Exam Roadmap
DOMAIN 1
CMMC Ecosystem
5%
~8–9 questions
DOMAIN 2
Code of Professional Conduct
5%
~8–9 questions
DOMAIN 3 ★ PRIORITY
Governance & Source Documents
15%
~25–26 questions
DOMAIN 4
Model Construct & Implementation
25–35%
~42–60 questions
DOMAIN 5 ★ PRIORITY
CMMC Assessment Process (CAP)
35–40%
~60–68 questions
DOMAIN 6
Scoping
15–20%
~25–34 questions
Suggested 2–3 Hour Study Schedule
Domain 3 · Governance & Source Docs Priority
25 min
Domain 5 · CMMC Assessment Process Priority
40 min
Domain 4 · Model Construct & Implementation
35 min
Domain 6 · Scoping
25 min
Domain 1 · Ecosystem
10 min
Domain 2 · Ethics / CoPC
10 min
Practice Questions (all domains)
35 min
Key Source Documents — Quick Reference
These documents are tested directly. Know the relationship between each one — many questions hinge on knowing which source document governs what.
| Document | What It Governs | Key Link |
|---|---|---|
| CMMC 2.0 Final Rule (32 CFR Part 170) | The CMMC program rule itself — levels, requirements, certification paths | DoD / OUSD(A&S) |
| DFARS 252.204-7012 | Safeguarding Covered Defense Information; mandates NIST SP 800-171 compliance | Existing contract clause |
| DFARS 252.204-7019 / 7020 / 7021 | 7019: SPRS score requirement; 7020: allows DoD to review SSP; 7021: requires CMMC certification | CMMC-level contracts |
| NIST SP 800-171 Rev 2 | 110 security requirements for protecting CUI; basis of CMMC Level 2 | Maps to 14 domains |
| NIST SP 800-172 | Enhanced security requirements for CUI (Level 3 baseline) | Critical programs only |
| NIST SP 800-171A | Assessment procedures for 800-171 controls — drives examination/interview/test methods | Used in CAP |
| 48 CFR Part 52 / FAR 52.204-21 | Basic Safeguarding of Covered Contractor Information Systems; 15 practices for FCI | Level 1 baseline |
| 32 CFR Part 2002 (CUI Rule) | ISOO CUI program; definitions, markings, categories | Authoritative for CUI |
| CMMC Assessment Process (CAP) Document | Cyber AB's official document governing how C3PAO assessments are conducted | C3PAO / assessment teams |
High-Frequency Exam Terms
Information Categories Know Cold
- FCI – Federal Contract Information: info provided by or generated for the Government under a contract. NOT intended for public release. Requires basic safeguarding (FAR 52.204-21, 15 practices).
- CUI – Controlled Unclassified Information: information the Government creates or possesses that requires safeguarding per law/policy. Requires NIST 800-171 (CMMC Level 2).
- CDI – Covered Defense Information: umbrella term per DFARS 7012; includes CUI and operationally critical technical data.
Key Acronyms Tested
- OSC – Organization Seeking Certification
- C3PAO – CMMC Third-Party Assessor Organization
- CCA – Certified CMMC Assessor
- CCP – Certified CMMC Professional (you)
- CCI – Certified CMMC Instructor
- DIB – Defense Industrial Base
- SPRS – Supplier Performance Risk System (score repository)
- POA&M – Plan of Action & Milestones
- SSP – System Security Plan
Domain 1
CMMC Ecosystem
5% of Exam
Ecosystem Roles & Relationships
| Entity | Role | Key Facts |
|---|---|---|
| OUSD(A&S) | Policy owner | Under Secretary of Defense for Acquisition & Sustainment. Owns CMMC program policy and rulemaking (32 CFR Part 170). |
| Cyber AB (formerly CMMC-AB) | Accreditation body | Non-profit authorized by DoD. Accredits C3PAOs, certifies CCPs/CCAs/CCIs. Maintains marketplace. Issues Code of Professional Conduct. |
| CAICO | Compliance & enforcement | CMMC Accreditation Institute Compliance Organization — investigates CoPC violations. |
| C3PAO | Conducts L2/L3 assessments | Must be Cyber AB–accredited. Employs Lead CCA + assessment team. Cannot consult for the same OSC they assess (conflict of interest). |
| RPO | Consulting / readiness | Registered Practitioner Organization — helps OSCs prepare. Cannot conduct formal assessments. Employs CCPs. |
| OSC | The contractor being assessed | Organization Seeking Certification. Responsible for their own compliance, SSP, evidence. |
| DCSA | DoD L3 government-led assessments | Defense Counterintelligence and Security Agency — conducts Level 3 assessments on behalf of DoD. |
CCP Role & Boundaries
A CCP can support assessments under CCA supervision but cannot lead them. Know the line between what a CCP vs. CCA vs. Lead CCA is authorized to do.
- CCP: Can be on assessment team, collect evidence, support gap analysis. Employed by RPOs and C3PAOs.
- CCA: Can lead and sign off on CMMC assessments. Requires passing CCA exam + mentored assessment hours.
- Lead CCA: Leads the entire assessment engagement; final responsible party for the report.
Conflict of Interest Rules
Prohibited Scenarios Tested
- Same C3PAO cannot both consult/prepare an OSC and conduct their CMMC assessment (consulting taint).
- An assessor cannot assess an organization where they have a financial or employment interest.
