Experience Matters When Selecting a C3PAO
KLC Consulting recognizes that CMMC Level 2 certification is a major milestone that elevates your organization’s standing within the Defense Industrial Base (DIB).
We provide the stability and institutional knowledge required to help you navigate the assessment process with confidence. Our credentials include:
- Institutional Knowledge Helping companies of every scale build and manage cybersecurity compliance programs since 2002.
- Authorized C3PAO Providing stability and expertise as an authorized C3PAO since the program’s inception.
- Collaborative Approach Rooting every assessment in professional empathy and respect for the work your team has already invested.
- Efficient Outcomes Ensuring your journey to certification is as accurate and streamlined as possible for your specific industry.
Your time, feedback, and detailed review of our artifacts made a huge difference… The clarity you provided throughout the assessment was incredibly valuable
— Marlie Andersch, CEO & Founder, rockITdata
Protecting Your Position in the Supply Chain
With Major Primes now mandating “Green Status” and specific CCRA risk ratings, CMMC certification is a fundamental requirement for business continuity. The risk today isn’t merely “failing” an assessment; it’s the potential loss of your spot in the supply chain to a competitor. KLC Consulting brings unique “GovCon Aptitude” to your assessment through a specialized approach:
- Contracting & IT Integration: We understand that CMMC is a contracting challenge as much as an IT challenge. We don’t just look at your firewalls; we understand how DFARS 252.204-7012 requirements and CUI segmentation affect your eligibility.
- Strategic Navigation: We help you manage the critical transition from self-attestation to the formal CMMC framework, as mandated by the DoD under DFARS 252.204-7021.
- Business Continuity: We focus on securing your standing with Primes to ensure you remain a viable, “Green Status” partner in an increasingly competitive landscape.
A Collaborative, “No-Surprises” Assessment Philosophy
We immediately eliminate the “IRS-audit” level of anxiety that often precedes a CMMC Assessment. By replacing the common “gotcha” auditor mentality with a friendly, collaborative style, we change the nature of the engagement. Our philosophy focuses on the objective validation of security practices derived from NIST SP 800-171, not a hunt for flaws. By shifting the focus from “finding failures” to “verifying implementation,” we inspire the confidence to present your compliance without unnecessary unease.
- In-House Integrity: We utilize only our own W2 employees for Lead and Quality Assurance roles, never subcontracting our assessment philosophy to 1099 contractors.
- Radical Transparency: Access our Online Price Quote Tool 24/7 to obtain an instant price for your budget planning.
Professional Discretion in High-Stakes Assessments
Our goal is to validate your implementation. When you present evidence that a security practice requirement has been implemented, we record it as “MET” and move to the next requirement. We don’t dig deeper in search of flaws. While we never lower the bar for the CMMC standard, we do exercise professional discretion within the bounds of the requirements—including utilizing the allowable 10-day grace period for submitting existing evidence to ensure a fair and comprehensive outcome.
C3PAO CMMC Assessment Experts
As an authorized C3PAO, our CMMC experts have a thorough understanding of DoD cybersecurity requirements and a proven track record of helping organizations achieve compliance. We hold advanced industry certifications including Lead Certified CMMC Assessor (CCA), Certified CMMC Professional (CCP), and Provisional Instructor (PI)
In addition to our official CMMC Level 2 certification assessments, we offer Readiness “Mock” assessments and a discounted bundle package for companies that choose to have us perform both services.
President and CISO
Principal CMMC Assessor-Advisor
Lead CMMC Assessor
Lead CMMC Assessor
Frequently Asked Questions About a C3PAO
Below are some of the most frequently asked questions we get regarding a C3PAO and Assessments. If you have any other questions, we’d love to hear them [Really!] Please contact us.
Defining the C3PAO
What is a C3PAO in the context of CMMC 2.0?
A: A C3PAO is a CMMC Third-Party Assessment Organization specifically authorized to validate a DoD Prime or Subcontractor’s adherence to the CMMC framework. While “3PAO” is a standard industry term for independent auditors, the “C” prefix (for CMMC) designates a firm uniquely authorized and accredited by the Cyber AB to assess compliance on behalf of the Department of Defense. C3PAOs serve as the essential bridge between regulatory requirements and the nearly 77,000 companies within the Defense Industrial Base that handle CUI. By verifying that a contractor provides Adequate Protection for sensitive data, a C3PAO enables your organization’s eligibility for federal contracts.
