CMMC LEVEL 2: Introduction
This document provides guidance in the preparation for and conduct of a Level 2 self-assessment or Level 2 certification assessment under the Cybersecurity Maturity Model Certification (CMMC) Program as set forth in section 170.16 of title 32, Code of Federal Regulations (CFR) and 32 CFR § 170.17 respectively. Certification at each CMMC level occurs independently. Guidance for conducting a Level 1 self-assessment can be found in CMMC Assessment Guide – Level 1. Guidance for conducting a Level 3 certification assessment can be found in CMMC Assessment Guide – Level 3. More details on the model can be found in the CMMC Model Overview document.
An Assessment as defined in 32 CFR § 170.4 means the testing or evaluation of security controls to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for an information system or organization as defined in 32 CFR § 170.15 to 32 CFR § 170.18. For Level 2 there are two types of assessments:
A self-assessment is the term for the activity performed by an entity to evaluate its own CMMC Level, as applied to Level 1 and some Level 2.
A Level 2 certification assessment is the term for the activity performed by a Certified Third-Party Assessment Organization (C3PAO)to evaluate the CMMC level of an OSC.
32 CFR § 170.16(b) describes contract or subcontract eligibility for any contract with a Level 2 self-assessment requirement, and 32 CFR § 170.17(b) describes contract or subcontract eligibility for any contract with a Level 2 certification assessment requirement. Level 2 certification assessment requires the Organization Seeking Assessment (OSA) achieve the CMMC Status of either Conditional Level 2 (C3PAO) or Final Level 2 (C3PAO), as described in 32 § CFR 170.4, obtained through an assessment by an accredited C3PAO.
Level 2 Description
Level 2 incorporates the security requirements specified in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Revision 2, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations. Level 2 addresses the protection of Controlled Unclassified Information (CUI), as defined in 32 CFR § 2002.4(h):
Information the Government creates or possesses, or that an entity creates or possesses for or on behalf of the Government, that a law, regulation, or Government-wide policy requires or permits an agency to handle using safeguarding or dissemination controls. However, CUI does not include classified information (see paragraph (e) of this section) or information a non-executive branch entity possesses and maintains in its own systems that did not come from, or was not created or possessed by or for, an executive branch agency or an entity acting for an agency. Law, regulation, or Government-wide policy may require or permit safeguarding or dissemination controls in three ways: Requiring or permitting agencies to control or protect the information but providing no specific controls, which makes the information CUI Basic; requiring or permitting agencies to control or protect the information and providing specific controls for doing so, which makes the information CUI Specified; or requiring or permitting agencies to control the information and specifying only some of those controls, which makes the information CUI Specified, but with CUI Basic controls where the authority does not specify.
Level 2 certification assessments provides increased assurance to the DoD that an OSA can adequately protect CUI at a level commensurate with the adversarial risk, including protecting information flow with subcontractors in a multi-tier supply chain.
Purpose and Audience
This guide is intended for assessors, OSAs, cybersecurity professionals, and individuals and companies that support CMMC efforts. This document can be used as part of preparation for and conducting a Level 2 self-assessment or a Level 2 certification assessment. The term Level 2 assessment encompasses both Level 2 self-assessment and Level 2 certification assessment.
Document Organization
This document is organized into the following sections:
Assessment and Certification: provides an overview of the Level 2 self-assessmen processes set forth in 32 CFR §170.16 as well as the Level 2 certification assessment processes set forth in 32 CFR § 170.17. It provides guidance regarding the scope requirements set forth in 32 CFR § 170.19(c).
CMMC-Custom Terms: incorporates definitions from 32 CFR § 170.4 and definitions included by reference from 32 CFR § 170.2, and provides clarification of the intent and scope of custom terms as used in the context of CMMC.
Assessment Criteria and Methodology: provides guidance on the criteria and methodology (i.e., interview, examine, and test) to be employed during a Level 2 assessment, as well as on assessment findings.
Requirement Descriptions: provides guidance specific to each Level 2 security requirement.
Assessment and Certification
Certified Assessors as described in 32 CFR § 170.11 will use the assessment methods defined in NIST SP 800-171A, Assessing Security Requirements for Controlled Unclassified Information, along with the supplemental information in this guide, to conduct Level 2 certification assessments. Certified Assessors will review information and evidence to verify that an OSC meets the stated assessment objectives for all of the requirements.