- CCPs/CCAs must disclose conflicts before being assigned to engagements.
- Marketplace listing does not imply endorsement of any specific OSC relationship.
Practice Questions · Domain 1
Q1
An RPO has been helping an OSC prepare for their Level 2 CMMC assessment for six months. The OSC now asks the same RPO to conduct the formal certification assessment. What is the correct course of action?
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Q2
Which entity is responsible for investigating potential Code of Professional Conduct violations against a Certified CMMC Professional?
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Domain 2
Code of Professional Conduct (Ethics)
5% of Exam
CoPC Core Pillars
Professionalism
- Represent credentials accurately; only claim certifications you hold.
- Perform only work within your competence level.
- Maintain continuing education requirements for certification renewal.
Objectivity / Independence
- Assessors must remain free of bias and conflict of interest.
- Cannot allow personal relationships to influence assessment outcomes.
- Results must be based solely on evidence.
Confidentiality
- Protect all information obtained during assessments — including SSPs, network diagrams, and findings.
- OSC data cannot be shared without authorization.
- Confidentiality obligations survive after an engagement ends.
Proper Use of Materials
- Do not reproduce, distribute, or share proprietary CMMC training materials.
- Exam content is confidential — sharing questions is a CoPC violation.
- Includes materials from Cyber AB, LTPs, and official source documents.
Exam questions often present scenarios and ask you to identify which CoPC principle was violated. Map each scenario to: Professionalism, Objectivity, Confidentiality, or Proper Use.
Practice Questions · Domain 2
Q3
A CCP who recently completed an assessment casually mentions specific findings from an OSC's assessment to colleagues at an industry conference. Which CoPC principle has been violated?
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Domain 3
Governance & Source Documents
15% — Priority ★
The Regulatory Chain
The exam tests whether you understand the hierarchy of requirements — from federal law → DoD policy → contract clause → CMMC requirement. Many wrong answers confuse which layer governs what.
01
Federal Law
FISMA, E.O. 13556
02
DoD Regulation
32 CFR 170
03
Contract Clauses
DFARS 252.204
04
NIST Standards
800-171, 800-172
05
CMMC Model
L1 / L2 / L3
DFARS Clauses — Critical Distinctions
| Clause | Requirement | Who It Applies To |
|---|---|---|
252.204-7012 | Safeguard Covered Defense Information; report cyber incidents to DIBNet within 72 hours; preserve images 90 days; report malicious software | All contractors handling CDI/CUI |
252.204-7019 | Notice of NIST SP 800-171 DoD Assessment Req. — contractor must complete NIST 800-171 assessment and post score to SPRS | Contractors before award |
252.204-7020 | NIST SP 800-171 DoD Assessment Requirements — gives DoD right to review contractor's SSP and assessment results | Contractors post-award |
252.204-7021 | CMMC Level Requirements — specifies the required CMMC level; contractor must achieve and maintain it | Contracts requiring CMMC cert |
FCI vs. CUI — Master This
FCI Federal Contract Information
- Information provided by or generated for the Government under a contract.
- Not intended for public release.
- Governed by FAR 52.204-21 (15 basic safeguarding practices).
- Requires CMMC Level 1 (17 practices, annual self-assessment).
- Does NOT include information provided to the public or simple transactional data (price lists, etc.).
CUI Controlled Unclassified Information
- Information the Government creates or possesses that requires safeguarding per law, regulation, or policy.
- Governed by 32 CFR Part 2002 and the CUI Registry (ISOO).
- Handling, marking, and destruction governed by CUI markings (e.g., CUI//SP-CTI).
- Requires CMMC Level 2 (110 practices from NIST 800-171).
- All CUI is a subset of CDI under DFARS 7012.
Key distinction: FCI flows under a contract. CUI is designated by a Government agency and requires specific handling. A contractor can have FCI without having CUI.
CMMC Level Structure
| Level | Name | Practices | Source | Assessment | For |
|---|---|---|---|---|---|
| L1 | Foundational | 17 | FAR 52.204-21 | Annual self-assessment, affirmed to SPRS | Contractors with FCI only |
| L2 | Advanced | 110 | NIST SP 800-171 Rev 2 | Triennial third-party (C3PAO) or self-assessment (some programs) | Contractors with CUI |
| L3 | Expert | 110 + 24 | NIST SP 800-171 + 800-172 subset | Government-led (DCSA) | Critical programs, highest-risk CUI |
POA&M Rules
Plan of Action & Milestones (POA&M) rules differ by level. This is tested frequently.
- For Level 2 third-party assessments: limited POA&M is allowed for certain practices, but there is a minimum floor score — a contractor cannot achieve CMMC if their score is below the threshold, regardless of POA&M.
- POA&M items must have realistic, achievable timelines — they are a commitment, not a parking lot.
- Critical/high-impact practices cannot be left on a POA&M; they must be MET at time of assessment.
- Closing the POA&M triggers a follow-up or confirmation assessment before certification is awarded.
Practice Questions · Domain 3
Q4
A prime contractor generates reports documenting technical specifications used during weapon system development for the DoD. These reports are shared with a subcontractor. Which information category BEST describes these reports?
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Q5
A contractor discovers that their SPRS score is -147 and has not been updated in 18 months. A new contract under DFARS 252.204-7019 is being awarded. What is the contractor's immediate obligation?
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Q6
Which DFARS clause specifically grants the DoD Contracting Officer the right to review a contractor's System Security Plan?