How do I verify if a company is an authorized C3PAO?
A: The definitive source of truth for verification is the Cyber AB Marketplace, which maintains the official registry of all authorized organizations. This catalog identifies every firm that meets the rigorous requirements to be a fully authorized C3PAO. By visiting the official marketplace listing, defense contractors can confirm an organization’s current standing and accreditation status. It is critical to note that if an assessment provider is absent from this list, they lack the legal authority to conduct your assessment or issue a formal CMMC certificate.
Why did the DoD transition from self-attestation to mandatory C3PAO assessments?
A: The transition reflects a “crawl-walk-run” evolution intended to ensure that cybersecurity intentions are independently verified. While the initial stage introduced NIST 800-171 verification through self-assessment scoring, the DoD recognized that self-attestation alone was insufficient. By mandating independent verification through a C3PAO under DFARS 7021, the framework establishes a high standard of accountability. This evolution ensures that every organization in the supply chain provides “Adequate Protection” for sensitive CUI data vital to national security.
What is the difference between a CMMC Registered Provider Organization (RPO) and a C3PAO?
A: RPOs serve as trained consultants who help build your compliance infrastructure, while C3PAOs function as independent assessors authorized to provide impartial verification. This structural divide ensures that the organization certifying your environment is not the same entity that designed it, preventing the inherent conflict of “grading one’s own work”. By maintaining this clear separation between consulting and auditing, the framework ensures a higher level of integrity and trust.
Are all C3PAOs required to be U.S.-based organizations?
A: C3PAOs must meet stringent residency and ownership standards, generally requiring 100% U.S. citizen ownership or successful navigation of a FOCI investigation. This rigorous background verification ensures that no foreign entity can exert undue pressure on the assessment process. Additionally, all individual assessors must meet challenging education and professional experience requirements and hold a favorable DoD Tier 3 suitability determination to participate in a Level 2 engagement. Ultimately, these strict protocols exist to ensure our Defense Industrial Base can protect sensitive information and support national security.
The Assessor & Methodology
What qualifications must a CMMC Certified Assessor (CCA) hold to lead an assessment?
A: A CCA must hold an active CCP credential, pass a specialized DoD Tier 3 background check, and possess professional audit experience aligned with DoD standards. Additionally, a Lead CCA requires another progressive “Lead” certification credential. While these baseline standards ensure technical proficiency, KLC Consulting further differentiates itself by requiring that every Level 2 Assessment be Lead and Quality Assured by our senior W2 Assessor staff. By utilizing only our dedicated staff (rather than outsourced contractors), we maintain control over the execution and experience of every assessment. Our staffing philosophy ensures our delivery remains consistently congenial, collaborative, and professional.
How does KLC Consulting’s use of 100% W2 assessors impact the quality of my assessment?
A: We utilize a 100% W2 workforce of Lead and Quality Assurance assessors to eliminate the “IRS-level” audit anxiety people fear with CMMC Level 2 Certification Assessments. We do not subcontract these roles, ensuring consistency across our Aerospace & Defense, Manufacturing, Software, IT MSP, and Professional Services clients. When our assessors validate that a CMMC requirement is “MET,” we check the box and advance to the next requirement rather than “dig deeper in search of flaws.” Our approach delivers an assessment experience with the technical fidelity the DoD requires and the collaborative touch you deserve.
Can a C3PAO provide consulting and assessment services to the same company?
A: C3PAOs are prohibited from assessing any client for whom they have provided CMMC consulting services within the previous three years. This restriction is a core requirement of ISO/IEC 17020, designed to prevent conflicts of interest and ensure objective verification. Once this three-year cooling-off period has passed, a C3PAO may then proceed with a formal Level 2 engagement. To maintain the highest level of integrity, we perform a thorough conflict-of-interest check at the kickoff of every assessment.
What is the “Ethical Wall” requirement between CMMC consulting and auditing?
