Cyber AB CMMC-CCA Online Access

Under AT.L2-3.2.3 (Security Awareness Training) and AT.L2-3.2.2 (Insider Threat Training), insider threat awareness training must equip personnel to recognize and report indicators of insider threat activity. Training must focus on organizational processes for reporting suspicious behavior, not just awareness of famous cases or punitive systems. The ability to act and report appropriately is the most critical element.

Exact extracts:

“Training includes recognition of potential indicators of insider threat activity and the organizational processes for reporting suspicious activity.”

“Assessment Objectives … Determine if: insider threat training includes reporting mechanisms.”

“Case studies may be used for context, but training must include clear reporting procedures.”

Expanded explanation:

Insider threat programs under DoD guidance (e.g., NISPOM, CMMC) emphasize:

Awareness of behaviors that may indicate insider threat activity.

Reporting mechanisms — employees must know exactly how to act if they identify an issue.

Procedures for escalation and protection of CUI.

Without reporting procedures, insider threat training is incomplete.

Why other options are incorrect:

A: Bounty systems are not sanctioned practices and could create a hostile work environment.

B: Risk-ranking individuals could be discriminatory and is not a CMMC requirement.

C: Case studies may supplement training but are not sufficient by themselves.

Both the CSP’s cloud environment and the OSC’s on-premises network/workstations are in-scope because CUI is stored in the cloud but also accessed and transmitted by OSC assets. The cloud vendor’s internal employee network is not in-scope because only the customer-facing FedRAMP environment is within the assessment boundary.

Exact extracts:

“CUI Assets include any OSC asset that stores, processes, or transmits CUI.”

“External service providers are in-scope if their services process, store, or transmit CUI on behalf of the OSC.”

“The OSC’s endpoints and local infrastructure that access CUI are also in-scope.”

Why the other options are incorrect:

A: Cloud environment only is incomplete; OSC workstations also access and transmit CUI.

B: OSC network only ignores the fact that CUI is stored in the cloud.

D: The cloud vendor’s internal employee network is not in-scope.

The Scoping Guidance for Specialized Assets allows exclusion of assets when they are physically and logically isolated from the CMMC assessment boundary and do not process, store, or transmit CUI.

Extract from CMMC Scoping Guidance:

“Specialized Assets may be designated as out-of-scope if they are physically or logically separated from CUI assets, or if they are inherently unable to process, store, or transmit CUI.”

The camera system in this case does not interact with CUI and is fully isolated, making exclusion appropriate.

The OSC is responsible for identifying and declaring where CUI is processed, stored, or transmitted. A Certified CMMC Assessor (CCA) may verify boundaries, examine evidence, and confirm monitoring or control practices, but cannot independently determine if a physically separated asset contains CUI. That determination is the responsibility of the OSC, not the assessor.

Exact extracts:

“The OSC is responsible for identifying CUI assets.”

“Assessors verify and validate the OSC’s identification, but do not independently declare or determine the presence of CUI.”

“Assessors are permitted to examine boundary protections, monitoring mechanisms, and internal boundary controls.”

Why the other options are allowed:

A: Assessors are required to verify internal system boundaries.

C: Assessors must confirm that external system boundaries are clearly defined.

D: Assessors must examine evidence of communication monitoring.

References (CCA documents / Study Guide):

CMMC Assessment Guide – Level 2, Assessor Roles and Responsibilities.

CMMC Code of Professional Conduct (OSC retains CUI ownership; assessors validate but cannot declare CUI).