An OSC can obtain a Level 2 certification assessment for an entire enterprise network or for a specific enclave(s), depending upon how the CMMC Assessment Scope is defined in accordance with 32 CFR § 170.19(c).
OSAs conducting self-assessments in accordance with 32 CFR § 170.16 are expected to evaluate their compliance with CMMC requirements using the same criteria established in NIST SP 800-171A and this assessment guide and used for third-party assessments.
Assessment Scope
The CMMC Assessment Scope must be specified prior to assessment in accordance with the requirements of 32 CFR § 170.19. The CMMC Assessment Scope is the set of all assets in the OSA’s environment that will be assessed against CMMC security requirements.
Because the scoping of a Level 2 certification assessment is not the same as the scoping of a Level 3 certification assessment, before determining the CMMC Assessment Scope it is important to first consider whether the goal is a Level 2 or Level 3 CMMC Status. If the intent is not to achieve a CMMC Status of Final Level 3 (DIBCAC) as defined in 32 CFR § 170.18, refer to the guidance provided in the CMMC Scoping Guide – Level 2 document which summarizes 32 CFR § 170.19(c). If the intent is to achieve a CMMC Status of Final Level 3 (DIBCAC), refer to the guidance provided in the CMMC Scoping Guide – Level 3 document which summarizes 32 CFR § 170.19(d). Both documents are available on the official CMMC documentation site at https://dodcio.defense.gov/CMMC/Documentation/.
CMMC-Custom Terms
The CMMC Program has custom terms that align with program requirements. Although some terms may have other definitions in open forums, it is important to understand these terms as they apply to the CMMC Program.
The specific terms as associated with Level 2 are:
Assessment: As defined in 32 CFR § 170.4 means the testing or evaluation of security controls to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for an information system or organization, as defined in 32 CFR § 170.15 to 32 CFR § 170.18.
Level 2 self-assessment is the term for the activity performed by an OSA to evaluate its own information system when seeking a CMMC Status of Level 2 (Self).
Level 2 certification assessment is the term for the activity performed by a C3PAO to evaluate the information system of an OSC when seeking a CMMC Status of Level 2 (C3PAO).
POA&M closeout self-assessment is the term for the activity performed by an OSA to evaluate only the NOT MET requirements that were identified with POA&M during the initial assessment, when seeking a CMMC Status of Final Level 2 (Self).
POA&M closeout certification assessment is the term for the activity performed by a C3PAO or DCMA DIBCAC to evaluate only the NOT MET requirements that were identified with POA&M during the initial assessment, when seeking a CMMC Status of Final Level 2 (C3PAO) or Final Level 3 (DIBCAC) respectively.
Assessment Objective: As defined in 32 CFR § 170.4 means a set of determination statements that, taken together, expresses the desired outcome for the assessment of a security requirement. Successful implementation of the corresponding CMMC security requirement requires meeting all applicable assessment objectives defined in NIST SP 800–171A or NIST SP 800-172A.
Asset: An item of value to stakeholders. An asset may be tangible (e.g., a physical item such as hardware, firmware, computing platform, network device, or other technology component) or intangible (e.g., humans, data, information, software, capability, function, service, trademark, copyright, patent, intellectual property, image, or reputation). The value of an asset is determined by stakeholders in consideration of loss concerns across the entire system life cycle. Such concerns include but are not limited to business or mission concerns, as defined in NIST SP 800-160 Rev 1.
CMMC Assessment Scope: As defined in 32 CFR § 170.4 means the set of all assets in the OSA’s environment that will be assessed against CMMC security requirements.
CMMC Status: As defined in 32 CFR § 170.4 is the result of meeting or exceeding the minimum required score for the corresponding assessment. The CMMC Status of an OSA information system is officially stored in SPRS and additionally issued on a Certificate of CMMC Status, if the assessment was conducted by a C3PAO or DCMA DIBCAC.
Conditional Level 2 (Self) is defined in § 170.16(a)(1)(ii). The OSA has conducted a Level 2 self-assessment, submitted compliance results in the Supplier Performance Risk System (SPRS), and created a CMMC POA&M that meets all CMMC POA&M requirements listed in 32 CFR §170.16(a)(1)(ii).
