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CMMC Level 2 System Assessment Report

Training Tool - ACME Technology Services Corporation

Instructor Controls

1Executive Summary

Assessment Overview

This System Assessment Report (SAR) documents the independent evaluation of ACME Technology Services Corporation's cybersecurity controls implementation for CMMC Level 2 compliance. The assessment was conducted by certified C3PAO assessors in accordance with NIST SP 800-171 Rev 2 requirements and CMMC 2.0 standards.

Organization Information

  • Organization: ACME Technology Services Corporation
  • Location: El Paso, Texas
  • Employees: 64
  • Business Type: Defense contractor providing uniform and textile logistics services to U.S. Army
  • Assessment Level: CMMC Level 2
  • Assessment Date: June 15, 2025

Overall Score: 92/110 (84%)

Conditional Certification Achieved

Key Findings

ACME Technology Services Corporation has demonstrated strong cybersecurity posture with 84% compliance rate. The organization has successfully implemented 92 out of 110 required NIST SP 800-171 controls. The remaining 18 controls require remediation within 180 days through POA&M closeout.

2Assessment Methodology & Scope

Assessment Approach

The assessment followed the CMMC Assessment Process (CAP) version 2.0 methodology, employing multiple evaluation methods:

  • Document Review: System Security Plan (SSP), policies, procedures, and technical documentation
  • Interviews: Key personnel responsible for security control implementation
  • System Testing: Technical validation of security controls and configurations
  • Physical Inspection: On-site evaluation of physical security measures

Assessment Scope

The assessment scope included all systems and assets that process, store, or transmit Controlled Unclassified Information (CUI):

In-Scope CUI Assets

  • Primary Data Server (CUI-001)
  • Azure Cloud Backup Repository (CUI-002)
  • Contract Coordinator Workstations (CUI-003 to CUI-005)
  • CISO Management Workstation (CUI-006)
  • Secure File Server (CUI-007)

Security Protection Assets

  • Enterprise Firewall (SPA-001)
  • VPN Gateway (SPA-002)
  • Endpoint Protection System (SPA-004)
  • SIEM Platform (SPA-005)
  • Badge Access Control System (SPA-006)

3Assessment Team Credentials

C3PAO Information

Assessment Organization: SecureAssess C3PAO LLC

C3PAO Authorization Number: C3PAO-2025-001

ISO 17020 Certification: Valid through December 2026

Assessment Team Members

Name Role Certification Experience
Sarah Mitchell Lead Certified CMMC Assessor (CCA) CCA-2024-156 8 years cybersecurity, 3 years CMMC
James Rodriguez Certified CMMC Professional (CCP) CCP-2024-342 12 years IT security, 2 years CMMC
Dr. Emily Chen Quality Control Lead CCA-2023-089 15 years security assessments

4Detailed Security Control Findings

Control Assessment Results

AC.1.001 - Account Management MET

Control Description: Limit information system access to authorized users, processes, and devices.

Implementation Status: ACME has implemented Active Directory-based account management with proper user lifecycle management processes.

Evidence Reviewed: Account creation procedures, termination checklists, regular access reviews

Assessment Method: Document review, system inspection, staff interviews

AC.1.002 - Access Enforcement MET

Control Description: Limit information system access to the types of transactions and functions authorized users are permitted to execute.

Implementation Status: Role-based access controls properly implemented through Active Directory groups and application-level permissions.

Evidence Reviewed: Role matrices, permission configurations, access testing results

AU.2.041 - Audit Record Correlation NOT MET

Control Description: Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, or unusual activity.

Implementation Status: While SIEM platform is deployed, correlation rules for investigative processes are incomplete.

Gap Identified: Missing formal correlation procedures and insufficient automated alerting rules.

Remediation Required: Develop correlation procedures and implement additional SIEM rules within 180 days.

SC.1.175 - Collaborative Computing CONDITIONAL

Control Description: Prohibit remote activation of collaborative computing devices and provide indication of devices in use.

Implementation Status: Partially implemented - webcam disable policies in place but microphone controls need enhancement.