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Q7
Under 32 CFR Part 170, which CMMC level requires a Government-led assessment conducted by DCSA?
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Domain 4
CMMC Model Construct & Implementation Evaluation
25–35% of Exam
The 14 CMMC Security Domains
These map directly from NIST SP 800-171. Know each domain abbreviation, approximate practice count at L2, and what it governs. Scenario questions will test whether you can assign a control to the right domain.
| Abbr | Domain | Key Focus | L2 Practices |
|---|---|---|---|
AC | Access Control | Least privilege, remote access, session controls, CUI flow control | 22 |
AT | Awareness & Training | User security awareness, role-based training, insider threat awareness | 3 |
AU | Audit & Accountability | Log creation, protection, review, retention, event correlation | 9 |
CM | Configuration Management | Baselines, change control, least functionality, software restrictions | 9 |
IA | Identification & Authentication | Multi-factor auth, password management, authenticator management | 11 |
IR | Incident Response | Incident handling, reporting (72-hr DIBNet), testing response capability | 3 |
MA | Maintenance | Controlled/sanitized maintenance, maintenance tools, remote maintenance | 6 |
MP | Media Protection | Access, marking, storage, transport, sanitization, destruction of CUI media | 9 |
PS | Personnel Security | Screening, termination, transfer, third-party personnel | 2 |
PE | Physical Protection | Physical access to systems/facilities containing CUI | 6 |
RA | Risk Assessment | Risk assessments, vulnerability scanning, risk response | 3 |
CA | Security Assessment | System assessments, plans of action, configuration management, monitoring | 4 |
SC | System & Communications Protection | Network boundaries, CUI in transit, architecture, mobile code, VoIP | 16 |
SI | System & Information Integrity | Malware, security alerts, patching, spam protection, input validation | 7 |
Practice vs. Objective vs. Capability
CMMC Model Hierarchy Architecture
- Domain → Highest grouping (14 total, e.g., Access Control)
- Capability → Grouping of related practices within a domain (not tested as heavily in CCP)
- Practice → Specific activity requirement, numbered (e.g., AC.L2-3.1.1)
- Objective → Sub-elements within a practice used in assessment; from NIST 800-171A
Practice Numbering Format
AC.L2-3.1.1
- AC = Domain (Access Control)
- L2 = Level (Level 2)
- 3.1.1 = NIST SP 800-171 requirement number (Family 3.1, Req. 1)
Level 1 practices are labeled L1; Level 2 includes all Level 1 practices plus additional ones.
Evidence Types
From NIST 800-171A / CMMC Assessment Guide — assessors use three methods. Know when each is appropriate.
| Method | What It Is | Examples |
|---|---|---|
| Examine | Review of documentation, mechanisms, and configurations | Policies, SSP, log samples, screenshots, config files, network diagrams |
| Interview | Questioning of individuals to verify knowledge and process | System admin confirming patch process, ISSO explaining incident response steps |
| Test | Exercising a mechanism to verify it works as intended | Attempting unauthorized access, running vulnerability scanner, MFA test |
Most CMMC practices require ALL THREE methods to achieve a MET determination. A practice is only MET when all objectives are satisfied. If any objective is NOT MET, the practice is NOT MET.
MET / NOT MET Scoring
- Each practice is scored as either MET or NOT MET — there is no partial credit.
- SPRS score starts at 110. Each NOT MET practice deducts a weighted point value. The maximum SPRS score is 110; a perfect score means all practices are MET.
- Negative SPRS scores are possible and reflect significant gaps.
- A CMMC Level 2 certification requires all 110 practices MET (with limited POA&M exceptions).
Practice Questions · Domain 4
Q8
During an assessment, an assessor reviews firewall rule sets, interviews the network engineer about segmentation rationale, and attempts to access a CUI system from an untrusted network segment. Which assessment methods are being used, respectively?
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Q9
An OSC has 108 out of 110 practices MET. The 2 remaining practices are NOT MET and placed on a POA&M. Under CMMC Level 2 with a third-party assessment, what outcome is MOST accurate?
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Q10
An assessor is evaluating practice SI.L2-3.14.1 (Identify, report, and correct information and information system flaws). The system has a documented patching policy, the admin demonstrates the patching tool, and the assessor confirms recent patches are applied. Three of four objectives are satisfied; the fourth (timely remediation verification) cannot be confirmed. What is the determination?
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Domain 5
CMMC Assessment Process (CAP)
35–40% — Priority ★
CAP — 4 Phases Overview
The CAP applies to Level 2 assessments only. It is developed by the Cyber AB, reviewed/endorsed by DoD, and adherence is required by C3PAOs and their assessors. The word "shall" in the CAP = a requirement.