Final Level 2 (Self) is defined in § 170.16(a)(1)(iii). The OSA will achieve a CMMC Status of Final Level 2 (Self) for the information system(s) within the CMMC Assessment Scope upon implementation of all security requirements and close out of the POA&M, as applicable.
Conditional Level 2 (C3PAO) is defined in § 170.17(a)(1)(ii). The OSC will achieve a CMMC Status of Conditional Level 2 (C3PAO) if a POA&M exists upon completion of the assessment and the POA&M meets all Level 2 POA&M requirements listed in 32 CFR § 170.21(a)(2).
Final Level 2 (C3PAO) is defined in § 170.17(a)(1)(iii). The OSC will achieve a CMMC Status of Final Level 2 (C3PAO) for the information systems within the CMMC Assessment Scope upon implementation of all security requirements and as applicable, a POA&M closeout assessment conducted by the C3PAO within 180 days. Additional guidance can be found in 32 CFR § 170.21.
Component: A discrete identifiable information technology asset that represents a building block of a system and may include hardware, software, and firmware. A component is one type of asset.
Enduring Exception: As defined in 32 CFR § 170.4 means a special circumstance or system where remediation and full compliance with CMMC security requirements is not feasible. Examples include systems required to replicate the configuration of ‘fielded’ systems, medical devices, test equipment, OT, and IoT. No operational plan of action is required but the circumstance must be documented within a system security plan. Specialized Assets and GFE may be Enduring Exceptions.
Event: Any observable occurrence in a system. As described in NIST SP 800-171A, the terms “information system” and “system” can be used interchangeably. Events sometimes provide indication that an incident is occurring.
Incident: An occurrence that actually or potentially jeopardizes the confidentiality, integrity, or availability of a system or the information the system processes, stores, or transmits or that constitutes a violation or imminent threat of violation of security policies, security procedures, or acceptable use policies.
Information System (IS): As defined in 32 CFR § 170.4 means a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information. An IS is one type of asset.
Monitoring: The act of continually checking, supervising, critically observing, or determining the status in order to identify change from the performance level required or expected at an organization-defined frequency and rate.
Operational plan of action: As used in security requirement CA.L2-3.12.2, means the formal artifact which identifies temporary vulnerabilities and temporary deficiencies in implementation of requirements and documents how and when they will be mitigated, corrected, or eliminated. The OSA defines the format (e.g., document, spreadsheet, database) and specific content of its operational plan of action. An operational plan of action is not the same as a POA&M associated with an assessment.
Organization-defined: As determined by the OSA being assessed except as defined in the case of Organization-Defined Parameter (ODP). This can be applied to a frequency or rate at which something occurs within a given time period, or it could be associated with describing the configuration of an OSA’s solution.
Periodically: Occurring at a regular interval as determined by the OSA that may not exceed one year. As used in many requirements within CMMC, the interval length is organization-defined to provide OSA flexibility, with an interval length of no more than one year.
Security Protection Data (SPD): As defined in 32 CFR § 170.4 means data stored or processed by Security Protection Assets (SPA) that are used to protect an OSC's assessed environment. SPD is security relevant information and includes, but is not limited to: configuration data required to operate an SPA, log files generated by or ingested by an SPA, data related to the configuration or vulnerability status of in-scope assets, and passwords that grant access to the in-scope environment.
System Security Plan (SSP): As defined in 32 CFR § 170.4 means the formal document that provides an overview of the security requirements for an information system or an information security program and describes the security controls in place or planned for meeting those requirements. The system security plan describes the system components that are included within the system, the environment in which the system operates, how the security requirements are implemented, and the relationships with or connections to other systems, as defined in NIST SP 800-53 Rev 5.
Temporary deficiency: As defined in 32 CFR § 170.4 means a condition where remediation of a discovered deficiency is feasible and a known fix is available or is in process. The deficiency must be documented in an operational plan of action. A temporary deficiency is not based on an ‘in progress’ initial implementation of a CMMC security requirement but arises after implementation. A temporary deficiency may apply during the initial implementation of a security requirement if, during roll-out, specific issues with a very limited subset of equipment is discovered that must be separately addressed. There is no standard duration for which a temporary deficiency may be active. For example, FIPS-validated cryptography that requires a patch and the patched version is no longer the validated version may be a temporary deficiency.
