What Happens in Phase 4 of the CMMC Assessment Process?Phase 4 of theCMMC Assessment Process (CAP)is theFinal Reporting and Decision Phase. During this phase, theLead Assessormust:

Review all assessment findings

Determine the Organization Seeking Certification’s (OSC) eligibility for certification

Make a recommendation to the C3PAO (Certified Third-Party Assessment Organization)

Ensure that the OSC hasmet the required practices and processes.

Confirm that anydeficiencieshave been corrected or appropriately documented.

Recommendwhether the OSC is eligible for certificationbased on assessment results.

Key Responsibilities of the Lead Assessor in Phase 4:Since theLead Assessor must determine and recommend the OSC’s eligibilityto the C3PAO, the correct answer isB. Eligibility.

A. Ability❌Incorrect. While assessing an OSC’s ability to meet CMMC requirements is part of the process, the final determination in Phase 4 is abouteligibilityfor certification.

C. Capability❌Incorrect. Capability refers to an organization'stechnical and operational readiness. The Lead Assessor is making a recommendation oneligibility, not just capability.

D. Suitability❌Incorrect. Suitability is not a defined term in theCMMC CAP processfor final assessment recommendations. The correct term iseligibility.

Why the Other Answers Are Incorrect

CMMC Assessment Process (CAP) Document– Specifies that the Lead Assessor must determine and recommend theeligibilityof the OSC in Phase 4.

CMMC 2.0 Model– Defines the assessment process, including certification decision-making.

CMMC Official ReferencesThus,option B (Eligibility) is the correct answer, as per official CMMC guidance.

Understanding "Adequate Evidence" in the CMMC Assessment ProcessIn aCMMC assessment,adequate evidencerefers to the proof required to demonstrate that a specific cybersecurity practice has been implemented correctly. Evidence can come from:

Artifacts(e.g., security policies, system configurations, logs).

Interview responses(e.g., verbal confirmation from personnel about their responsibilities).

Demonstrations(e.g., showing how a security control is implemented in real time).

Testing(e.g., verifying technical security mechanisms such as multi-factor authentication).

Thegoalof evidence collection is to determinewhether a CMMC practice is met—not just whether the organization operates within the assessment scope.

A. Verify, based on an assessment and organizational scope → Incorrect

Theassessment scopedefineswhat is evaluated, but adequacy of evidence is based oncompliance with specific CMMC practices.

B. Verify, based on an assessment and organizational practice → Incorrect

CMMC assessments focus on cybersecurity practices defined in the CMMC framework, not just general organizational practices.

C. Determine if a given artifact, interview response, demonstration, or test meets the CMMC scope → Incorrect

Thescopedefines the assessment boundaries, but theassessment team's job is to confirm whether CMMC practices are satisfied.

D. Determine if a given artifact, interview response, demonstration, or test meets the CMMC practice → Correct

TheCMMC assessment process focuses on ensuring that required practices are implemented, making this the correct answer.

Why is the Correct Answer "Determine if a given artifact, interview response, demonstration, or test meets the CMMC practice" (D)?

CMMC Assessment Process (CAP) Document

Defines "adequate evidence" asproof that a CMMC practice has been correctly implemented.

CMMC 2.0 Assessment Criteria

Specifies that evidence must beevaluated against specific cybersecurity practices.

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

Provides guidance on evaluating artifacts, interviews, demonstrations, and testing to confirm compliance with required practices.

CMMC 2.0 References Supporting this Answer:

Final Answer:✔D. Determine if a given artifact, interview response, demonstration, or test meets the CMMC practice.

Understanding the CMMC-AB Code of Professional ConductTheCybersecurity Maturity Model Certification Accreditation Body (CMMC-AB), now referred to asThe Cyber AB, establishes aCode of Professional Conduct (CoPC)for all individuals involved in CMMC assessments, includingCertified Assessors (CAs), Certified Professionals (CPs), and C3PAOs (Certified Third-Party Assessment Organizations).

Thecore principlesoutlined in theCMMC-AB Code of Professional Conductinclude:

Responsibility

CMMC professionals must takefull accountabilityfor their actions, ensuring that assessments are conducted withintegrity and professionalism.

They mustadhere to all ethical and regulatory requirementsestablished by The Cyber AB and the DoD.

Confidentiality

CMMC professionals mustprotect sensitive information, includingControlled Unclassified Information (CUI)andFederal Contract Information (FCI).

They are required toadhere to non-disclosure agreements (NDAs)and avoid improper information sharing.

Information Integrity

All reports, findings, and recommendations in CMMC assessments must beaccurate, unbiased, and truthful.

Assessors mustavoid conflicts of interestand ensure that all data provided in an assessment isverifiable and free from misrepresentation.

