The Certified CMMC Professional (CCP) Exam (CMMC-CCP)

For CMMC Level 1 scoping , the DoD’s CMMC Scoping Guide – Level 1 (v2.13) instructs an organization performing a Level 1 self-assessment to consider what is in scope for protecting Federal Contract Information (FCI) . Specifically, it states that to appropriately scope a Level 1 self-assessment, the OSA should consider the people, technology, facilities, and external service providers (ESPs) within its environment that process, store, or transmit FCI .

In this scenario, the director is evaluating company offices and data centers where FCI is stored. These are physical locations and physical environments—exactly what the scoping guidance categorizes under Facilities . Facilities in a Level 1 context include physical sites and spaces that may house systems or media containing FCI (e.g., offices, server rooms, data centers), because those locations affect physical access controls, environmental protections, and overall safeguarding of where FCI is handled and stored.

This is distinct from Technology (devices/systems), People (personnel who handle FCI), and ESPs (external providers delivering IT/cyber services). Since the question is explicitly about which offices and data centers store FCI —a physical boundary and location question—the correct asset type is Facilities .

1. Understanding CMMC 2.0 Levels and CUI Handling Requirements

UnderCMMC 2.0, contractors handlingControlled Unclassified Information (CUI)must meet aminimumcertification level to be eligible for contract awards involving CUI.

CMMC 2.0 Levels:

Level 1 (Foundational) – 17 Practices

Covers onlyFederal Contract Information (FCI)security.

Does NOT meet CUI handling requirements.

Level 2 (Advanced) – 110 Practices✅

REQUIRED for handling CUI.

Aligns withNIST SP 800-171, which establishes security controls for protecting CUI.

Contractorsmust achieve Level 2for contracts requiring CUI protection.

Level 3 (Expert) – 110+ Practices

Required for contracts involvinghigh-value CUIandcritical national security information.

Includesadditionalprotections fromNIST SP 800-172.

2. Official CMMC 2.0 References Confirming Level 2 for CUI

TheCMMC 2.0 Model Overviewclearly states that Level 2 is required for contractorshandling CUI.

DFARS 252.204-7012mandates that contractors protecting CUI must implementNIST SP 800-171, which is thefoundation of CMMC Level 2.

TheDoD’s CMMC Assessment Guidefor Level 2 specifies thatorganizations handling CUI must demonstrate full implementation of 110 practices from NIST SP 800-171to qualify for contract awards.

3. Why the Other Options Are Incorrect

A. Level 1❌

Only covers FCI, not CUI.

Does notmeet DoD requirements for protectingCUI.

C. Level 3❌

While Level 3 offersadditional protectionsfor high-risk CUI, it isnot the minimumrequirement.

Level 2 is the minimumneeded to handle CUI.

D. Any level❌

OnlyLevel 2 and higherare eligible for contracts requiring CUI protection.

Level 1 doesnotmeet CUI security standards.

Step 1: Understanding CMMC Assessment Scope Determination

In a CMMC Level 2 assessment, the Organization Seeking Certification (OSC) is responsible for identifying the assessment scope based on the CMMC Scoping Guidance provided by the Cyber AB (Cyber Accreditation Body) and DoD.

The OSC must determine which assets and systems handle Controlled Unclassified Information (CUI) and categorize them accordingly.

TheAudit and Accountability (AU) domainis one of the14 familiesof security requirements inNIST SP 800-171 Rev. 2, which is fully adopted byCMMC 2.0 Level 2.

Analysis of the Given Options:

A. Level 1→Incorrect

CMMCLevel 1only includes17 basic FAR 52.204-21 safeguarding requirementsand does not coverAudit and Accountability (AU)practices.

B. Level 2→Correct

TheAU domain is required at Level 2, which aligns withNIST SP 800-171.

CMMC 2.0 Level 2includes110 security controls, among whichAU-related controlsfocus on logging, monitoring, and accountability.

C. Levels 1 and 2→Incorrect

Level 1 does not requireaudit and accountability practices.

D. Levels 1 and 3→Incorrect

CMMC 2.0 only has Levels 1, 2, and 3, andAU is present in Level 2, making Level 3 irrelevant for this answer.

Official References Supporting the Correct Answer:

NIST SP 800-171 Rev. 2 (Audit and Accountability - Family 3.3)

TheAU domainconsists of security controls3.3.1 – 3.3.8, focusing on audit log generation, retention, and accountability.

CMMC 2.0 Level 2 Practices (Aligned with NIST SP 800-171)

AU practices (Audit and Accountability) are only required at Level 2.

Conclusion:

TheAU domain applies only to CMMC 2.0 Level 2, making the correct answer:

✅B. Level 2.

The False Claims Act (31 U.S.C. §§ 3729–3733) imposes liability on companies that knowingly misrepresent compliance in order to receive or retain federal contracts. Penalties include treble damages (three times the government’s losses) plus additional penalties per claim.

Supporting Extracts from Official Content:

False Claims Act: “Any person who knowingly submits false claims to the Government is liable for three times the Government’s damages plus a penalty.”

DOJ Cyber-Fraud Initiative (2021): confirms the FCA is applied to cases of misrepresenting compliance with cybersecurity requirements.

Why Option D is Correct:

The applicable law is the False Claims Act, not a “Cyber Claims Act” (which does not exist).

The FCA specifies treble damages plus penalties, which exactly matches Option D.