A: The “Ethical Wall” is a mandatory operational safeguard that ensures total impartiality during a formal CMMC Level 2 assessment. Pursuant to CAP v2.0, C3PAOs are responsible for identifying and managing conflicts of interest, a duty that cannot be delegated. At KLC Consulting, we strictly adhere to the CMMC Code of Professional Conduct (CoPC), obtaining the OSC’s concurrence on the assigned Lead CCA to ensure a transparent validation. By maintaining these internal firewalls, your certification remains technically sound and fully defensible.
How does a C3PAO use the E-I-T (Examine, Interview, Test) protocol during the audit?
A: Assessors utilize the E-I-T protocol to validate compliance by examining artifacts, interviewing personnel, and testing technical implementations. This multi-faceted approach ensures that security practices are not merely documented on paper but are actively functioning within the organization’s daily operations.
Assessment Process & Readiness
What role does a C3PAO play if there is a dispute over a specific NIST 800-171 control finding?
A: KLC Consulting prevents disputes before they occur through a collaborative philosophy that affords every OSC the opportunity to demonstrate compliance. We utilize the full 10-day grace period CMMC allows following assessment interviews to allow your team to locate and provide existing documentation that may have been missing. Should a formal disagreement arise, we’ll adhere to CAP guidance, utilizing an independent Quality Assurance CCA to manage the internal appeals process. Our zero-dispute track record proves our approach ensures that every finding is accurate, fair, and aligned with DoD standards.
How long does a typical C3PAO Level 2 assessment take from kickoff to certificate?
A: A formal 4-Phase CMMC Level 2 engagement can span several weeks from kickoff to certification. The duration of your assessment will depend on the nature and complexity of your CUI environment, number of CAGE Codes in scope, availability of your staff and documentation, and whether you achieve Conditional Status requiring a POA&M closeout. If so, you may resolve a score of 109 in as little as one day. A score of 88 may take several weeks for you to self-remediate and tell us you’re ready before we can perform a final POA&M Closeout Assessment. By managing these variables through a well-defined cadence, we ensure your path to certification is efficient, predictable, and defensible.
What happens during the “Plan and Prepare” phase of a C3PAO engagement?
A: We collaborate to define the scope to ensure no critical assets are overlooked or over-audited. We work with you to identify the boundaries of your CUI environment, and every asset that processes, stores, or transmits CUI. This process includes addressing the applicability of physical and environmental controls. Establishing a precise and defensible scope is the single most important step in ensuring a successful assessment outcome.
What documentation does a C3PAO require before they can begin an official assessment?
A: Your CAGE Codes with HLO CAGE Code, a list of ESPs/CSPs in scope, and a complete System Security Plan (SSP). During CAP Phase 1: Conduct the Pre-Assessment, KLC Consulting performs a high-level review of this information to ensure all required documentation is present and available to proceed to Phase 2: Assess Conformity to Security Requirements. Phase 1 concludes with a “Determination of Readiness” letter, which confirms whether or not you are administratively prepared to proceed. However, the Determination of Readiness is not designed as an opinion of whether you will pass or fail.
Why should I choose an authorized C3PAO for my readiness review instead of a general consultant?
A: Engaging KLC Consulting for a Mock Readiness Assessment provides a strategic advantage because we utilize the same three Certified Assessors to conduct your official assessment. Unlike providers who utilize a single, non-CCA resource, our “full-contact scrimmage” ensures that control interpretation remains consistent from the mock review through the final audit. Critically, our “Mock-Official Bundle” includes a Deficiency Remediation Review to verify that your self-remediation is technically sound, maximizing your probability of success. By bundling these services at our 1.5x rate, you secure significant cost advantage and confidence going into your official assessment.
Pricing & Transactional Logic
How does KLC Consulting determine the cost of a CMMC Level 2 assessment?
A: Our pricing is based on the size and complexity of your CUI environment, with the total number of in-scope endpoints serving as the most significant variable. We apply a nominal price factor if you develop custom software that is or contacts CUI, because we must assess additional security practices that apply. If none, no additional cost applies. Infrastructure also plays a major role; if you utilize a cloud-only environment with no physical CUI, we can properly conduct the assessment virtually, resulting in a direct $7,100 savings. Likewise, inheritance of shared responsibilities for controls through IT MSPs and secure enclaves further reduces your cost. By anchoring our quotes in objective technical factors, you don’t pay for assessment service you don’t need.
Does KLC offer fixed-fee pricing models for Level 2 certification?