Phase 1
Plan & Prepare
1–several days
Phase 2
Conduct
Examine/Interview/Test
Phase 3
Report Results
Findings & eMASS Upload
Phase 4
Close-Out POA&Ms
Within 180 days
Critical Numbers — Memorize These
Key Timeframes Tested Heavily
- 5 business days — C3PAO must respond to OSC's initial assessment request
- 5 business days — OSC has to correct Limited Practice Deficiencies after Final Findings Briefing (or Lead Assessor-defined date, max 5 calendar days before eMASS upload)
- 180 days — Maximum POA&M validity from the Assessment Final Recommended Findings Briefing (Phase 3)
- 180 days — OSC must complete POA&M Close-Out Assessment within this window
- 10 business days — Report must be submitted to CQAP from Final Findings Briefing
- 20 business days — Report must be uploaded to eMASS from Final Findings Briefing
- 3 years — Assessment artifacts and notes must be retained and protected
Key Thresholds & Numbers Tested Heavily
- 88 / 110 — Minimum MET practices (80%) required for a Conditional L2 Certification (POA&M pathway)
- 110 — Starting SPRS score; perfect score = all practices MET
- 15 — Number of practice objectives that must be assessed in-person (cannot be virtual)
- 5 pts — SPRS deduction for high-impact practices (significant exploitation risk)
- 3 pts — SPRS deduction for medium-impact practices
- 1 pt — SPRS deduction for low-impact practices
- 1 CQAP minimum — Every C3PAO must have at least one CMMC Quality Assurance Professional on staff
Phase 1 — Plan & Prepare the Assessment
Phase 1 is driven by the C3PAO and Lead Assessor. The Pre-Assessment Data Form is the master planning document — it must be kept current throughout Phase 1 and uploaded to eMASS at Phase 1 completion.
1.1 — Receive Assessment Request & Frame
Initial Contact Rules CAP §1.1
- OSC initiates contact with a C3PAO listed as "Authorized" on the CMMC Marketplace.
- C3PAO must respond within 5 business days, acknowledging the request and proposing an initial coordination call.
- Contact may be initiated by either party. Neither the Cyber AB nor DoD may serve in an introductory or facilitation role between OSC and C3PAO.
- OSC may express a preference for a specific assessor — C3PAO may consider it, but the authority to select the assessment team rests solely with the C3PAO.
Assessment Framing vs. CMMC Assessment Scope — These two terms are often confused on the exam. Assessment Framing = high-level discussion of size, scale, date, location, cost, and effort. CMMC Assessment Scope = the technical, official boundary of assets to be assessed. Both are defined in Phase 1, but they are distinct activities.
1.2 — Roles & Responsibilities
| Role | Who They Are | Key Authority / Constraint |
|---|---|---|
| OSC Assessment Official | Most senior OSC representative directly responsible for the assessment engagement | Must be an employee of the OSC. Only they can sign/approve the assessment contract. |
| OSC POC | Day-to-day liaison between OSC and assessment team | Does NOT have to be an OSC employee — can be an RP or consultant. |
| Lead Assessor (CCA) | CCA who oversees and manages the C3PAO Assessment Team | Makes final determination on all practice scores. Holds the formal Lead Assessor designation from Cyber AB. |
| Assessment Team Members | CCPs/CCAs on the C3PAO team | Must be in Active/Good Standing status verifiable on the Marketplace. |
| CQAP | CMMC Quality Assurance Professional | Verifies documentation completeness/accuracy before eMASS upload. Each C3PAO must have at least one. |
1.3 — Templates: Mandatory vs. Not Mandatory
The exam tests which templates are mandatory. Know this table cold.
| Template | Format | Phase | Mandatory? |
|---|---|---|---|
| CMMC Pre-Assessment Form | Excel | 1 | MANDATORY |
| Virtual Assessment Evidence Preparation Template | Excel | 1 | MANDATORY |
| CMMC Assessment Readiness Review (CA-RR) Checklist | 1 | Not Mandatory | |
| C3PAO and Assessor COI Attestation | MS Word | 2 | Not Mandatory |
| CMMC Assessment In-Brief | PowerPoint | 2 | Not Mandatory |
| Daily Checkpoint | PowerPoint | 2 | Not Mandatory |
| Limited Practice Deficiency Correction Worksheet | 2 | MANDATORY | |
| CMMC Assessment Results Form | Excel | 2/3/4 | MANDATORY |
| CMMC Assessment Findings Briefing | PowerPoint | 2 | Not Mandatory (brief-out itself IS required) |
| CMMC Assessment Quality Review Checklist | 1/3 | MANDATORY | |
| Confirmation of Destruction of OSC Data | MS Word | 4 | Not Mandatory (notification IS required) |
1.4 — Corporate Identity & Scoping
Organizational Definitions CAP §1.4.3
- HQ Organization — The legal entity delivering products/services under a DoD contract. May itself be the OSC, or may designate a Host Unit.
- Host Unit — The specific people, procedures, and technology within an HQ org applied to the DoD contract. This is the OSC for assessment purposes.
- Enclave — A set of system resources in the same security domain behind a common security perimeter. An assessment scope can be within an enclave.
- Supporting Organization — External entities that support the Host Unit. Their assets may be in scope, but they do NOT receive a CMMC Certification.
Pre-Assessment Requirements Can Block Assessment
- The OSC must have a valid CAGE code issued by DoD — assessment cannot proceed without it.
- The OSC must be registered in SAM.gov and have a UEI (Unique Entity Identifier).
- An NDA is recommended before proprietary information is shared — though a formal contract may not yet exist.
- Scope disagreements between C3PAO and OSC must be resolved before assessment commences.
- Non-duplication rule: ISO 27001, FedRAMP, or other certifications do NOT grant CMMC credit or status absent DoD published non-duplication policy.
1.5 — Evidence Collection Approach & COI
The Evidence Collection Approach documents how artifacts will be gathered, how interviews will be scheduled, and how tests will be observed — including any virtual collection techniques and associated CUI protection measures.
