Cyber AB CMMC-CCP Online Access

Understanding the False Claims Act (FCA) and Whistleblower ProtectionsTheFalse Claims Act (FCA)(31 U.S.C. §§ 3729–3733) is aU.S. federal lawthat allowswhistleblowers (also known as "relators")to sue on behalf of the federal government if they believe a company issubmitting fraudulent claimsfor government funds.

The FCA includes a"qui tam" provision, which:

✅Allows private individuals to file lawsuits on behalf of the U.S. government.

✅Provides financial rewards to whistleblowersif the lawsuit results in recovered funds.

✅Protects whistleblowers from employer retaliation.

In the context ofCMMC and cybersecurity compliance, theFCA has been used to hold companies accountableformisrepresenting their cybersecurity compliancewhen working with federal contracts.

For example:

If a companyfalsely claimscompliance withCMMC, NIST SP 800-171, or DFARS 252.204-7012butfails to meet security requirements, it could beliable under the FCA.

TheDepartment of Justice (DOJ)has pursued cases under theCyber-Fraud Initiative, using theFCA against defense contractorsfor cybersecurity noncompliance.

Thus, the correct answer isC. False Claims Actbecause it specifically allows whistleblowers tosue on behalf of the federal government.

A. NIST SP 800-53❌Incorrect.NIST SP 800-53provides security controls for federal agencies butdoes notcontain whistleblower provisions.

B. NIST SP 800-171❌Incorrect.NIST SP 800-171outlines security requirements for protectingCUI, but itdoes not have legal mechanismsfor whistleblower lawsuits.

D. Code of Professional Conduct❌Incorrect. TheCMMC Code of Professional Conductapplies toC3PAOs and assessorsbut doesnot provide a legal basis for whistleblower lawsuits.

Why the Other Answers Are Incorrect

False Claims Act (31 U.S.C. §§ 3729–3733)– Establishes whistleblower protections and qui tam lawsuits.

DOJ Cyber-Fraud Initiative– Uses the FCA to enforce cybersecurity compliance in government contracts.

DFARS 252.204-7012 & CMMC– Require accurate reporting of cybersecurity compliance, which can lead to FCA violations if misrepresented.

CMMC Official ReferencesThus,option C (False Claims Act) is the correct answeras per official legal guidance.

Understanding IA.L1-3.5.1 (Identification and Authentication Requirements)TheCMMC 2.0 Level 1practiceIA.L1-3.5.1aligns withNIST SP 800-171, Requirement 3.5.1, which mandates that organizationsidentify system users, processes acting on behalf of users, and devicesto ensure proper access control.

To comply with this requirement, anOrganization Seeking Certification (OSC)must maintain documentation that demonstrates:

A unique identifier (username) for each system user

Mapping of system accounts to specific individuals

Identification of devices and automated processes that access systems

This documentation directly satisfies IA.L1-3.5.1because it showshow system users are uniquely identified and linked to specific accountswithin the environment.

Alist of users and their assigned accountsconfirms that the organization has a structured method oftracking access and authentication.

It allows auditors to verify thateach user has a distinct identityand that access control mechanisms are properly applied.

A. Procedures for implementing access control lists (Incorrect)

While access control lists (ACLs) are relevant for authorization, they do notidentify users or devicesspecifically, making them insufficient as primary evidence for IA.L1-3.5.1.

B. List of unauthorized users that identifies their identities and roles (Incorrect)

Identifying unauthorized users does not fulfill the requirement of trackingauthorizedusers, devices, and processes.

D. Physical access policy stating "All non-employees must wear a special visitor pass or be escorted" (Incorrect)

This pertains tophysical security, not system-baseduser identification and authentication.

The correct answer isC. User names associated with system accounts assigned to those individuals, as thisdirectly satisfies the identification requirement of IA.L1-3.5.1.

In the context of the Cybersecurity Maturity Model Certification (CMMC) 2.0, the remediation review process is a critical phase where identified deficiencies from an initial assessment are addressed. The Lead Assessor, representing a Certified Third-Party Assessment Organization (C3PAO), plays a pivotal role in this process.

