What the assessment actually tests
An assessment is not a review of your policy binder. It is evidence that the 110 NIST SP 800-171 requirements are in place, operating, and documented for the system boundary on the contract. If you need the requirements themselves, start with CMMC Level 2; this page covers the assessment process and the evidence an assessor will ask for.
The three paths to a Level 2 result
| Path | Who runs it | What you get | When it applies |
|---|---|---|---|
| Self-assessment | You | An SPRS score you submit yourself | Some contracts, and as a prerequisite step before a C3PAO assessment |
| C3PAO assessment | Certified third-party assessor | Certification, valid for three years | Contracts that require Level 2 certification |
| Government-led assessment | DoD assessors | Assessment result | Selected contracts, typically larger or higher-risk |
The self-assessment is not a lighter version of certification — it is a different mechanism. Doing it well is what makes a C3PAO assessment survivable.
What an assessor reads first
- Your system security plan (3.12.4). It defines scope, boundary, data flows and how each requirement is met. Without it, the assessment does not start.
- Your POA&M. Every unmet requirement with an owner, a date and a remediation plan. A POA&M with vague dates is a finding waiting to happen.
- Evidence per requirement. Screenshots age badly. Configuration exports, policy documents with revision history, and tickets that show the control operating are worth more than a folder of PNGs.
- Consistency. The most common failure is not a missing control — it is a control that exists in the SSP, is described one way in the policy, and is configured another way in production.
Realistic timeline for a small contractor
| Stage | Typical duration | What happens |
|---|---|---|
| Scoping | 1–3 weeks | Define the boundary, find where CUI actually lives, decide what is in scope |
| Gap assessment | 2–4 weeks | Score all 110, build the POA&M, cost the remediation |
| Remediation | 3–9 months | Technical controls, policy writing, SSP, evidence collection |
| C3PAO assessment | 4–8 weeks | Document review, interviews, technical testing, findings |
| Close-out | 2–6 weeks | Fix findings, submit, receive certification |
Remediation is the long pole. Almost every contractor underestimates it — the assessment itself is the short part.
The five requirements that sink first-time assessments
| Requirement | What assessors find |
|---|---|
| 3.5.3 MFA | Enabled on email, missing on VPN, admin consoles or cloud tenants |
| 3.13.11 FIPS-validated crypto | Encryption exists but is not a FIPS-validated module |
| 3.3.1 / 3.3.5 Audit logging & review | Logs collected, never reviewed; retention shorter than required |
| 3.12.3 Continuous monitoring | Controls assessed once, then not revisited |
| 3.4.1 / 3.4.2 Baselines & settings | No documented baseline, no evidence of enforcement |
Start with the number
Before any of this, you need to know how far you are from 110. The calculator takes about 15 minutes and gives you a point gap by family.
Calculate my SPRS scoreRelated: What Level 2 requires · The 110-point checklist · Running a self-assessment · Software that tracks this