CMMC RPO vs a C3PAO: Understanding Their Roles in Compliance

CMMC RPO vs a C3PAO: Understanding Their Roles in Compliance

With increasingly sophisticated cyberattacks becoming a growing national security concern, the Department of Defense (DoD) has introduced the Cybersecurity Maturity Model Certification (CMMC) to provide standardized security guidelines for organizations within the defense industrial base (DIB). However, CMMC compliance is a complex undertaking that generally involves the assistance of outside organizations for consulting, preparation, and assessment purposes. Two of the biggest players in the CMMC certification process are Registered Provider Organizations (RPOs) and Certified Third-Party Assessment Organizations (C3PAOs). Of course, this may leave you wondering what these organizations do, what role they play in the CMMC certification process, and when you’ll need to partner with each one. Keep reading to learn more about these organizations and the role they play in CMMC compliance.

What is an RPO (Registered Provider Organization)?

CMMC RPOs are organizations registered with the CMMC Accreditation Body (The Cyber-AB) that provide government contractors with pre-assessment consulting services. Their primary role is to help Organizations Seeking Certification (OSC) understand and prepare for CMMC by conducting gap analyses, identifying necessary cybersecurity practices, and developing policies, procedures, and technical controls designed to help OSCs achieve CMMC compliance. While RPOs are authorized to provide advisory and security support services to organizations preparing for CMMC certification, they cannot conduct official CMMC assessments or certifications and cannot act as a C3PAO.

The key functions of an RPO include:

• Providing Training and Education to Help OSCs Understand CMMC
• Conducting Gap Assessments to Identify Security Deficiencies
• Implementing Security Controls and Remediation Efforts
• Providing Guidance on NIST 800-171 Compliance
• Ensuring Readiness for Third-Party CMMC Assessment
• As Well as providing Continuous Monitoring Services and Regular Updates to Cybersecurity Practices to Help OSCs Maintain Compliance

Working with an RPO takes time, as it may take an OSC 6-24 months to prepare for CMMC assessment depending on the organization’s existing cybersecurity maturity. Have you started your journey? Agile IT has helped over 2,000 organizations navigate their own unique requirements in a secure Microsoft Cloud environment.

What is a C3PAO (CMMC Third-Party Assessment Organization)?

Alternatively, while an RPO prepares OSCs for assessment, the primary role of the C3PAO is to provide the actual CMMC certification assessment. While RPOs work closely with the OSC to help them develop a strong cybersecurity posture, a C3PAO must maintain its distance to provide an objective evaluation of the OSC’s compliance. For this reason, C3PAOs must not provide both assessment and advisement services to the same company even if they are also a certified RPO. C3PAOs are accredited by the Cyber-AB to evaluate an organization’s security practices and infrastructure against the CMMC framework to determine if they meet the required CMMC cybersecurity standards.

Key responsibilities of C3PAOs include:

• Conducting Formal CMMC Level 2 Audits
• Evaluating Implemented Security Controls for Compliance
• And Issuing CMMC Findings and Certification Decisions.

The CMMC assessment process by a C3PAO typically takes 4-8 weeks to complete.

Why an RPO and a C3PAO Should Not Be the Same Company

In some instances, a company may be accredited by the Cyber-AB to provide both RPO and C3PAO services to organizations in the defense industrial base seeking CMMC certification. However, even if a third-party organization is authorized to provide both services, they cannot extend both services (assessment and advisement) to the same company. Yet, you may find yourself wondering why this is the case. Surely it would be easier if the RPO you’ve already been working with could provide your CMMC assessment, right? However, several risks can come from doing this. A few reasons why your RPO and C3PAO cannot be the same company include:

• Conflict of Interest Concerns: Perhaps the biggest reason an RPO and a C3PAO should not be the same company is that this creates a potential conflict of interest. The fact is that an RPO prepares organizations for CMMC certification, while a C3PAO is supposed to independently evaluate them. However, a C3PAO cannot provide an impartial evaluation of an organization whose cybersecurity posture they helped establish.
• Separation of Duties: Working with different companies for RPO and C3PAO services is then critical as it ensures impartial assessments and prevents bias in CMMC certification.
• Best practice: To ensure impartiality in the CMMC assessment process, OSCs should then:
  • Work with an RPO that can assist with both the compliance preparation process and your remediation needs. An RPO that offers CMMC Compliance Services and CMMC Managed Services for Optimal Cloud Security can significantly assist in your journey continuously meeting compliance.
  • Once you’ve worked with an RPO and are ready for assessment, you can then engage a C3PAO for the official certification process.

Best Practices for Working with an RPO and a C3PAO

Choosing the right third-party organizations is essential in helping you achieve and maintain CMMC certification. To ensure this process goes smoothly and to avoid conflict of interest, follow these best practices when working with an RPO and C3PAO.

1. Start with an RPO to assess your current compliance posture with a gap analysis and guidance.
2. Develop and implement a remediation plan based on the RPO’s findings. This is your Plan of Action and Milestones (POA&M) that addresses deficiencies. Note: Your RPO can help!.
3. Ensure all required security controls are in place, your System Security Plan (SSP) documentation is complete, and internal self-assessments indicate readiness before engaging a C3PAO.
4. Schedule the official CMMC assessment with a C3PAO once prepared.
5. Use CMMC certification findings to maintain continuous compliance. Certification is not a one-time event; it requires ongoing compliance and maintenance to prepare for reassessments, required every 3 years.

Need Help Preparing for CMMC? Work with Agile IT’s RPO Services Today

For DoD contractors that handle CUI, achieving and maintaining CMMC compliance is essential to protect national security and meet the terms of their contract. Yet, the prospect of achieving CMMC certification and facing a CMMC assessment can seem daunting, and you may not be sure where to start or how you’ll know when you’re ready to contact a C3PAO to start the certification process.

If this is the situation you currently find yourself in, consider contacting Agile IT today to learn about our AgileThrive RPO service. The fact is that navigating the complexities of CMMC shouldn’t hold your business back, and our experienced team is here to provide the expert guidance you need to protect your contracts, win new opportunities, and confidently pass audits. We can evaluate your compliance posture and help you prepare for CMMC certification to ensure you’re ready for assessment.

Contact us today to learn more about our services and how our team can help you face CMMC assessment with confidence.