A: To provide our clients with total budgetary certainty, KLC exclusively utilizes a fixed-fee pricing model for all Level 2 certification engagements. We utilize objective technical variables, such as endpoint volume, software scope, and inheritance of controls to provide a quote tailored to you. This approach eliminates the uncertainty of hourly billing or hidden administrative costs, allowing your leadership team to plan with confidence. Whether you are engaging us for a standalone assessment or our Mock-Official bundle, the price we quote is the price you pay to cross the finish line.
What happens if our organization does not achieve a passing score?
A: If your score falls below the compliant threshold of 88, 32 CFR mandates a complete reassessment rather than a POA&M closeout. KLC Consulting mitigates this impact by treating the initial engagement as a comprehensive Mock Assessment, providing a detailed report identifying precisely which practices were “NOT MET” to empower your self-remediation. To support your eventual success, we offer a significant professional courtesy: if you re-engage KLC Consulting for your official reassessment, we only charge a 50% additional cost over the original fee. This ensures that even an unsuccessful first attempt provides the most cost-effective path needed to achieve your final CMMC certification.
How long is my CMMC Level 2 Certification valid?
A: A CMMC Level 2 Certificate is valid for three years from the date of issuance, provided the organization maintains its security posture through mandated annual affirmations. During this period, you are welcome to share your certificate with Prime Customers and partners to demonstrate your compliance status. To avoid counterfeiting, the DoD and Cyber AB discourage publishing images of your certificate on social media platforms. This three-year window provides stability for your contract eligibility while operating within a validated security framework.
What is the role of a C3PAO in the annual self-affirmation process?
A: While not officially required, KLC Consulting offers a specialized Annual Attestation Affirmation Review to support your affirming official’s peace of mind. Under 32 CFR, a senior company official, often the CEO or President, must personally affirm that the organization continues to meet all CMMC requirements, carrying significant liability under the False Claims Act. Our review provides an independent “sanity check” to ensure that no significant changes have occurred within your CUI environment that would necessitate a full recertification assessment. This service provides a layer of verification to submit a truthful and defensible affirmation.
Ask the Experts: The Essential Takeaways for Your CMMC Assessment
We’ll walk you through the entire CMMC Level 2 Certification process, from understanding the typical timelines and cost contributors to identifying the essential artifacts and documentation you’ll need. We’ll give you a look at what to expect behind the scenes during the actual assessment week and highlight common challenges and pitfalls so you can avoid them. This includes a clear roadmap for what to do, when to do it, and what to look out for in your unique environment. You’ll leave with actionable strategies to effectively prepare for and successfully achieve your certification.
In this video, we address the most pressing questions surrounding the CMMC Level 2 Assessment process. We offer C3PAO insider tips to guide your company through preparing for and achieving CMMC Accreditation. Transcript for: Ace Your CMMC Level 2 Assessment.
Ask the Experts: CMMC Certification with a Friendly C3PAO
Hello, everyone. Welcome to our webinar, “Ask the Experts.” I’m Kelly McDermott from KLC Consulting. We’re a C3PAO (CMMC Third-Party Assessment Organization) authorized by the Cyber AB to assess and certify companies. Our firm also helps DIB (Defense Industrial Base) companies meet their DoD information security requirements.
Understanding the C3PAO CMMC Level 2 Assessment Process
Kyle Lai: We’ll walk you through the CMMC certification process, the key terminology, and the timeline. This is based on the official CMMC Assessment Process (CAP) 2.0 as defined by the Cyber AB. A typical CMMC Level 2 certification assessment takes about 8-12 weeks, depending on your readiness.
CMMC Level 2 Assessment: Step-by-Step Process
- Step 1: The Pre-Assessment Phase (First 1-3 weeks). This is where we kick things off. You’ll provide all the necessary information we need, including your System Security Plan (SSP) and CUI data flow diagrams. We review these to ensure you’re ready to proceed to the formal assessment. If we determine you are prepared, we move to Step 2.
- Step 2: The Formal Assessment Phase (Middle 5 weeks). During this phase, you provide us with all the required artifacts. We then review these documents. We also coordinate logistics, including on-site physical inspections if you have any physical CUI. The assessment itself usually takes one week. At the end of each day, we provide a touch point to let you know if anything is trending as “not met” or if any artifacts are still missing.