Evidence: Adequacy vs. Sufficiency High Frequency
- Adequacy — Does the assessment team have the right evidence? (Does this artifact actually demonstrate performance of the CMMC practice?)
- Sufficiency — Does the assessment team have enough of the right evidence? (Does coverage span all in-scope assets, Host Units, and Supporting Orgs?)
- Both must be satisfied for a practice to be scored MET. A gap in either = Evidence Gap.
COI Management CAP §1.5.4
- Lead Assessor is responsible for identifying COIs and documenting them in the Pre-Assessment Plan.
- If a COI cannot be sufficiently mitigated, the C3PAO must not proceed with the assessment.
- All team members must attest (by signature) to an Absence of COI before Phase 2 commences.
- ISO/IEC 17020 governs impartiality requirements for conformity assessments.
1.6 — Readiness Determination
The Lead Assessor makes the readiness recommendation; the C3PAO retains final decision authority. The readiness review does NOT predict whether the OSC will pass — only that both parties are ready to conduct the assessment.
4 Possible Phase 1 Outcomes Know All Four
- Proceed as planned — All conditions satisfied; assessment is a go.
- Replan — Preparedness requirements not met; discrepancies must be resolved before proceeding. C3PAO cannot offer advice on how to improve readiness — this is a CoPC violation.
- Reschedule — Ready but external factors (health issues, disaster, COVID protocols) require a new date.
- Cancel — Insurmountable factors: unmitigable COI, failure to reach contract terms, etc.
Critical prohibition: At no time during the Phase 1 evidence verification or readiness review may the C3PAO or assessment team provide any advice, recommendations, or implementation assistance on how the OSC could improve their evidence or readiness. Doing so is an explicit CoPC violation.
Phase 2 — Conduct the Assessment
Phase 2 begins with the kickoff meeting and is iterative by nature. The Lead Assessor makes final determination on all preliminary recommended findings. The C3PAO holds final interpretation authority on practice scores.
2.1 — Kickoff Meeting
- Convened by the Lead Assessor using the CMMC Assessment In-Brief (or equivalent).
- Attendees: OSC Assessment Official, OSC POC, assessment team, and relevant OSC staff. The OSC's RP/RPO may attend.
- OSC delivers a high-level overview of its cybersecurity program.
- Lead Assessor ensures minutes/summary are documented and retained — including all Q&A.
2.2 — Evidence Collection (Examine / Interview / Test)
Evidence Rules
- Evidence artifacts may not have a 1:1 relationship with practices — multiple artifacts may be required.
- Artifacts must be produced by people who implement, perform, or support the work — not just described by them.
- Policies and procedures must show deployment and adoption by affected OSC personnel — a signed policy alone is not sufficient.
- For interviews: statements are accepted as evidence when provided by people who actually implement, perform, or support the practice.
- For tests: any failed test results in NOT MET for that practice. Observed by the Lead Assessor and team.
Evidence Gaps & Daily Checkpoints
- Evidence gaps = the space between what OSC evidence shows and what the assessment team requires.
- Examples of deficient evidence: incomplete access control lists; affirmations from someone who is not the proper owner; policies lacking endorsement by senior management (unsigned or signed by someone without authority).
- Daily Checkpoint — "Hot wash" meeting each day. OSC may present additional evidence during these sessions; the Lead Assessor decides if it changes scores.
- NOT MET determinations are reported to the Lead Assessor immediately — assessed by any team member but determination confirmed by Lead Assessor.
In-Person Only — 15 Practice Objectives (Cannot Be Virtual)
These 15 objectives MUST be observed by the assessment team in-person, on-premises. This is frequently tested — know the domains they fall under.
| Domain | Practice Objective | What Must Be Observed In-Person |
|---|---|---|
CM | CM.L2-3.4.5[d] | Physical access restrictions associated with system changes |
MA | MA.L2-3.7.2[d] | Personnel used for maintenance are controlled |
MP | MP.L2-3.8.1[c] | Paper media containing CUI is securely stored |
MP | MP.L2-3.8.1[d] | Digital media containing CUI is securely stored |
MP | MP.L2-3.8.4[a] | Media containing CUI is marked with CUI markings |
MP | MP.L2-3.8.4[b] | Media containing CUI is marked with distribution limitations |
PE | PE.L1-3.10.1[b] | Physical access to org systems is limited to authorized individuals |
PE | PE.L1-3.10.1[c] | Physical access to equipment is limited to authorized individuals |
PE | PE.L2-3.10.2[a] | Physical facility is monitored |
PE | PE.L2-3.10.2[d] | Support infrastructure for org systems is monitored |
PE | PE.L1-3.10.3[a] | Visitors are escorted |
PE | PE.L1-3.10.3[b] | Visitor activity is monitored |
PE | PE.L1-3.10.5[b] | Physical access devices are controlled |
PE | PE.L1-3.10.5[c] | Physical access devices are managed |
SC | SC.L2-3.13.12[b] | Collaborative computing devices provide indication of use to present users |
2.3 — Scoring & Limited Practice Deficiency Correction
The Limited Practice Deficiency Correction program is a nuanced mechanism that is heavily tested. Know the eligibility criteria, the ineligibility criteria, and the scoring threshold that triggers it.
