10 Lessons Learned from the CMMC Certified Assessor Course: A Masterclass in CMMC

I recently completed the Cybersecurity Maturity Model Certification (CMMC) Certified Assessor (CCA) course, and it was nothing short of a masterclass in understanding the intricacies of CMMC compliance and what “right” indeed looks like.

The course, led by Koren Wise —a seasoned CMMC Certified Assessor with a track record of guiding clients through Joint Surveillance Voluntary Assessments (JSVAs)—provided invaluable insights. The lessons and discussions with CMMC Certified Professionals (CCPs) clarified pain points and offered proven solutions for navigating the most challenging aspects of assessing (and implementing) the CMMC model.

As is often the case, the real value comes from engaging with others deeply embedded in the CMMC ecosystem. This is where expertise meets collaboration and cements understanding.

Whether you're an OSC (Organization Seeking Certification) or a C3PAO (Certified Third-Party Assessor Organization) building a team of qualified assessors, I wanted to share ten key lessons I took away from the CCA course. These insights might resonate with you and (possibly) save you some headaches along the way.

1. Phenomenal Resources in the Ecosystem

The CMMC ecosystem is rich with resources, from CCPs to CCAs. These certified experts can clarify the complexities of the regulations and accelerate your path to compliance. Koren's in-depth explanation and breakdown of current JSVA experiences were particularly enlightening, and the class input was outstanding. The key takeaway? Tap into the ecosystem—don’t try to go it alone. Explore the CMMC ecosystem.

2. Subjectivity is Still an Issue

Subjectivity remains one of the biggest challenges in CMMC assessments. This is a significant risk as the model continues to evolve. There’s still much that isn’t as clear-cut as we’d like, but this is where leveraging experts becomes crucial. A recent National Defense article highlights the subjectivity that can lead to varying interpretations. The lesson here? Stay informed and rely on professionals who follow and implement the latest developments.

3. Scoping is Critical (and a Huge Opportunity)

Getting the scope right isn’t just critical—it’s a strategic opportunity and necessity. Proper scoping can control costs, streamline CUI data flow, and lead to more effective solutions. A well-defined scope can make or break your assessment and ultimate certification. If you don’t get it right from the start, you won’t make it past Phase I. Check out the DoD’s Scoping Guide to ensure you're on track. Categorize your assets according to this guidance.

4. The Assessment Cycle Can Be Long and Drawn Out

The CMMC Assessment Process (CAP) can drag on, especially if there’s confusion about what’s in and out of scope. Precision in the early stages pays off later. The formal CAP includes four phases, and each one can extend timelines if not managed correctly. Dive into the CAP details to avoid common pitfalls.

5. Leverage CMMC Certified Resources

The CMMC curriculum and certification process ensures you're not just checking boxes but truly understanding the requirements and are on "the right path." While RPOs (Registered Provider Organizations) and RPs (Registered Practitioners) are trained in the model, they lack formal training in the assessment process. I always advise my clients to seek a CCP or CCA for any readiness work. There’s too much subjectivity and nuance to rely on someone with general knowledge—especially when hundreds of millions of dollars in contracts are at stake. That's my input. Learn more about the roles in the CMMC ecosystem.

6. C3PAOs Need to Build a Bench of 1099 Assessors

With the growing demand for qualified assessors, C3PAOs must develop a reliable bench of 1099 assessors. This is crucial for scaling operations, meeting client demands efficiently, and certifying that defense vendors meet their contractual obligations to secure Controlled Unclassified Information (CUI). Summit 7 provides an insightful overview of what this entails. Learn more from Summit 7 about the C3PAO landscape.

7. Conflicts of Interest Are Real

Be aware of potential conflicts of interest when choosing your partners. These can limit what you can do in future engagements, so knowing the rules and planning accordingly is critical. In the relatively small CMMC ecosystem, being mindful of who you work with is essential. Conflicts of interest are not deal-breakers but must be managed carefully. This Compliance Forge article provides an excellent overview of what to consider.

8. Take Advantage of JSVA

The Joint Surveillance Voluntary Assessment (JSVA) process is an excellent opportunity for OSCs to address potential certification hurdles proactively. This process is something every OSC should consider now to smooth out bumps in the certification journey. Schellman’s blog offers insightful guidance on why and how to engage with the JSVA process.

9. The CMMC Marketplace: More Than Just a Directory

The CMMC marketplace isn’t just a directory—it’s a community of practice. Whether you’re looking for assessors, consultants, or other resources, this is your go-to hub. Check out the CMMC marketplace and connect with the right partners.

10. Remember the Mission: Protecting What Matters Most

Amid all the noise, it’s easy to lose sight of the core mission: protecting Controlled Unclassified Information (CUI) and ensuring secure and proper access. The Department of Defense’s (DoD) Defense Industrial Base (DIB) Cybersecurity Strategy emphasizes the importance of a resilient, secure Joint Force and defense ecosystem. Read more on the DIB Cyber Strategy.

Key Takeaways:

1. Leverage Experts: Use the ecosystem’s resources—they’re there to help.
2. Get Scoping Right: A well-defined scope is your best friend. It saves time, money, and frustration.
3. Stay Focused on the Mission: All these processes and assessments boil down to one main thing: protecting CUI - the restricted data that gives our warfighters battlefield advantage.

Conclusion:

I thoroughly enjoyed the CCA course and learned a great deal. These ten lessons have reshaped my understanding of CMMC and its complexities. Completing the CCA course was a significant step forward in my commitment to supporting the CMMC ecosystem and ensuring our defense industrial base remains secure.

Let’s keep moving forward together—securing the DIB with simplicity, security, and strength.

Now, on to that exam...