSC or C3PAO and makes final determinations.
* The CMMC-AB maintains oversight to ensure assessmentsalign with CMMC 2.0 policies and DFARS 252.204-7021 requirements.
* A. C3PAO- The C3PAO conducts the assessment and submits findings, butit does not have the final interpretation authority. Findings must pass through theCMMC-AB quality assurance process.
* C. OSC Sponsor- The OSC (Organization Seeking Certification)cannot interpret findings; they can only respond to identified deficiencies and appeal assessments through CMMC-AB channels.
* D. Assessment Team Members- The assessment teamrecommends findingsbut does not make final interpretations. Their role is limited to conducting evaluations, collecting evidence, and submitting reports to the C3PAO.
References:CMMC Assessment Process Guide (CAP v2.0)-Cyber AB
DFARS 252.204-7021(DoD Regulation on CMMC Requirements)
CMMC 2.0 Model Overview(DoD CIO Site)
#Final Answer: B. CMMC-AB