Ineligible Practices (Cannot Use Correction Program)
- Practices that could lead to significant exploitation or CUI exfiltration (5-point practices from Appendix P/K)
- Any practice already on the OSC's Self-Assessment Practice Deficiency Tracker (known beforehand)
- Practices that were NOT implemented prior to the current assessment
- Any practice that changes or limits the effectiveness of another practice already scored MET
Eligible for Correction Program (Both Criteria Required)
- The practice WAS implemented but has minor documentation gaps (outdated policy, missing updated signature) — implementation evidence shows it has been in place for a period of time; AND
- Team consensus that fixing it does NOT change or limit the effectiveness of any other MET practice.
- Eligible practices are scored as NOT MET and tracked on the Limited Practice Deficiency Correction Worksheet (Appendix J — mandatory template).
2.4 — Determining Final MET/NOT MET/NA & POA&M Review
The 80% Rule (88/110) Exact Numbers Tested
- After applying Limited Practice Deficiency Correction: if OSC scores fewer than 88/110 MET (<80%) → finding is "Not Achieved" — OSC must correct deficiencies and reapply. No conditional cert.
- If OSC scores 88/110 or more MET (≥80%) → OSC may proceed to either: (a) close Limited Deficiencies within 5 business days for Final Cert, or (b) move remaining deficiencies to a POA&M for Conditional Cert.
- POA&Ms are not allowed for the highest-weighted practices (the 5-point practices from Appendix P).
- POA&M validity period: maximum 180 days from the Assessment Final Recommended Findings Briefing.
A valid POA&M must document: the specific weakness tied to the practice, severity, scope within the environment, proposed mitigation, estimated remediation cost, documented progress, and a risk assessment of the deficiency.
Phase 3 — Report Recommended Assessment Results
The C3PAO and Lead Assessor deliver findings to the OSC, then the CQAP verifies documentation before upload to eMASS. The CQAP verifies the package at the end of both Phase 1 and Phase 3.
| Deliverable | Timeline | Responsibility |
|---|---|---|
| Final Findings Briefing to OSC | End of Phase 2 / beginning of Phase 3 | Lead Assessor; formal brief-out required even if Findings Brief template not used |
| Report submitted to CQAP | NLT 10 business days from Final Findings Briefing | Lead Assessor → C3PAO |
| Upload to CMMC eMASS | NLT 20 business days from Final Findings Briefing | C3PAO designated eMASS account holder |
| Artifact retention | 3 years | C3PAO (notes/records); OSC (hashed artifacts) |
| OSC artifact hashing | Prior to eMASS upload | OSC hashes artifacts; C3PAO reports hash values to eMASS |
| Destruction of OSC proprietary data | At assessment conclusion | C3PAO — all OSC proprietary information must be returned or destroyed. Retaining it past conclusion is a CoPC violation. |
Certification Types After Phase 3
- CMMC L2 Final Certification — All 110 practices MET (or Limited Deficiencies closed). No POA&M outstanding.
- CMMC L2 Conditional Certification — ≥88/110 practices MET; remaining NOT MET items on approved POA&M. OSC must close within 180 days and undergo a POA&M Close-Out Assessment.
- Not Achieved — <88/110 MET. OSC must correct all deficiencies and reapply from scratch.
Assessment Appeals
- If OSC believes there are scoring discrepancies, they can submit an appeal through the Assessment Appeals Process (Appendix R of the CAP).
- The C3PAO official holds final interpretation authority for practice scores during the assessment.
- Appeals of final assessment results go to the Cyber AB — not the C3PAO.
- The C3PAO issuing the Conditional Cert is NOT responsible for conducting the POA&M Close-Out Assessment.
Phase 4 — Close-Out POA&Ms and Assessment
Phase 4 is unique to OSCs with a Conditional Certification. It does NOT apply to OSCs with a Final Certification or those who received a "Not Achieved" result. Knowing when Phase 4 applies is itself a testable point.
Phase 4 Process CAP §4.1
- OSC selects a C3PAO (may be different from the original assessment C3PAO) to conduct the POA&M Close-Out Assessment within 180 days of the Final Recommended Findings Briefing.
- Lead Assessor reviews the updated POA&M with any evidence (observations, interviews, or tests).
- If ALL POA&M items are MET → Lead Assessor recommends CMMC L2 Final Certification → follow Phase 3 steps 3.2.2–3.2.4.
- If ANY POA&M item fails → Lead Assessor recommends OSC NOT receive Final Cert. The Conditional Cert becomes null and void. OSC must correct and reapply.
Criteria for a successful POA&M Close-Out: (1) The practice is now "Fully-Implemented" and scored MET; (2) closing the practice does NOT change/limit effectiveness of any previously MET practice; (3) updated risk assessment reflects removal of the POA&M practice; (4) updated POA&M shows no remaining deficiencies.