- Step 3: The Post-Assessment Phase (Last 2-4 weeks). Once we have everything we need, we write up the assessment report. We will then present an official out-brief. If you have any deficiencies, you will enter a conditional status and have up to 180 days to address them in a POA&M (Plan of Action and Milestones). If everything is good, we issue your certificate.
John Sciandra: It’s important to remember that these timelines are not set by us; they are prescribed by the CMMC program itself.
CMMC Level 2 Assessment Costs and Finding C3PAO Companies
Kyle Lai: A common question is, “How much does a CMMC assessment cost?” We can tell you that each assessment requires three assessors to be involved: two to conduct the assessment and a third for quality assurance. Prices start around $43,000 and go up depending on factors like the size and complexity of your organization, the number of locations, and your system’s design (on-prem vs. cloud-based).
Kelly McDermott: You can get an instant quote on our website.
Kyle Lai: Another common question is, “Where can I find reliable CMMC resources?” The official DoD CIO’s CMMC site is a great resource. You can also find certified professionals, C3PAO companies, and other resources on the Cyber AB marketplace. Of course, our website also provides a lot of information, blogs, and resources.
Navigating CMMC Terminology
Kyle Lai: Another common question is whether a managed service provider or cloud service provider (CSP) counts as a CUI enclave. The definition of a CSP is defined within the 32 CFR 170.17(c)(2), based on NIST 800-145. It must offer “on-demand, network access to a shared pool of configurable computing resources.” The key part is “on-demand,” which means it’s automated and requires very little manual setup.
John Sciandra: There’s a bit of finesse. For example, if you’re setting up an environment like GCC High, you may use a reseller, but the idea is that you can configure it yourself once you’ve made the purchase.
Operational Plan of Action, Enduring Exceptions, and Temporary Deficiencies
Kyle Lai: I want to introduce three newer terms we use during assessments: Operational Plan of Action, Enduring Exceptions, and Temporary Deficiencies.
- An Operational Plan of Action is something you can work on to address a minor vulnerability or deficiency after your implementation is complete. It is not the same as a POA&M.
- An Enduring Exception applies when there’s a vulnerability but nothing you can do about it. For example, a piece of certified test equipment that must run on an old operating system like Windows XP. You can document an enduring exception and still be assessed as “met.”
- A Temporary Deficiency is something you are actively working to fix. You document it in an Operational Plan of Action. There is no standard time limit for closing it out, unlike the 180-day limit for a POA&M.
John Sciandra: The CMMC program is easing up a bit on this. We’ve seen these exceptions help in unique situations, like a FIPS certificate expiring or you’re in the middle of upgrading a firewall.
C3PAO Assessment Reviews and Common Issues
Impact of the Trump Administration
Kelly McDermott: Will CMMC be impacted by the new Trump administration?
Kyle Lai: I know there’s only a slight delay. There was an executive order to hold all unfinalized rules for 60 days for review, and CMMC was caught up in that. However, the program’s original champion, Katie Arrington, is back at the DoD, and it seems there will be no impact on the program moving forward.
John Sciandra: My personal opinion is that the program is too vital to national security to be canceled. I don’t think any OSC should delay a decision to move forward based on these concerns.
C3PAO Certification Assessment Timeline
Kelly McDermott: John, how long does a CMMC certification assessment take?
John Sciandra: That’s a great question, and the answer is “it depends.” We have a set structure, but a lot depends on how well the OSC is prepared and how well they present information. We’ve had assessments where we had to do more digging because the artifacts weren’t well-organized. The more you make it easy for the CMMC assessor to find and correlate artifacts, the faster and smother the process will be.
Using a GRC Tools for C3PAO Assessment
Kelly McDermott: As an OSC, can we use our GRC tool for the assessment?
John Sciandra: We can, as long as we know how to use it. However, we recommend that you export the artifacts from your GRC tool instead. This makes it easier for us to hash the files and maintain their integrity. While a GRC tool is a great benefit for you, it doesn’t necessarily lower the cost of the CMMC assessment.
CMMC Assessment Artifact Requirements
Kelly McDermott: Kyle, what kind of artifacts do I need to provide?
