When Should You Work with a CMMC RPO vs. a C3PAO?

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CMMC is a complex undertaking. Depending on where you are in your certification journey, you could require consulting, assessment, or both. Fortunately, the CMMC program includes training and authorization for two distinct types of organizations: Registered Provider Organizations (RPOs) and Certified Third-Party Assessment Organizations (C3PAOs), each offering different services. 

We’re discussing these organizations and which one you might want to engage with when preparing for CMMC certification. 


What Are Registered Provider Organizations (RPOs)?

A CMMC Registered Provider Organization is a consulting entity officially registered with the CMMC Accreditation Body (CMMC-AB), the authoritative body established to operationalize and manage the DoD’s CMMC program. RPOs are authorized to provide advisory and security support services to organizations preparing for their CMMC certification process. 

All RPOs will share a few common traits and requirements:

  • Training and Assessment: Firms looking to become RPOs must undergo a training process designed by the CMMC-AB. This includes ensuring that their staff complete the required CMMC training courses and assessments to understand the CMMC model’s intricacies thoroughly.
  • CMMC-AB Registration: Once the training requirements are met, the organization applies to the CMMC-AB to be recognized as an RPO. This process involves submitting documentation that demonstrates their understanding and capability to consult on CMMC requirements.
  • Agreement to Code of Professional Conduct: RPOs must agree to and adhere to a professional code of conduct set by the CMMC-AB. This ensures they maintain high integrity and professionalism while providing services to organizations seeking CMMC certification.
  • Ongoing Requirements: To maintain their status, RPOs must comply with ongoing professional development and training requirements to stay current with the latest CMMC standards and practices.

The responsibilities of an RPO include:

  • Advisory Role: RPOs guide organizations through the certification process under the CMMC framework, helping them understand the requirements and how to meet them. This includes interpreting the specific cybersecurity practices and processes required at each CMMC level.
  • Pre-Assessment Services: RPOs offer pre-assessment services such as gap analyses, readiness assessments, and remediation assistance. These help organizations identify areas for improvement in cybersecurity practices to achieve the desired level of CMMC certification.
  • Implementation Support: RPOs assist in implementing the required cybersecurity controls, processes, and policies. They can help develop documentation and implement the technical and administrative controls necessary for compliance.
  • Training and Education: Many RPOs provide training and education to help organizations and their employees understand CMMC requirements, cybersecurity best practices, and how to maintain compliance over time.


Certified Third-Party Assessment Organizations

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The CMMC-AB formally accredits a C3PAO to assess defense contractors’ compliance with CMMC standards. These organizations play a crucial role in the Defense Industrial Base infrastructure by certifying third-party contractors offering IT services to DoD and Executive agencies. 

In their role as an assessment organization, C3PAOs share the following responsibilities:

  • Formal Assessments: C3PAOs carry out the official assessments required for a company to achieve CMMC certification. This involves evaluating the implementation of cybersecurity requirements at the appropriate CMMC level (for CMMC 2.0, this typically means most Level 2 and all Level 3 certifications) that the company must meet to be awarded contracts by the DoD.
  • Objective Evaluation: They provide an objective and independent evaluation of a company’s cybersecurity maturity against the CMMC framework. This ensures that only companies with the appropriate level of cybersecurity controls in place can access sensitive DoD information.
  • Certification Recommendation: While C3PAOs do not grant certifications, they collect, review, and submit evidence of compliance to the CMMC-AB. Based on this submission, the CMMC-AB issues the certification if the company meets the required standards.


Accreditation Process for CMMC 3PAOs

To become a C3PAO, an organization must undergo a rigorous accreditation process by the CMMC-AB. This process ensures that the C3PAO has the expertise, processes, and impartiality to conduct fair assessments. 

Critical steps in this process include:

  • Application and Background Checks: Organizations interested in becoming 3PAOs must apply through the CMMC-AB, including comprehensive background checks to ensure no conflicts of interest.
  • Training and Examination: Staff and assessors within the organization must complete specialized training and pass examinations to demonstrate their understanding of the CMMC framework and assessment procedures.
  • Operational Capability Demonstration: Organizations must prove they have the operational capabilities to conduct assessments, including documented procedures, trained personnel, and the infrastructure to securely manage sensitive information.
  • Ongoing Compliance: The CMMC-AB continuously oversees accredited 3PAOs to ensure they maintain high standards of professionalism, confidentiality, and impartiality. This includes regularly updating their practices and processes to align with any changes in the CMMC standards.

Once a C3PAO is certified, it will be listed in the CMMC marketplace. The CMMC-AB approves any organization listed here, so you won’t have to worry about verifying credentials. 


When Should I Work with an RPO?

It’s important to note that RPOs do not provide assessment services–this responsibility is limited to C3PAOs or government agencies, depending on the assessment level. That being said, RPOs serve an essential function based on your organization’s needs:

  • Preparation and Readiness: If your organization is in the early stages of preparing for CMMC certification and needs help understanding the requirements, implementing necessary cybersecurity practices, or preparing documentation, an RPO can guide you through these steps.
  • Gap Analysis: Before undergoing a formal CMMC assessment, you may want to identify gaps in your cybersecurity practices and processes. RPOs can conduct preliminary evaluations to help you understand where you stand against CMMC requirements.
  • Consulting Services: RPOs can provide tailored advice on improving cybersecurity maturity by CMMC levels, helping you develop policies, procedures, and technical controls that meet specific CMMC practices and processes.


When Should I Work with a C3PAO?

Once you look at CMMC Level 2 or Level 3 certification, you will find that C3PAOs are non-negotiable. It is important to note that if you’re already working with an RPO, that same company cannot serve as your C3PAO due to conflicts of interest. 

Accordingly, you should work with a C3PAO when you’re ready for certification:

  • Formal Assessment: When ready to undergo the official CMMC assessment, you must engage a C3PAO. This step comes after you’ve prepared, possibly with the help of an RPO, and believe your cybersecurity practices meet CMMC requirements.
  • Certification: The ultimate goal of working with a C3PAO is to achieve CMMC certification, which is necessary for bidding on specific DoD contracts. Only a C3PAO can provide the assessment needed for certification.


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