SPRS Scoring — Appendix P Reference
Every NOT MET practice deducts a weighted value from the maximum score of 110. Score can go negative. Know the weight tiers and which practices fall into each.
| Weight | Why | Example Practices |
|---|---|---|
| 5 pts | Not implemented = significant network exploitation or CUI exfiltration risk | AC.L1-3.1.1/3.1.2, IA.L1-3.5.1/3.5.2, IA.L2-3.5.3 (MFA), AU.L2-3.3.1, CM.L2-3.4.1/3.4.2, IR.L2-3.6.1/3.6.2, SI.L1-3.14.1/3.14.2/3.14.4, SC.L1-3.13.1/3.13.5, PE.L1-3.10.1, SC.L2-3.13.15, MA.L2-3.7.2 |
| 3 pts | Specific and confined effect — puts CUI on media/system at risk, not entire network | AC.L2-3.1.5, AU.L2-3.3.2, MA.L2-3.7.1/3.7.4, MP.L2-3.8.1/3.8.2/3.8.8, PS.L2-3.9.1, RA.L2-3.11.1, CA.L2-3.12.2, SC.L2-3.13.8, SI.L1-3.14.5/3.14.7 |
| 1 pt | Limited or indirect effect on network security | All remaining derived security requirements not in 5 or 3 categories |
| N/A (special) | CA.L2-3.12.4 (SSP) | Absence of SSP = assessment CANNOT BE COMPLETED due to noncompliance with DFARS 252.204-7012 |
FIPS Encryption Special Rule (SC.L2-3.13.11): If encryption is NOT employed at all → deduct 5 points. If encryption is employed but NOT FIPS-validated → deduct 3 points. This is the only practice with a tiered deduction built in.
Practice Questions · Domain 5 (CAP) — 12 Questions
Q1
The CAP v5.6.1 describes how many phases for a CMMC Level 2 assessment?
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Q2
An OSC initiates contact with a C3PAO on Monday morning. Per the CAP, by when must the C3PAO acknowledge the request and propose an initial coordination call?
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Q3
During Phase 1 readiness review, the Lead Assessor discovers the OSC's system security plan is incomplete and some evidence is not yet available. The Lead Assessor wants to notify the OSC of what evidence would strengthen their readiness. What does the CAP say about this?
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Q4
An OSC's parent company (Acme Heavy Industries) has a defense-focused division (Acme Defense Mission Systems) that performs DoD contract work. A subcontractor cloud provider (All-American Cloud Services) provides IT services to that division. In the CMMC organizational model, what role does All-American Cloud Services play?
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Q5
Which of the following templates is NOT mandatory per the CAP v5.6.1?
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Q6
During a CMMC assessment, an assessor needs to verify that CUI stored on physical paper media is securely stored. The OSC proposes demonstrating this via a live video call tour of the storage area. What does the CAP require?
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Q7
An OSC achieves a final score of 97 out of 110 practices MET. The 13 NOT MET practices are minor documentation gaps, and the Lead Assessor places them on the Limited Practice Deficiency Correction program. The OSC does not resolve them within 5 business days. What happens next?
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Q8
An OSC received a Conditional CMMC L2 Certification 6 months ago. They have successfully implemented all POA&M items and select a new C3PAO to conduct the POA&M Close-Out Assessment. During the review, one POA&M item is found to be MET, but its implementation now limits the effectiveness of a previously MET practice (AC.L1-3.1.1). What is the correct outcome?
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Q9
During a CMMC assessment, the OSC argues that their ISO 27001 certification demonstrates compliance with several CMMC practices and requests that the assessment team give credit for those controls. What does the CAP say?
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Q10
An OSC's CMMC Assessment Results must be uploaded into CMMC eMASS. What are the correct timelines for (a) submitting the report to the CQAP, and (b) completing the eMASS upload?
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Q11
Practice SC.L2-3.13.11 (FIPS-validated encryption) is assessed during a CMMC Level 2 assessment. The OSC uses encryption to protect CUI in transit but the cryptographic module is NOT FIPS-validated. What is the SPRS score impact?
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Q12
During a CMMC assessment, the OSC does not have a System Security Plan (SSP). Practice CA.L2-3.12.4 requires an SSP. What is the correct assessment outcome?
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Domain 6
Scoping
15–20% of Exam
Asset Categories — Know All 6
Scoping is one of the most nuanced areas. Many questions present asset scenarios and ask you to categorize them. Memorize all six asset types, their definitions, and how they affect the assessment scope.
| Asset Type | Definition | In Scope? | Assessment Impact |
|---|---|---|---|
| CUI Assets | Systems/components that process, store, or transmit CUI | Yes — fully in scope | All 110 practices assessed; highest scrutiny |
| Security Protection Assets (SPAs) | Assets that provide security functions protecting CUI assets (firewalls, IDS, IAM systems, logging platforms) | Yes — in scope | Assessed for their protective functions; critical controls apply |
| Contractor Risk Managed Assets (CRMAs) | Assets that can reach CUI assets but are managed to limit risk (e.g., managed network segments) | Partial | Contractor must demonstrate risk management; selected practices apply |
| Specialized Assets | OT/ICS, IoT, government-furnished equipment (GFE), test equipment not designed for standard NIST controls | In scope (documented) | May require documented exceptions; assessed for feasibility of practice implementation |
| Out-of-Scope Assets | Assets with no logical or physical connection to CUI environment and no path to CUI | No | Excluded; must be documented and justified in the SSP |
| External Service Providers (ESPs) | Cloud service providers, MSSPs, or vendors with access to CUI or CUI systems | In scope (inherited or shared) | Must meet applicable CMMC practices; FedRAMP equivalency for cloud |
Cloud & FedRAMP
Cloud is heavily tested. Know when FedRAMP is required and what equivalency means.
- Cloud service providers (CSPs) that process, store, or transmit CUI must be FedRAMP Authorized at a Moderate or higher baseline — OR meet equivalent security requirements as determined by the DoD.
- FedRAMP Moderate baseline aligns with NIST 800-171 and is the standard threshold for CUI in cloud environments.
- SaaS/IaaS/PaaS all fall under the same rule if CUI touches the service.