POA&M Item: Complete microphone access controls configuration by September 15, 2025.

5Risk Assessment & Impact Analysis

Risk Summary

Risk Category Risk Level Count Impact
Access Control Gaps Medium 3 Potential unauthorized access to CUI systems
Audit & Monitoring Medium 5 Reduced incident detection capability
Configuration Management Low 4 Minor compliance documentation gaps
Incident Response Medium 2 Delayed response to security incidents

Overall Risk Determination

The residual risk to ACME Technology Services Corporation is assessed as MODERATE. While the organization has implemented a strong cybersecurity foundation, the identified gaps primarily relate to monitoring and audit capabilities that could impact incident detection and response times.

Risk Mitigation Recommendations

  • Prioritize completion of audit correlation procedures and SIEM tuning
  • Enhance monitoring coverage for CUI processing systems
  • Implement automated alerting for critical security events
  • Conduct tabletop exercises to validate incident response procedures

6Plan of Action & Milestones (POA&M)

Required Remediation Items

The following 18 security controls require remediation within 180 days to achieve final CMMC Level 2 certification:

Control ID Control Name Priority Target Date Responsible Party
AU.2.041 Audit Record Correlation High August 15, 2025 Raymond Lawrence, CISO
IR.2.092 Incident Handling High September 1, 2025 IT Security Team
SC.1.175 Collaborative Computing Medium September 15, 2025 IT Operations
SI.1.210 Information Input Validation Medium October 1, 2025 Application Development

POA&M Closeout Requirements

  • All items must be completed within 180 days (by December 12, 2025)
  • C3PAO closeout assessment required for certification finalization
  • Evidence packages must be submitted for each remediated control
  • Final assessment report will be generated upon successful closeout

7Recommendations for Improvement

Strategic Recommendations

  1. Enhance Security Monitoring: Implement 24/7 SOC capabilities or engage managed security services to improve incident detection and response times.
  2. Automate Compliance Monitoring: Deploy automated compliance monitoring tools to continuously assess control effectiveness and identify drift.
  3. Strengthen Incident Response: Conduct regular tabletop exercises and update incident response procedures based on current threat landscape.
  4. Employee Training: Implement comprehensive cybersecurity awareness training program with regular phishing simulations.
  5. Supply Chain Security: Extend CMMC requirements to subcontractors and implement supply chain risk management procedures.

Technical Improvements

  • Implement privileged access management (PAM) solution for administrative accounts
  • Deploy network segmentation monitoring tools to detect lateral movement
  • Enhance endpoint detection and response (EDR) capabilities
  • Implement automated patch management for critical security updates
  • Deploy data loss prevention (DLP) solutions for CUI protection

Process Improvements

  • Establish formal change management procedures for security configurations
  • Implement regular vulnerability assessment and penetration testing schedule
  • Create security metrics dashboard for executive reporting
  • Develop business continuity and disaster recovery testing program

8Certification Decision

Assessment Conclusion

Based on the comprehensive assessment conducted from June 10-14, 2025, ACME Technology Services Corporation has demonstrated substantial compliance with CMMC Level 2 requirements.

CONDITIONAL LEVEL 2 CERTIFICATE ISSUED

Valid subject to POA&M closeout by December 12, 2025

Certification Details

  • Certificate Number: CMMC-L2-2025-ACME-001
  • Issue Date: June 16, 2025
  • Expiration Date: June 16, 2028 (3 years)
  • Annual Reaffirmation Required: June 16, 2026 and June 16, 2027
  • Re-assessment Required: June 16, 2028

Conditions for Final Certification

To convert this conditional certification to final status, ACME Technology Services Corporation must:

  1. Complete all 18 POA&M items within 180 days
  2. Engage a C3PAO for POA&M closeout assessment
  3. Demonstrate full implementation of all 110 NIST SP 800-171 controls
  4. Submit evidence packages for all remediated controls

Assessor Signature

Lead Certified CMMC Assessor: Sarah Mitchell, CCA-2024-156

Date: June 16, 2025

C3PAO: SecureAssess C3PAO LLC