Role of the Lead Assessor in Remediation Reviews:

Validation of Remediation Efforts:

Objective:Ensure that the Organization Seeking Certification (OSC) has effectively addressed and corrected all deficiencies identified during the initial assessment.

Process:The Lead Assessor reviews the evidence provided by the OSC to confirm that each previously unmet practice now meets the required standards. This involves examining updated policies, procedures, system configurations, and other relevant artifacts.

Delta Assessment Remediation Package Submission:

Definition:A delta assessment focuses on evaluating only the components or practices that were previously found non-compliant or deficient.

Responsibility:After validating the remediation efforts, the Lead Assessor compiles a remediation package that includes:

Detailed documentation of the deficiencies identified in the initial assessment.

Evidence of the corrective actions taken by the OSC.

Findings from the reassessment of the remediated practices.

Internal Quality Review:This remediation package is then submitted for the C3PAO's internal quality review process. The purpose of this review is to ensure the accuracy, completeness, and consistency of the assessment findings before finalizing the certification decision.

Rationale for Selecting Answer C:

Alignment with CMMC Assessment Process:The submission of a delta assessment remediation package for internal quality review is a standard procedure outlined in the CMMC Assessment Process. This step ensures that all remediated items are thoroughly evaluated and validated, maintaining the integrity of the certification process.

Clarification of Incorrect Options:

Option A:"Help OSC to complete planned remediation activities."

The Lead Assessor's role is to assess and validate the OSC's compliance, not to assist in the implementation or completion of remediation activities. Providing such assistance could lead to a conflict of interest and compromise the objectivity of the assessment.

Option B:"Plan two consecutive remediation reviews for an OSC."

The standard process involves conducting a single remediation review after the OSC has addressed the identified deficiencies. Planning multiple consecutive remediation reviews is not a typical practice and could indicate a lack of proper remediation planning by the OSC.

Option D:"Validate that practices previously listed on the POA&M have been removed on an updated Risk Assessment."

While it's essential to ensure that deficiencies are addressed, the primary focus of the Lead Assessor during a remediation review is to validate the implementation of remediated practices. Updating the Risk Assessment is the responsibility of the OSC's internal risk management team, not the Lead Assessor.

The correct answer isA. CMMC Assessment Reporting Requirementsbecause this document specifically outlines thestructured processthat Certified Third-Party Assessment Organizations (C3PAOs) must follow when conducting and reporting CMMC assessments.

Understanding the CMMC Assessment Process

TheLead Assessorbriefs the team on theassessment requirementsand theevaluation criteriabefore the assessment begins.

Throughout the assessment,findings summaries, practice ratings, and level recommendationsare documented and reported.

These findings are internally reviewed by theC3PAObefore they are formally submitted forquality review and final rating approval.

Key Document Stipulating Reporting Requirements: CMMC Assessment Reporting Requirements

This documentspecifically details how assessments must be reportedwithin theCMMC ecosystem.

It describes the structured process for assessment submission, internalC3PAO reviews, andquality checks by the CMMC-ABbefore an organization can receive a final certification decision.

It ensures thatresults are consistent, transparent, and aligned with DoD cybersecurity compliance expectations.

Why Other Options Are Incorrect:

B. DFARS 52.204-21 Assessment Reporting Requirements

This clause only specifiesbasic safeguardingof Federal Contract Information (FCI) but doesnotdictate the reporting process for CMMC assessments.

C. NIST SP 800-171 Revision 2 Assessment Reporting Requirements

WhileNIST SP 800-171 Rev. 2outlines security controls, it doesnotdefine how CMMC assessments must be conducted and reported.

D. DFARS Clause 252.204-7012 Assessment Reporting Requirements

This DFARS clause focuses onincident reportingandcyber incident response requirementsbut does not detail theCMMC assessment reporting process.

CMMC Assessment Reporting Requirements, issued byThe Cyber ABandDoD, governs how C3PAOs must report assessment results.

CMMC Assessment Process (CAP)also outlines reporting workflows for certification.

Step-by-Step Breakdown:Official Reference:Thus, theCMMC Assessment Reporting Requirementsdocument is the authoritative source that dictates the reporting procedures for CMMC assessments.