Complete CMMC-CCA Cyber AB Materials

The Physical and Environmental Protection (PE) Policy is the governing artifact that describes how physical access to facilities and environments is managed and controlled. While the SSP provides a system-wide overview, and access lists provide details of who is authorized, it is the PE Policy that explicitly documents the physical access control measures required under CMMC.

Extract from PE.L2-3.10.1:

“Organizations must develop, document, and disseminate physical and environmental protection policies that govern how access to buildings and systems containing CUI is limited to authorized individuals.”

The OSC (Organization Seeking Certification) is always responsible for meeting CMMC requirements, regardless of what responsibilities are shared or outsourced to an ESP. ESPs can provide inherited practices (e.g., FedRAMP Moderate for cloud CUI), but the OSC remains accountable for compliance under government mandates.

Exact Extracts:

CMMC Assessment Guide: “The OSC is the entity being assessed. While an ESP may provide inherited practices, the OSC retains ultimate responsibility for compliance.”

Scoping Guide: “External Service Providers may meet requirements on behalf of the OSC; however, it is the OSC that is assessed and must demonstrate sufficiency of evidence.”

Why other options are not correct:

A: Incorrect — ESPs that process CUI must meet FedRAMP Moderate equivalency, even if not directly assessed for CMMC.

B: While true, factoring documentation does not override that OSC remains accountable.

C: ESPs are not assessed at the same time as the OSC; only the OSC receives certification.

The Physical Protection (PE) practices require that visitors to facilities where CUI is processed must be escorted at all times by an authorized individual. Familiarity or long-term knowledge of the visitor does not remove the requirement.

Extract from PE.L2-3.10.3:

“Escort visitors and monitor visitor activity to ensure they do not access areas or information for which they are not authorized.”

Thus, the correct action is for the contact person (the engineer’s point of contact) to escort the engineer during the entire maintenance activity.

The CMMC Scoping Guidance specifies that Contractor Risk Managed Assets must:

Be documented in the asset inventory,

Be governed by the organization’s own risk-based policies and procedures,

Be included in the system boundary/network diagram.

Extract:

“Contractor Risk Managed Assets are those managed according to the OSC’s risk-based policies and procedures. They must be documented in the asset inventory and represented in the system boundary.”

Thus, option C is the best answer.