Assessment Criteria and Methodology
The The CMMC Assessment Guide – Level 2 leverages the assessment procedure described in NIST SP 800-171A Section 2.1:
An assessment procedure consists of an assessment objective and a set of potential assessment methods and assessment objects that can be used to conduct the assessment. Each assessment objective includes a determination statement related to the requirement that is the subject of the assessment. The determination statements are linked to the content of the requirement to ensure traceability of the assessment results to the requirements. The application of an assessment procedure to a requirement produces assessment findings. These findings reflect, or are subsequently used, to help determine if the requirement has been satisfied.
Assessment objects identify the specific items being assessed and can include specifications, mechanisms, activities, and individuals.
• Specifications are the document-based artifacts (e.g., policies, procedures, security plans, security requirements, functional specifications, architectural designs) associated with a system.
• Mechanisms are the specific hardware, software, or firmware safeguards employed within a system.
• Activities are the protection-related actions supporting a system that involve people (e.g., conducting system backup operations, exercising a contingency plan, and monitoring network traffic).
• Individuals, or groups of individuals, are people applying the specifications, mechanisms, or activities described above.
The assessment methods define the nature and the extent of the assessor’s actions. The methods include examine, interview, and test.
• The examine method is the process of reviewing, inspecting, observing, studying, or analyzing assessment objects (i.e., specifications, mechanisms, activities). The purpose of the examine method is to facilitate understanding, achieve clarification, or obtain evidence.
• The interview method is the process of holding discussions with individuals or groups of individuals to facilitate understanding, achieve clarification, or obtain evidence.
• And finally, the test method is the process of exercising assessment objects (i.e., activities, mechanisms) under specified conditions to compare actual with expected behavior.
In all three assessment methods, the results are used in making specific determinations called for in the determination statements and thereby achieving the objectives for the assessment procedure.
Criteria
Assessment objectives are provided for each requirement and are based on existing criteria from NIST SP 800-171A. The criteria are authoritative and provide a basis for the assessment of a requirement.
Methodology
To verify and validate that an OSA is meeting CMMC requirements, evidence needs to exist demonstrating that the OSA has fulfilled the objectives of the Level 2 requirements. Because different assessment objectives can be met in different ways (e.g., through documentation, computer configuration, network configuration, or training), a variety of techniques may be used to determine if the OSA meets the Level 2 requirements, including any of the three assessment methods from NIST SP 800-171A.
The assessor will follow the guidance in NIST SP 800-171A when determining which assessment methods to use:
Organizations [Certified Assessors] are not expected to employ all assessment methods and objects contained within the assessment procedures identified in this publication. Rather, organizations [Certified Assessors] have the flexibility to determine the level of effort needed and the assurance required for an assessment (e.g., which assessment methods and assessment objects are deemed to be the most useful in obtaining the desired results). This determination is made based on how the organization [contractor] can accomplish the assessment objectives in the most cost-effective manner and with sufficient confidence to support the determination that the CUI requirements have been satisfied.
The primary deliverable of an assessment is a compliance score and accompanying reportthat contains the findings associated with each requirement. For more detailed information on assessment methods, see Appendix D of NIST SP 800-171A, incorporated by reference per 32 CFR § 170.2.
Who Is Interviewed
Interviews of applicable staff (possibly at different organizational levels) may provide information to help an assessor determine if security requirements have been implemented, as well as if adequate resourcing, training, and planning have occurred for individuals to perform the requirements.
What Is Examined
Examination includes reviewing, inspecting, observing, studying, or analyzing assessment objects. The objects can be documents, mechanisms, or activities.
For some security requirements, review of documentation may assist assessors in determining if the assessment objectives have been met. Interviews with staff may help
identify relevant documents. Documents need to be in their final forms; drafts of policies or documentation are not eligible to be used as evidence because they are not yet official and still subject to change. Common types of documents that may be used as evidence include:
• policy, process, and procedure documents;
• training materials;
• plans and planning documents; and
• system, network, and data flow diagrams.
