My firm has 18 employees and an outsourced IT provider. We just got a Request for Information (RFI) for a federal contract under NAICS 541519, and it mentioned CMMC Level 2. Our IT provider said they handle most of the requirements already, but we need to get certified. We reached out to a Registered Practitioner Organization (RPO) and they quoted us a readiness engagement. Separately, a Certified Third-Party Assessment Organization (C3PAO) quoted us an actual assessment. What exactly does a CMMC consultant from an RPO do, and what does the C3PAO do? Can the same company do both the readiness work and the assessment? What should a readiness report look like? We are trying to figure out what we can realistically do ourselves with our IT provider versus what we need an outside consultant for before we go straight to an assessor.
What does a CMMC consultant actually do, and when do I need one versus going straight to an assessor?
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A CMMC consultant from a Registered Practitioner Organization (RPO) helps your company prepare for a CMMC assessment, while a Certified Third-Party Assessment Organization (C3PAO) conducts the actual assessment to determine if your company meets the required CMMC level. An RPO cannot perform the assessment because the CMMC Program separates those roles to ensure impartiality. For CMMC Level 2, an RPO consultant would help you understand the 110 requirements of NIST SP 800-171 Revision 2, identify gaps in your current cybersecurity practices, and assist in implementing the necessary controls. They would also help you develop documentation like a System Security Plan (SSP) and Plans of Action & Milestones (POA&M). A readiness report from an RPO should detail your current compliance status against each NIST SP 800-171 requirement, list identified gaps, and recommend corrective actions. Your IT provider can handle some of the technical implementation, but an RPO brings expertise in the specific CMMC framework and documentation requirements. You will need a C3PAO for the formal CMMC Level 2 certification assessment, which is either a self-assessment conducted every three years or a certification assessment by the C3PAO, depending on the contract.