Pearson CMMC-CCP New Attempt

1. Understanding Basic Safeguarding Requirements for FCI in CMMC Level 1

Federal Contract Information (FCI) is defined as information provided by or generated for the government under a contract that isnot intended for public release.

CMMCLevel 1is designed to ensurebasic safeguardingof FCI, aligning with15 security requirementsfound inFAR 52.204-21 (Basic Safeguarding of Covered Contractor Information Systems).

Contractors handlingonly FCImust meetCMMC Level 1, which alignsdirectlywith the safeguarding requirements set inFAR 52.204-21.

2. FAR 52.204-21 and Its Role in CMMC Level 1 Compliance

FAR 52.204-21establishes the baseline cybersecurity controls that contractors must implement to protectFCI.

The15 basic safeguarding requirementsinclude:

Limiting information accessto authorized users.

Identifying and authenticating usersbefore allowing system access.

Protecting transmitted FCIfrom unauthorized disclosure.

Monitoring and controlling connectionsto external systems.

Applying boundary protectionand cybersecurity measures.

Sanitizing mediabefore disposal.

Updating security configurationsto reduce vulnerabilities.

Providing physical securityprotections.

Controlling physical accessto systems that process FCI.

Enforcing multi-factor authentication (MFA) where applicable.

Patching vulnerabilitiesin software and hardware.

Limiting the use of removable media.

Creating and retaining system audit logs.

Performing risk-based security assessments.

Developing an incident response plan.

These 15 practices form thefoundationof CMMCLevel 1 Self-Assessment, ensuring contractorsmeet minimum cybersecurity expectationsfor handling FCI.

3. Why the Other Options Are Incorrect

B. 22 CFR 120-130:

This refers toInternational Traffic in Arms Regulations (ITAR), which controls the export of defense-related articles and services,notFCI safeguarding requirements.

C. DFARS 252.204-7011:

This clause refers toalternative line item structuresand does not pertain to cybersecurity or safeguarding FCI.

D. DFARS 252.204-7021:

This clause enforcesCMMC requirementsbut doesnot definebasic safeguarding controls. It requires compliance with CMMC but does not specify the foundational requirements (which come fromFAR 52.204-21for Level 1).

4. Official CMMC 2.0 Reference & Study Guide Alignment

TheCMMC 2.0 model documentationconfirms that Level 1 is focused on the15 practices from FAR 52.204-21.

TheDoD’s official CMMC Assessment Guidefor Level 1 explicitly states that meeting FAR 52.204-21 is therequirement for passing a Level 1 Self-Assessment.

TheCMMC 2.0 Scoping Guideclarifies that contractors handling onlyFCIand seekingLevel 1 certificationmust implementonly FAR 52.204-21security controls.

Final Confirmation:The correct answer isA. FAR 52.204-21, as it directly governs the basic safeguarding ofFCIand is the foundational requirement for aLevel 1 Self-Assessmentin CMMC 2.0.

In the context of a Cybersecurity Maturity Model Certification (CMMC) Level 2 Assessment, specific practices must be evaluated to ensure compliance with established security requirements. One such practice is AC.L2-3.1.19, which mandates the encryption of Controlled Unclassified Information (CUI) on mobile devices and mobile computing platforms.

Step-by-Step Explanation:

Requirement Overview:

Practice AC.L2-3.1.19 requires organizations to "Encrypt CUI on mobile devices and mobile computing platforms." This ensures that any CUI accessed, stored, or transmitted via mobile devices is protected through encryption, mitigating risks associated with data breaches or unauthorized access.

Assessment of Provided Evidence:

During the assessment, the Organization Seeking Certification (OSC) provided an inventory list encompassing servers, workstations, and network devices. Notably, this list lacks any mention of mobile devices or mobile computing platforms.

Implications of the Omission:

The absence of mobile devices in the inventory suggests that the OSC may not have accounted for all assets that process, store, or transmit CUI. Without a comprehensive inventory that includes mobile devices, it's challenging to verify whether the OSC has implemented the necessary encryption measures for CUI on these platforms.

Assessment Determination:

Given the incomplete inventory, the evidence is insufficient to make a definitive scoring determination for practice AC.L2-3.1.19. The OSC must provide a detailed inventory that encompasses all relevant devices, including mobile devices and computing platforms, to demonstrate compliance with the encryption requirements for CUI.

Understanding Who Must Perform Tests in a CMMC AssessmentDuring aCMMC Level 2 Assessment, assessorsmust observe operational activities and security practicesto verify compliance. This process involves:

✔Testing security controls and proceduresas part of the assessment.

✔Observation of standard work practicesto ensure controls are properly implemented.

✔Using operational personnel (OSC employees) who regularly perform the taskto ensure realistic assessment conditions.

Operational personnel (OSC employees) must conduct the actual work while assessors observe.

Certified CMMC Professionals (CCPs) or Lead Assessorsoversee and document the testing process.

Who Performs Tests?

A. OSC personnel who normally perform that work as the CCP observes → Correct

CMMC assessments require actual users (OSC personnel) to perform their regular duties while assessors observeto verify security practices.

B. Military personnel and the CCP and/or Lead Assessor to test the adequacy of the written procedure(s) → Incorrect

Military personnel are not responsible for testing contractor security controls.

Assessors observe and evaluate but do not perform testing themselves.

C. Military personnel assigned to the contractor for that contract to ensure the confidentiality of the CUI → Incorrect

Military personnel do not perform the testing.

The contractor (OSC) is responsible for implementing and demonstrating security controls.

D. OSC personnel who do not ordinarily perform that work to evaluate the accuracy of the written procedure(s) → Incorrect

Personnel unfamiliar with the job should not be used for testing.

Theassessment must reflect real-world conditions, so theactual employees who perform the work must demonstrate the process.

Why is the Correct Answer "A" (OSC personnel who normally perform that work as the CCP observes)?

CMMC Assessment Process (CAP) Document

Specifies thatassessments must observe real operational activities to determine compliance.

CMMC-AB Assessment Methodology

Requirestesting of security controls in a realistic operational environment, meaning actual OSC personnel must perform the tasks.

NIST SP 800-171A (Assessment Procedures for NIST SP 800-171)

Specifies thatinterviews and observations should be conducted with personnel who regularly perform the work.

In Phase 1 (Planning) of the CMMC Assessment Process, the Lead Assessor is responsible for managing the team and identifying conflicts of interest. Assessment team members must also disclose potential conflicts.

Supporting Extracts from Official Content:

CAP v2.0, Planning (§2.5–2.8): “The Lead Assessor and Assessment Team Members must identify and disclose any conflicts of interest prior to conducting the assessment.”

Why Option D is Correct:

Only the Lead Assessor and assessment team are responsible for identifying conflicts of interest during Phase 1.

Options A, B, and C incorrectly assign this role to organizations that do not hold the responsibility.

References (Official CMMC v2.0 Content):

CMMC Assessment Process (CAP) v2.0, Phase 1 Planning responsibilities.

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