This list of documents is not exhaustive or prescriptive. An OSA may not have these specific documents, and other documents may be reviewed.
In other cases, the security requirement is best self-assessed by observing that safeguards are in place by viewing hardware, associated configuration information, or observing staff following a process.
What Is Tested
Testing is an important part of the self-assessment process. Interviews provide information about what the OSA staff believe to be true, documentation provides evidence of implementing policies and procedures, and testing demonstrates what has or has not been done. For example, OSA staff may talk about how users are identified, documentation may provide details on how users are identified, but seeing a demonstration of identifying users provides evidence that the requirement is met. The assessor will determine which requirements or objectives within a requirement need demonstration or testing. Most objectives will require testing.
Assessment Findings
The assessment of a CMMC requirement results in one of three possible findings: MET, NOT MET, or NOT APPLICABLE as defined in 32 CFR § 170.24. To achieve a Final Level 2 (Self) or Final Level 2 (C3PAO) CMMC Status, the OSA will need a finding of MET or NOT APPLICABLE on all Level 2 security requirements.
• MET: All applicable assessment objectives for the security requirement are satisfied based on evidence. All evidence must be in final form and not draft. Unacceptable forms of evidence include working papers, drafts, and unofficial or unapproved policies. For each security requirement marked MET, it is best practice to record statements that indicate the response conforms to all objectives and document the appropriate evidence to support the response.
o Enduring Exceptions when described, along with any mitigations, in the system security plan shall be assessed as MET.
o Temporary deficiencies that are appropriately addressed in operational plans of action (i.e., include deficiency reviews, milestones, and show progress towards the implementation of corrections to reduce or eliminate identified vulnerabilities) shall be assessed as MET.
• NOT MET: One or more objectives for the security requirement is not satisfied. For each security requirement marked NOT MET, it is best practice to record statements that explain why and document the appropriate evidence showing that the OSA does not conform fully to all of the objectives. During Level 2 certification assessments, for each requirement objective marked NOT MET, the assessor will document why the evidence does not conform.
• NOT APPLICABLE (N/A): A security requirement and/or objective does not apply at the time of the assessment. For each security requirement marked N/A, it is best practice to record a statement that explains why the requirement does not apply to the OSA. For example, Public-Access System Separation (SC.L2-3.13.5) might be N/A if there are no publicly accessible systems within the CMMC Assessment Scope. During an assessment, an assessment objective assessed as N/A is equivalent to the same assessment objective being assessed as MET.
If an OSC previously received a favorable adjudication from the DoD CIO indicating that a requirement is not applicable or that an alternative security measure is equally effective, the DoD CIO adjudication must be included in the system security plan to receive consideration during an assessment. Implemented security measures adjudicated by the DoD CIO as equally effective are assessed as MET if there have been no changes in the environment.
Each assessment objective in NIST SP 800-171A must yield a finding of MET or NOT APPLICABLE in order for the overall security requirement to be scored as MET. Assessors exercise judgment in determining when sufficient and adequate evidence has been presented to make an assessment finding.
CMMC assessments are conducted and results are captured at the assessment objective level. One NOT MET assessment objective results in a failure of the entire security requirement.
A security requirement can be applicable even when assessment objectives included in the security requirement are scored as N/A. The security requirement is NOT MET when one or more applicable assessment objectives is NOT MET.
Satisfaction of security requirements may be accomplished by other parts of the enterprise or an External Service Provider (ESP), as defined in 32 CFR § 170.4. A security requirement is considered MET if adequate evidence is provided that the enterprise or External Service Provider (ESP), implements the requirement objectives. An ESP may be external people, technology, or facilities that the OSA uses, including cloud service providers, managed service providers, managed security service providers, or cybersecurity-as-a-service providers.
Requirement Descriptions
Introduction
This section provides detailed information and guidance for assessing each Level 2 security requirement. The section is organized first by domain and then by individual security requirement. Each requirement description contains the following elements as described in 32 CFR § 170.14(c):
• Requirement Number, Name, and Statement: Headed by the requirement identification number in the format, DD.L#-REQ (e.g., AC.L2-3.1.1); followed by the requirement short name identifier, meant to be used for quick reference only; and finally followed by the complete CMMC security requirement statement.
• Assessment Objectives [NIST SP 800-171A]: Identifies the specific set of objectives that must be met to receive MET for the requirement as defined in NIST SP 800-171A.
• Potential Assessment Methods and Objects [NIST SP 800-171A]: Describes the nature and the extent of the assessment actions as set forth in NIST SP 800-171A. The methods include examine, interview, and test. Assessment objects identify the items being assessed and can include specifications, mechanisms, activities, and individuals.
• Discussion [NIST SP 800-171 Rev. 2]: Contains discussion from the associated NIST SP 800-171 security requirement.
• Further Discussion:
o Expands upon the NIST SP 800-171 Rev. 2 discussion content to provide additional guidance.
o Contains examples illustrating application of the requirements. These examples are intended to provide insight but are not prescriptive of how the requirement must be implemented, nor are they comprehensive of all assessment objectives necessary to achieve the requirement. The assessment objectives met within the example are referenced by letter in a bracket (e.g., [a, d] for objectives “a” and “d”) within the text.
o Examples are written from the perspective of an organization or an employee of an organization implementing solutions or researching approaches to satisfy CMMC requirements. The objective is to put the reader into the role of implementing or maintaining alternatives to satisfy security requirements. Examples are not allinclusive or prescriptive and do not imply any personal responsibility for complying with CMMC requirements.
o Provides potential assessment considerations. These may include common considerations for assessing the requirement and potential questions that may be asked when assessing the objectives.
• Key References: Lists the basic safeguarding requirement from NIST SP 800-171 Rev. 2.
Appendix A – Acronyms and Abbreviations
AC Access Control
AES Advanced Encryption Standard
API Application Programming Interface
AT Awareness and Training
AU Audit and Accountability
C3PAO CMMC Third-Party Assessment Organization
CA Security Assessment
CD-ROM Compact Disk Read-Only Memory
CFR Code of Federal Regulations
CM Configuration Management
CMMC Cybersecurity Maturity Model Certification
CMVP Cryptographic Module Validation Program
CUI Controlled Unclassified Information
CVE Common Vulnerabilities and Exposures
CWE Common Weakness Enumeration
DCMA Defense Contract Management Agency
DFARS Defense Federal Acquisition Regulation Supplement
DHC Device Health Check
DIBCAC Defense Industrial Base Cybersecurity Assessment Center
DMZ Demilitarized Zone
DoD Department of Defense
DVD Digital Versatile Disc or Digital Video Disc
ESP External Service Provider
FAQ Frequently Asked Question
FAR Federal Acquisition Regulation
FDDI Fiber Distributed Data Interface
FDE Full Disk Encryption
FIPS Federal Information Processing Standard
FTP File Transfer Protocol
IA Identification and Authentication
ID Identification
IDS Intrusion Detection System
IoT Internet of Things
IP Internet Protocol
IPSec Internet Protocol Security
IR Incident Response
ISAC Information Sharing and Analysis Center
ISDN Integrated Services Digital Network
IT Information Technology
LAN Local Area Network
MA Maintenance
MAC Media Access Control
MDM Mobile Device Management
MFA Multifactor Authentication
MP Media Protection
NARA National Archives and Records Administration
NAS Networked Attached Storage
NIST National Institute of Standards and Technology
NSA National Security Agency
NTP Network Time Protocol
OS Operating System
OSA Organization Seeking Assessment
OSC Organization Seeking Certification
OT Operational Technology
PDA Personal Digital Assistant
PE Physical Protection
PIV Personal Identity Verification
PKI Public Key Infrastructure
POTS Plain Old Telephone Service
PS Personnel Security
RADIUS Remote Authentication Dial-in User Service
RA Risk Assessment
SC System and Communications Protection
SI System and Information Integrity
SMS Short Message Service
SOC Security Operations Center
SP Special Publication
SSP System Security Plan
TLS Transport Layer Security
URL Universal Resource Locator (aka Uniform Resource Locator)
USB Universal Serial Bus
UTC Coordinated Universal Time
UUENCODE Unix-to-Unix Encode
VLAN Virtual Local Area Network
VoIP Voice over Internet Protocol
VPN Virtual Private Network
WPA2-PSK WiFi Protected Access-Pre-shared Key
Frameworks & Controls