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

False Claims Act (31 U.S.C. §§ 3729–3733).

DOJ Cyber-Fraud Initiative (2021), applied to CMMC-related compliance misrepresentation.

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For SI.L2-3.14.7 (Identify Unauthorized Use) , the assessment objectives focus on two outcomes: (a) the organization has defined authorized use of the system, and (b) the organization identifies unauthorized use when it occurs. The strongest evidence is therefore evidence that the organization actively monitors systems and can detect and recognize activity outside the defined authorized-use baseline.

In the DoD CMMC Assessment Guide – Level 2 (v2.13) , the “Potential Assessment Methods and Objects” for SI.L2-3.14.7 emphasize artifacts that are directly tied to monitoring and detection—such as a continuous monitoring strategy , system and information integrity policy , procedures addressing system monitoring tools and techniques , and technical monitoring capabilities (e.g., tools/techniques like IDS/IPS , audit record monitoring , and network monitoring ).

These artifacts are exactly what demonstrate that unauthorized use is being identified in practice (alerts, logs, correlation, and review processes) and that authorized use is defined (policies/standards that establish what “authorized” looks like so “unauthorized” can be recognized).

By contrast, risk assessment/response and incident response may be related program elements, but they are not the primary evidence that the organization is continuously detecting unauthorized use. The assessment guide’s focus on monitoring artifacts makes System monitoring the best evidence.

Step 1: Define CUI (Controlled Unclassified Information)

CUI is information thatrequires safeguarding or dissemination controlspursuant to and consistent with applicable law, regulations, and government-wide policies, butis not classifiedunder Executive Order 13526 or the Atomic Energy Act.

✅Step 2: Authority over CUI — NARA’s Role

NARA – National Archives and Records Administration, specifically theInformation Security Oversight Office (ISOO), is thegovernment-wide executive agentresponsible for implementing the CUI program.

Source:

32 CFR Part 2002 – Controlled Unclassified Information (CUI)

Executive Order 13556 – Controlled Unclassified Information

CUI Registry – https://www.archives.gov/cui

NARA:

Maintains theCUI Registry,

Issuesmarking and handling guidance,

DefinesCUI categoriesand their authority under law or regulation,

Trains and informs Federal agencies and contractors on CUI policy.

❌Why the Other Options Are Incorrect

B. NIST

✘NIST (National Institute of Standards and Technology) developstechnical standards(e.g., SP 800-171), but it doesnot define or mark CUI. It helps secure CUI once it’s identified.

C. CMMC-AB (now Cyber AB)

✘The Cyber AB is theCMMC ecosystem’s accreditation body, not a government agency, and hasno authority over CUI classification or marking.

D. Department of Homeland Security (DHS)

✘While DHS mayhandle and protect CUI internally, it is not the executive agent for the CUI program.

NARAis theofficial U.S. government authorityresponsible for defining, categorizing, and marking CUI via theCUI Registryand associated policies underExecutive Order 13556.

Understanding the Definition of an Agreement in the CMMC-AB Code of Professional Conduct

TheCMMC-AB Code of Professional Conductdefines anagreementasany contract between two legal entities. This includes:

✔Contracts between an OSC and a C3PAOfor CMMC assessments.

✔Service agreements between cybersecurity providers and defense contractors.

✔Any formal, legally binding arrangement related to CMMC compliance.

Why is the Correct Answer " D. Agreement " ?

A. Union → Incorrect

Auniontypically refers to anorganization representing workersand is not used to describe acontractual relationship.

B. Accord → Incorrect

While anaccordcan mean an agreement, it isnot the standard legal term for a binding contractin CMMC documentation.

C. Alliance → Incorrect

Analliancerefers to astrategic partnership, but does not necessarily imply alegally binding contract.

D. Agreement → Correct

TheCMMC-AB Code of Professional Conductdefines anagreementas anylegally binding contract between two entities.

CMMC 2.0 References Supporting This Answer:

CMMC-AB Code of Professional Conduct

Defines " Agreement " as alegally binding contract between two parties.

CMMC-AB Licensed Training and Assessment Provider Guidelines

Requires that all engagementsbe governed by a formal agreement (contract) between the parties.

DFARS and CMMC Certification Contracts

States thatOSC-C3PAO relationships must be formalized through a legal agreement.

The correct answer is C . Under the official CMMC Assessment Process, the C3PAO is responsible for submitting CMMC Level 2 certification assessment results into CMMC eMASS , which is the Enterprise Mission Assurance Support Service environment used for CMMC assessment result submission. The CMMC Assessment Process Version 2.0 states that CMMC Level 2 certification assessment results are uploaded to CMMC eMASS by the C3PAO, and that the user workspace used for upload must exist within the scope of the C3PAO’s DIBCAC-assessed environment.

This means the OSC does not submit the final certification assessment package directly, and the Lead Assessor does not independently submit final results to the CMMC-AB. The Lead Assessor leads assessment execution, prepares findings, supports the out-brief, and works with the assessment team, but the formal assessment-result submission function belongs to the authorized C3PAO. The CMMC Quality Assurance Professional review occurs before final submission to help ensure assessment completeness, consistency, and quality. After that review, the C3PAO submits the assessment results into the official CMMC eMASS environment. Therefore, options A , B , and D are incorrect because they identify the wrong receiving entity or the wrong submitting party. Option C correctly identifies both the submitting organization and the official submission system.

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