- Inherited controls from a FedRAMP-authorized CSP still require the OSC to implement customer-responsible controls.
- A contractor cannot claim FedRAMP controls as MET if the CSP's authorization doesn't cover the specific service being used.
Scoping Key Rules
What Drives the Scope
- Data flows: any path CUI can travel defines the boundary.
- Network connectivity: a system connected to a CUI system is in scope unless isolated by a security boundary.
- The SSP defines the boundary — the assessor verifies it is accurate and complete.
- Scoping must be conservative — assessors err toward including ambiguous systems rather than excluding them.
Scoping Gotchas
- A system used for backup of CUI data is a CUI asset — not out of scope.
- A printer connected to the CUI network is a specialized asset — still in scope.
- Email systems that receive CUI from DoD partners are in scope even if CUI is incidental.
- Personnel with access rights to CUI systems are in scope for AT and PS practices.
- A firewall protecting CUI systems is an SPA — still assessed.
Practice Questions · Domain 6
Q16
A contractor uses a commercial email platform hosted in the cloud. Employees occasionally receive technical drawings (CUI) as email attachments from a DoD prime contractor. The cloud email provider does NOT have FedRAMP authorization. What is the MOST accurate scoping determination?
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Q17
A manufacturing company's shop floor uses legacy programmable logic controllers (PLCs) that cannot support modern authentication standards. These PLCs control machinery in a facility that also processes CUI in an adjacent office network. How should these PLCs be categorized?
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All Practice Questions
24 Questions · All Domains
Use this section for a timed run-through. Click each question to expand, select your answer, then check the explanation. Track your score in the bar below.
Domain 1 · Ecosystem
Q1
An RPO has been helping an OSC prepare for their Level 2 CMMC assessment for six months. The OSC now asks the same RPO to conduct the formal certification assessment. What is the correct course of action?
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Q2
Which entity investigates potential Code of Professional Conduct violations against a Certified CMMC Professional?
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Domain 2 · Ethics
Q3
A CCP casually mentions specific findings from an OSC's assessment to colleagues at an industry conference. Which CoPC principle was violated?
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Domain 3 · Governance
Q4
A prime contractor generates technical specifications for a weapon system and shares them with a subcontractor. Which information category BEST describes these reports?
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Q5
A contractor's SPRS score is -147 and hasn't been updated in 18 months. A new DFARS 252.204-7019 contract is being awarded. What is required?
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Q6
Which DFARS clause gives DoD the right to review a contractor's System Security Plan?
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Q7
Under 32 CFR Part 170, which CMMC level requires a Government-led assessment by DCSA?
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Domain 4 · Model
Q8
An assessor reviews firewall rules, interviews the network engineer about segmentation, and attempts access from an untrusted segment. What assessment methods are used, in order?
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Q9
Three of four objectives for a practice are satisfied; the fourth cannot be confirmed. What is the determination?
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Domain 5 · CAP (12 Questions)
Q10
The CAP v5.6.1 describes how many phases for a CMMC Level 2 assessment?
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Q11
An OSC initiates contact with a C3PAO on Monday morning. Per the CAP, by when must the C3PAO acknowledge the request and propose an initial coordination call?
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Q12
During Phase 1 readiness review, the Lead Assessor wants to notify the OSC of what evidence would strengthen their readiness before the assessment begins. What does the CAP say about this?
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Q13
Acme Heavy Industries (parent company) has a defense division, Acme Defense Mission Systems, that performs DoD contract work. A cloud provider, All-American Cloud Services, provides IT services to that division. What is All-American Cloud Services' role in the CMMC organizational model?
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Q14
Which of the following CAP templates is NOT mandatory per Table 1.3?
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Q15
An OSC proposes demonstrating that paper CUI media is securely stored via a live video call tour of the storage area. What does the CAP require?
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Q16
An OSC achieves 97/110 practices MET. The 13 NOT MET practices are minor documentation gaps placed on the Limited Practice Deficiency Correction program. The OSC does not resolve them within 5 business days. What is the outcome?
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Q17
An OSC with a Conditional Certification completes all POA&M items in Phase 4. However, one closed item now limits the effectiveness of a previously MET practice (AC.L1-3.1.1). What is the correct outcome?
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Q18
An OSC argues that their ISO 27001 certification demonstrates compliance with several CMMC practices and requests credit for those controls. What does the CAP say?
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Q19
What are the correct timelines for (a) submitting the assessment report to the CQAP, and (b) uploading to CMMC eMASS — both measured from the Final Findings Briefing?
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Q20
Practice SC.L2-3.13.11 is assessed and the OSC uses encryption to protect CUI in transit, but the cryptographic module is NOT FIPS-validated. What is the SPRS score impact?
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Q21
During a CMMC assessment, the OSC does not have a System Security Plan (SSP). What is the correct assessment outcome for CA.L2-3.12.4?
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Domain 6 · Scoping
Q22
A contractor uses a non-FedRAMP cloud email platform. Employees receive CUI technical drawings as attachments from a DoD prime. What is the scoping determination?
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Q23
Legacy PLCs on a shop floor cannot support modern authentication. They share facility space with an office network that processes CUI. How should the PLCs be categorized?
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Q24
An OSC's Security Protection Asset (SPA) — specifically their SIEM platform — has a known unpatched vulnerability. Which domain's practices are MOST directly applicable to this asset?
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