Free Access Cyber AB CMMC-CCA New Release

The Physical Protection (PE) Domain requires implementation of physical access controls to prevent unauthorized access to CUI systems. Simply trusting employees or sending communications is not sufficient. However, if the server is located inside a secondary restricted room that only the IT team can access, then adequate physical protection controls are still in place.

Extract from PE.L2-3.10.x (Physical Protection Practices):

“Organizations must limit physical access to systems, equipment, and environments that process, store, or transmit CUI to authorized individuals only.”

Thus, placing the server within an additional restricted access-controlled room ensures compliance, even if the outer door is propped open for cooling.

MA.L2-3.7.1 (Perform Maintenance) requires that maintenance activities and risks associated with outdated or unsupported systems be managed. Unsupported systems create a security risk if not mitigated, particularly when they process CUI.

Extract:

“Maintenance must be performed and documented to ensure continued secure operation. When systems cannot be updated or patched due to technical limitations, the OSC must implement and document risk mitigation strategies.”

Because the OSC has not demonstrated risk management for the outdated OT system, the practice is NOT MET.

Applicable Requirement: PE.L2-3.10.1 — “Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.”

Why D is Correct: Documented procedures describing physical access restrictions (badge policies, visitor management, locked server rooms, guard post orders) serve as primary evidence that access is managed and enforced. Assessors can then corroborate via interviews and observation.

Why Other Options Are Insufficient:

A (VPN configuration): Relates to remote logical access, not physical security.

B (Switch configs): Technical network controls, not physical access.

C (Architecture drawings): Show logical/system design, not physical entry restrictions.

References (CCA Official Sources):

NIST SP 800-171 Rev. 2 — PE.L2-3.10.1

NIST SP 800-171A — PE.L2-3.10.1 Assessment Objectives

CMMC Assessment Guide – Level 2 — Physical Protection Evidence Guidance

CMMC scoping focuses on assets that process, store, transmit, or protect CUI. A smoke detector connected to the OSC network is an IoT device with no impact on CUI, so it is considered Out-of-Scope. The other items (data centers used by the OSC, MSP SIEM tools, and MSP offices handling OSC management) all directly affect the OSC’s CUI environment and therefore fall within scope.

Exact extracts:

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

“Security Protection Assets are those that provide security functions for CUI Assets.”

“External Service Providers (e.g., MSPs, data centers, SIEMs) that support CUI Assets are in-scope.”

“Assets that cannot affect the confidentiality of CUI (e.g., unrelated IoT devices) are considered Out-of-Scope.”

Expanded explanation:

Data centers (A): If OSC CUI is stored or processed there, they are in-scope.

SIEM tools (C): Provide security monitoring of OSC networks — a clear Security Protection Asset.

MSP office (D): MSPs providing services that affect CUI are in-scope, including their management locations.

Smoke detector (B): Despite being network-connected, it does not interact with CUI or provide protective functions; it is explicitly out-of-scope.

Why the other options are in scope:

They either process, protect, or manage CUI directly.

Excluding them would improperly narrow the assessment boundary.