Answer A (Incorrect): "Classification" is not a primary principle of the CMMC-AB CoPC. The focus is on protectingCUI and FCI, not on classification procedures.

Answer B (Incorrect): "Objectivity" is important, but it is not explicitly listed as one of the three core principles in theCMMC-AB Code of Professional Conduct.

Answer C (Incorrect): "Classification" is not a guiding principle in the CoPC.

Answer D (Correct):The Code of Professional Conduct explicitly emphasizes responsibility, confidentiality, and information integrity.

The correct answer isD. Responsibility, Confidentiality, and Information Integrity.

These principlesensure that all CMMC professionals maintain ethical standards and uphold the integrity of the certification process.

Understanding Federal Contract Information (FCI) and Publicly Accessible InformationFederal Contract Information (FCI)isnon-public informationprovided by or generated for the U.S. governmentunder a contractthat isnot intended for public release.

Key Characteristics of FCI:✔FCI includesdetails related togovernment contracts, project specifics, and performance data.

✔It must be protected under FAR 52.204-21, which requiresbasic safeguarding measuresto prevent unauthorized access.

✔Posting FCI on a public site is a security violationsince it ismeant to be restrictedfrom public disclosure.

A. FCI → Correct

FCI must be protected from unauthorized access, and if it wasincorrectly published online, it should have been restricted.

B. Change of leadership in the organization → Incorrect

Leadership changes are typically public informationand do not require restriction unless they involve sensitive government-related security clearances.

C. Launching of their new business service line → Incorrect

Marketing and business announcementsare generallypublicly availableandnot restricted information.

D. Public releases identifying major deals signed with commercial entities → Incorrect

Commercial contracts and business deals are not considered FCIunless they involvegovernment contracts.

Why is the Correct Answer "A. FCI (Federal Contract Information)"?

FAR 52.204-21 (Basic Safeguarding of Covered Contractor Information Systems)

DefinesFCI as sensitive but unclassified informationthat must beprotected from public disclosure.

CMMC 2.0 Level 1 Requirements

Requires contractors toprotect FCI under basic cybersecurity standardsto prevent unauthorized exposure.

DoD Guidance on FCI Protection

States thatpublishing FCI on public websites violates federal cybersecurity requirements.

CMMC 2.0 References Supporting This Answer:

DoDI 5200.48 specifies that Authorized Holders of CUI are responsible for applying appropriate CUI markings. An authorized holder is an individual who has lawful government purpose access to the information. This ensures that responsibility for correctly marking information rests with those who create or handle the material, not only with original classification authorities (which apply to classified information, not CUI).

Reference Documents:

DoDI 5200.48, Controlled Unclassified Information (CUI)

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 the Role of "Discussion" and "Further Discussion" Sections in CMMC AssessmentsWhen assessing anOrganization Seeking Certification (OSC)forCMMC compliance, theLead Assessorrelies on various sources of guidance.

Eachpracticein the CMMC model includes:

The Practice Statement– The official requirement the OSC must meet.

Discussion Section– Providesclarifications, interpretations, and guidancefor implementation.

Further Discussion Section– Expands on the practice,offering additional details, best practices, and examples.

These sections arenot mandatory, but they help assessorsinterpret and evaluatewhether an OSC has met the practice requirements.

TheDiscussion and Further Discussion sectionsprovidecontext, explanations, and examplesto assist theLead Assessorin understanding how an OSC might demonstrate compliance.

Theyhelp guide the assessment processbut arenot prescriptiveormandatoryfor an OSC.

Theassessor uses these sectionsto verify whether theOSC's implementation meets the intent of the requirement.

Why "Provides Additional Information to Facilitate the Assessment" is Correct?Breakdown of Answer ChoicesOption

Description

Correct?

A. Is normative for an OSC to follow.

❌Incorrect–The sections areguidance, notnormative (mandatory)requirements.

B. Contains examples that an OSC must implement.

❌Incorrect–Examples aresuggestions, notmandatory implementations.

C. Is mandatory and aligns with FAR Clause 52.204-21.

❌Incorrect–The "Discussion" sections arenot mandatoryand arenot tied directlyto FAR 52.204-21.

D. Provides additional information to facilitate the assessment of the practice.

✅Correct – These sections help the assessor evaluate compliance but do not mandate specific implementations.

TheCMMC Assessment Guidestates that theDiscussion and Further Discussion sections provide clarificationsto help both assessors and OSCs.

These sections arenot bindingbut serve asinterpretive guidanceto assist in assessments.

Official References from CMMC 2.0 DocumentationFinal Verification and ConclusionThe correct answer isD. Provides additional information to facilitate the assessment of the practice.This aligns withCMMC 2.0 documentation and assessment guidelines.