CMMC CMMC-CCA Cyber AB Study Notes

In CMMC scoping, only assets that process, store, or transmit CUI (CUI Assets) or that can access them (Security Protection, Contractor Risk Managed, Specialized Assets) are in-scope. Since the SCADA system is firewalled off and does not handle CUI, it does not fall under CUI Asset classification and is considered Out-of-Scope.

Exact extracts:

“CUI Assets are those that process, store, or transmit CUI.”

“Assets that do not process, store, or transmit CUI and have no connectivity to CUI Assets are considered Out-of-Scope.”

“Specialized Assets… are only in-scope if they process, store, or transmit CUI.”

Why the other options are incorrect:

A: Inclusion requires processing/storing/transmitting CUI.

C: OSC cannot arbitrarily bring unrelated systems into scope; CUI relevance governs scope.

D: Not all Specialized Assets are in-scope; only those with CUI interaction are.

If an asset processes or generates CUI, it is a CUI Asset by definition, regardless of whether it is also part of a test lab or claimed as a Specialized Asset. Specialized Asset handling applies only when the asset does not process, store, or transmit CUI. Since the workstation outputs CUI, it must be assessed fully against CMMC practices.

Exact extracts:

“CUI Assets are those that process, store, or transmit CUI.”

“Specialized Assets… do not process, store, or transmit CUI.”

“If a Specialized Asset processes CUI, it must be categorized as a CUI Asset and is assessed against all applicable practices.”

Why the other options are incorrect:

B: The issue is not with the SSP practice; it is with misclassification of an asset.

C/D: Risk-based treatment applies only to Specialized Assets without CUI, which is not the case here.

The negative finding is that the OSC permits an uncertified external security provider to access the OSC’s internal network. This introduces unmanaged risk to the CUI environment. CMMC requires the OSC to control and monitor external service provider access. The storage of recordings externally is not inherently noncompliant if properly controlled, and video monitoring is a valid method of meeting PE.L2-3.10.2. The key failure is giving unmanaged third-party access.

Exact extracts:

“Monitor physical facility to detect and respond to physical security incidents.” (PE.L2-3.10.2)

“Assessment Objectives … Determine if: monitoring is performed; unauthorized physical access is detected and responded to.”

“External service providers that connect into the OSC network are considered in-scope and must meet CMMC requirements or have equivalent authorization (e.g., FedRAMP).”

Why other options are incorrect:

A: Requirement does not mandate monitoring of both public and private areas.

C: Video surveillance is an acceptable facility monitoring method when properly implemented.

D: External storage can be acceptable if contractual safeguards and compliance are in place.

CMMC Level 2 requires CSPs that process, store, or transmit CUI to meet FedRAMP Moderate (or equivalent) authorization, not FedRAMP High. FedRAMP High is not a CMMC requirement but may be required by contract or specific agencies.

Exact Extracts:

DoD CMMC Scoping Guide: “External Cloud Service Providers must meet FedRAMP Moderate equivalency when storing, processing, or transmitting CUI.”

CMMC Assessment Guide: “The baseline requirement for CUI in cloud environments is FedRAMP Moderate; higher levels may be contractually required.”

Why other options are not correct:

A: Equivalency is allowed, but only to FedRAMP Moderate level.

C/D: Incorrect, because CMMC Level 2 does not mandate FedRAMP High.