Free CMMC-CCP Cyber AB Updates

Contractors that handle Covered Defense Information (CDI) are required to report cyber incidents to the Department of Defense within 72 hours of discovery.

Supporting Extracts from Official Content:

DFARS 252.204-7012(c)(1): “When the Contractor discovers a cyber incident that affects a covered contractor information system or the covered defense information residing therein, the Contractor shall conduct a review… and rapidly report the cyber incident to DoD within 72 hours of discovery.”

Why Option C is Correct:

The regulation explicitly specifies 72 hours.

Options A (24 hrs), B (48 hrs), and D (96 hrs) do not align with DFARS requirements.

References (Official CMMC v2.0 Content and Source Documents):

DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting.

CMMC v2.0 Governance – Source Documents list includes DFARS 252.204-7012.

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Under the Cybersecurity Maturity Model Certification (CMMC) 2.0, a Plan of Action (POA) is a critical document that outlines the specific actions a contractor needs to take to remediate cybersecurity deficiencies. While POAs serve as a roadmap for achieving compliance with required controls, the inclusion of certain elements is standardized.

Key Elements of a Plan of Action (POA)

According to the CMMC guidelines and NIST SP 800-171, which underpins many CMMC requirements, a POA typically includes:

Completion Dates: Identifies target deadlines for resolving deficiencies.

Milestones to Measure Progress: Includes interim steps or markers to ensure progress is monitored over time.

Ownership or Accountability: Clearly assigns responsibility for each action item to specific personnel or teams.

What is Generally NOT Part of a POA?

Budget requirements to implement the plan's remediation actions (Option D) are generally not included in a POA. While budgeting is critical for ensuring the plan's success, it is considered a part of the broaderproject management or resource planning process, not the POA itself. This distinction is intentional to keep the POA focused on actionable items rather than resource allocation.

Supporting Reference

NIST SP 800-171A, Appendix D: Provides an overview of POA components, emphasizing the prioritization of corrective actions, responsibility, and measurable outcomes.

CMMC Level 2 Practices (Aligned with NIST SP 800-171): Specifically, the focus is on actions, timelines, and accountability rather than financial planning.

By excluding budget details, the POA remains a tactical document that supports immediate action and compliance tracking, separate from financial considerations.

For a practice to beadequately implementedin aCMMC Level 2 assessment, theresponsible personnel must demonstrate knowledge of deployment, maintenance, and operationof security tools such asantivirus programs. Simply having the tool in place isnot sufficient—there must be evidence that it isproperly configured, updated, and monitoredto protect against threats.

Step-by-Step Breakdown:✅1. Relevant CMMC and NIST SP 800-171 Requirements

CMMC Level 2 aligns with NIST SP 800-171, which includes:

Requirement 3.14.5 (System and Information Integrity - SI-3):

"Employautomatedmechanisms toidentify, report, and correctsystem flaws in a timely manner."

Requirement 3.14.6 (SI-3(2)):

"Employautomated toolsto detect and prevent malware execution."

These requirements imply that theperson responsible for antivirus must understand how it is deployed and maintainedto ensure compliance.

✅2. Why the Team Member’s Knowledge is Insufficient

Antivirus tools requireregular updates,configuration adjustments, andmonitoringto function properly.

The responsible team member must:

Knowhow the antivirus was deployedacross systems.

Be able toconfirm updates, logs, and alerts are monitored.

Understand how torespond to malware detectionsand failures.

If the team member lacks this knowledge, assessors maydetermine the practice is not fully implemented.

✅3. Why the Other Answer Choices Are Incorrect:

(A) Yes, the antivirus program is available, so it is sufficient.❌

Incorrect:Just having antivirus softwareinstalleddoes not prove compliance. It must bemanaged and maintained.

(B) Yes, antivirus programs are automated to run independently.❌

Incorrect:While automation helps, security toolsrequire oversight, updates, and configuration.

(D) No, the team member's interview answers about deployment and maintenance are insufficient.❌

Partially correct but incomplete:Themain issueis that the team membermust have sufficient knowledge, not just that their answers are weak.

Final Validation from CMMC Documentation:TheCMMC Assessment Guide for SI-3 and SI-3(2)states that personnel mustunderstand the function, deployment, and maintenance of security toolsto ensure proper implementation.

Thus, the correct answer is:

Understanding Specialized Assets in a CMMC Self-AssessmentDuringCMMC Level 1 Self-Assessments, organizations must classify theirassetsin theSystem Security Plan (SSP).

Operational Technology (OT)includesmachine controllers, industrial control systems (ICS), and assembly machines.

Thesesystems control physical processesin manufacturing, energy, and industrial environments.

OT assets are distinct from traditional IT systemsbecause they haveunique security considerations(e.g., real-time control, legacy system constraints).

Specialized Asset Type: Operational Technology (OT)

A. IoT (Internet of Things) → Incorrect

IoT devicesinclude smart home systems, connected sensors, and networked appliances, butmachine controllers and assembly machines fall under OT, not IoT.

B. Restricted IS → Incorrect

Restricted Information Systems (IS) refer to classified or highly controlled systems, whichdoes not apply to standard industrial machines.

C. Test Equipment → Incorrect

Test equipment includes diagnostic tools or measurement devicesused forquality assurance, not industrial machine controllers.

D. Operational Technology → Correct

Machine controllers and assembly machinesare part ofindustrial automation and control systems, which are classified asOperational Technology (OT).

Why is the Correct Answer "D. Operational Technology"?

CMMC Scoping Guidance for Level 1 & Level 2 Assessments

DefinesOperational Technology (OT) as a category of Specialized Assetsthat requirespecific security considerations.

NIST SP 800-82 (Guide to Industrial Control Systems Security)

Identifiesmachine controllers and assembly machinesas part ofOperational Technology (OT).

CMMC 2.0 Asset Classification Guidelines

Specifies thatOT systems should be documented separately in an organization's SSP.

CMMC 2.0 References Supporting This Answer: