What to Expect When Working With a C3PAO

February 10, 2026

You’ve implemented NIST SP 800-171, finalized your documentation, and aligned your environment to protect Controlled Unclassified Information (CUI). Now comes the final step: completing a CMMC Level 2 certification assessment with an authorized CMMC Third-Party Assessment Organization (C3PAO).

For many defense contractors, this is unfamiliar territory. Understanding how the process works and what a C3PAO will expect from you can help reduce uncertainty and keep your assessment on track.

Getting Started With a C3PAO

Only organizations authorized by the Cyber AB are permitted to conduct CMMC Level 2 certification assessments. Once you identify a C3PAO and initiate contact, the first step is an information-gathering discussion to determine assessment scope, complexity, and logistics.

At IBSS, this initial conversation focuses on understanding the environment to be assessed.

Additional details may be requested to estimate the level of effort and scope of the assessment. This stage is also your opportunity to evaluate the C3PAO. While assessors must remain independent, communication style, professionalism, and clarity still matter. A certification assessment is a formal process, but it should also be well-organized and predictable.

Before contracting, any potential conflicts of interest must be identified. A C3PAO that has provided readiness, advisory, or implementation services to your organization cannot serve as your assessor. If a conflict exists with a specific assessor rather than the C3PAO itself, it must be disclosed and acknowledged before proceeding. Once scope and eligibility are confirmed, the engagement moves forward with a formal agreement, including non-disclosure protections and a planned assessment window.

How the CMMC Assessment Is Conducted

At IBSS, CMMC Level 2 certification assessments follow a structured, four-phase process designed to promote clarity, efficiency, and assessment integrity. Each phase builds on the last, ensuring expectations are aligned before formal evaluation begins.

Phase 1: Readiness & Scoping Affirmation

Objective: To affirm the assessment boundaries and ensure the Organization Seeking Certification (OSC) is prepared for a formal engagement.

  • Boundary Validation: We facilitate a scoping session to affirm your CMMC assessment scope. This includes identifying Controlled Unclassified Information (CUI) assets, security protection assets, and confirming “Out-of-Scope” assets to prevent “scope creep” during the assessment.
  • Readiness Determination: We perform a high-level review of your system security plan (SSP) and associated scoping documentation. This identifies potential “showstoppers” (i.e., critical deficiencies where assessment objectives are not met) saving you time and resources.
  • Level of Effort (LOE) Projection: Based on the complexity of your CUI environment, we provide a detailed estimate of the timeline and resources required for a successful certification.

Phase 2: Strategic Planning & CAP Alignment

Objective: To formalize the engagement in strict accordance with the Cyber AB’s CMMC Assessment Process (CAP).

  • Formal Assessment Plan: We develop the official assessment plan, designating your Lead Certified CMMC Assessor (LCCA) and the supporting assessment team.
  • Regulatory Protocols: We execute all necessary legal agreements, including non-disclosure agreements (NDAs) and Quality Assurance (QA) protocols required for a C3PAO engagement.
  • Logistical Coordination: We establish a precise schedule for artifact examination and personnel interviews, designed to ensure thorough coverage while minimizing operational impact.

Phase 3: Formal Assessment Conduct

Objective: To verify compliance through the three official assessment methods: Examine, Interview, and Test.

  • Artifact Examination: Our team performs a rigorous review of your “Objective Evidence” (e.g., configurations, logs, and policies) to verify that all 110 NIST SP 800-171 security practices are fully implemented.
  • Personnel Interviews: We conduct focused discussions with key process owners and system administrators to ensure security practices are institutionalized and consistently followed.
  • Direct Observation: We perform real-time verification of physical and logical security controls within your environment (onsite or via secure remote session) to confirm the “live” state of your security posture.

Phase 4: Final Reporting & SPRS Submission

Objective: To adjudicate findings, finalize the record, and manage the official submission to the Department of Defense.

  • Findings Validation & Adjudication: We provide a formal Preliminary Assessment Findings Brief. This includes identifying any non-critical deficiencies eligible for a 180-day Plan of Action and Milestones (POA&M) per CMMC guidelines.
  • Final Assessment Report (FAR): We issue the official, signed FAR detailing your assessment results and final score. This report undergoes an independent review by our C3PAO Quality Manager to ensure total objectivity.
  • SPRS/eMASS Submission: As your C3PAO, we manage the official upload of your assessment results into the DoD’s Supplier Performance Risk System (SPRS), triggering the formal issuance of your certification.

IBSS’ Role as a C3PAO

IBSS is an authorized C3PAO focused exclusively on independent CMMC Level 2 certification assessments. We do not provide readiness consulting, remediation, or implementation support, preserving the objectivity required of assessors.

What organizations can expect from IBSS is:

  • Clear communication and structured assessment execution
  • Consistent evaluation aligned to Cyber AB requirements
  • Professional reporting grounded in evidence and transparency

Ready for Your CMMC Level 2 Assessment?

If your organization is ready for its CMMC Level 2 assessment, IBSS is now accepting engagements. Request a CMMC Level 2 Assessment slot or email us at C3PAO@ibsscorp.com to start the path toward certification with a team that knows the process inside and out.

About IBSS

Since 1992, IBSS has provided transformational cybersecurity services to the Federal defense, civilian, and commercial sectors. IBSS is an Authorized C3PAO, a designation granted by The Cyber AB (CMMC Accreditation Body) under the guidance of the Department of Defense (DoD). This authorization confirms that our organization has successfully completed the rigorous process required to assess the cybersecurity posture of organizations within the Defense Industrial Base (DIB) against the requirements of the Cybersecurity Maturity Model Certification (CMMC).

  • Authorized by: The Cyber AB (Official Accreditation Body)
  • Listing Verification: https://cyberab.org/Member/C3PAO-2829-Ibss-Corp
  • Relevant Standards: C3PAO Authorization, CMMI SVC Level 3 and DEV Level 3, ISO 9001:2015 Certified Quality Management System, ISO/IEC 20000-1:2018 Certified Information Technology Services Management (ITSM), ISO/IEC 27001-2022 Certified Information Security Management Systems (ISMS), ISO/IEC 17020:2012 Compliance (in progress).

Read more About Us.

Keywords: CMMC, Authorized C3PAO, DoD Requirements, NIST SP 800-171, Cybersecurity, DIB, Cyber AB 

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