Kyle Lai: At a minimum, we’re looking for your System Security Plan, policies and procedures for each requirement, and screenshots or other evidence that support the controls. We’ll still conduct interviews and ask for demonstrations, but these artifacts are the minimum we need to start.
C3PAO Assessor Expectations for Artifacts
Kelly McDermott: John, what do the CMMC assessors expect to see when they examine the artifacts?
John Sciandra: The CMMC program has three methods for examining artifacts. We’re looking to see that you have not only defined a policy for a requirement but also implemented it. You should show us that you’re doing periodic reviews and that unauthorized users are not getting into the system. It’s more than just a screenshot; we need to see the process. We’re looking to see that you’re following your own configuration management process.
What CMMC Assessors Do On-Site
Kelly McDermott: What does a CMMC assessor do when they’re actually on-site?
Kyle Lai: When we’re on-site, we focus on 18 specific physical security controls defined in the CMMC assessment process. We look at physical security, media protection, how you label things, and how you handle document shredding. Our CMMC Playbook, which you can download from our website, has these 18 controls color-coded so you know exactly what we’re looking for.
Common Issues in CMMC Assessments
John Sciandra: Common issues we see are outdated network diagrams, version numbers being out of sync, and a failure to follow your own change management process.
Kyle Lai: We also see issues with missing configuration baselines for all types of systems, like Macs and Linux.
John Sciandra: Another issue is with training. We’ve seen companies rely on general training without showing that it specifically addresses the risks unique to their organization.
Kyle Lai: Finally, just remember that even after you get your certificate, you must complete an annual affirmation every year to keep your status. Your certificate may be considered lapsed if you miss that anniversary date.
Audience Q&A
CMMC and FIPS Encryption
Audience Member: If something is FIPS encrypted, is it still CUI?
Kyle Lai: Yes, FIPS-encrypted CUI is still CUI. A representative from the DoD clarified this in a Cyber AB Town Hall last November.
Audience Member: Can any single point deficiency be fixed for re-evaluation within the 10-business-day window?
Kyle Lai: It can be fixed if you can provide new evidence within that time period. However, the change cannot impact other security requirements.
Audience Member: Is it a blanket enduring exception for an asset or network in question, or must we complete all feasible practices?
Kyle Lai: It’s a case-by-case basis. We will look at the specific situation to see if it’s truly something you have no control over.
Audience Member: Is it required to have evidence time-stamped?
John Sciandra: It is advised but not required. We look for the evidence to be current. For things like policies and procedures, we expect a version number and an approval date.
Audience Member: What portion of the assessment do you perform from your certified DIBAC enclave?
Kyle Lai: We perform all of the assessments from our own certified and authorized environment.
Audience Member: What False Claims Act risk do OSCs take when telling prime contractors they’ve implemented 100+ Level 2 controls when they have not?
Kyle Lai: I’m not a lawyer, so I can’t give legal advice. However, companies should only put a score on SPRS that they are comfortable with and can show evidence for. The DoD is watching, and they may ask for a deep dive assessment.
Audience Member: How detailed should procedures be documented?
Kyle Lai: We don’t dictate how you document them. As long as your policies and procedures cover the security requirements and you can demonstrate how you meet them, that’s what we’re looking for.
Kelly McDermott: On behalf of Kyle and John, thank you for joining us. We want you to know that as your C3PAO, our goal is for you to pass. We’re not “gotcha” auditors. We look for evidence that you’ve implemented the requirements, and we will exercise professional discretion to help you succeed.
Ready to Hire a C3PAO for Your CMMC Certifiction Requirement?
To provide the most accurate direction for your next steps in hiring a C3PAO, we recommend beginning by generating an instant price quote. We designed our online tool to be easy and efficient, it typically takes about 10 minutes to complete.
Why Reserve Your Spot Today?
- Limited Access: By the numbers, the ratio of authorized C3PAOs to DIB companies needing CMMC Level 2 Certification is about 1 : 1,000. The demand for C3PAO assessment services is very high.
- Avoid Delays: By reserving your spot now with KLC Consulting, even 6-12 months out and longer, you avoid potential scheduling conflicts and ensure a timely assessment process.
- Peace of Mind: Attain peace of mind knowing that your assessment is scheduled and focus on other priorities of running your business.
