What’s This About CMMC Assessment Objectives?
- David Sutherin
- Mar 4
- 3 min read
Organizations often find themselves confused – and sometimes surprised – by the differentiation between the 110 “practices” required for NIST SP 800-171 compliance and CMMC Level 2 certification and the 320 “assessment objectives” outlined in NIST SP 800-171A and the Department of Defense (DoD) Chief Information Officer’s CMMC Assessment Guide.
Many businesses prepare diligently to meet the 110 practices listed in NIST SP 800-171, only to discover that demonstrating compliance requires satisfying a more detailed set of 320 assessment objectives. This article explores the key differences between practices and assessment objectives, as well as how they work together to ensure a robust cybersecurity posture.
Understanding CMMC Practices vs. Assessment Objectives
CMMC Practices
At the core of CMMC Level 2 certification are 110 practices derived from NIST SP 800-171. These practices are organized into 14 families, covering essential security requirements. These practices define what your organization must do to protect Controlled Unclassified Information (CUI). However, they are intentionally high-level to allow flexibility in implementation. For example, a practice may state that an organization must “control remote system access,” but it doesn’t specify exactly how to achieve that control.
Assessment Objectives
The DoD CIO CMMC Assessment Guide, based on NIST SP 800-171A Assessing Security Requirements for Controlled Unclassified Information, breaks down each of the 110 practices into multiple assessment objectives – 320 in total. These objectives provide detailed criteria that assessors use to verify that each practice is effectively implemented.
While practices focus on what needs to be done, assessment objectives focus on how and how effectively an organization has implemented the practices. Assessment objectives require evidence of compliance, including documented policies, system configurations, user activity logs, and other artifacts demonstrating that security measures are in place and functioning as intended to protected CUI.
For example, if a practice requires you to “control remote system access,” the assessment objectives might specify that you must:
Identify remote access methods (e.g., RDP, SSH).
Verify the methods for securing remote access (e.g., encryption, source system restrictions).
Confirm logging and monitoring of remote access sessions (e.g., successful/failed logins, session activity).
Why Are Assessment Objectives Important?
Assessment objectives provide the detailed criteria needed to measure compliance rigorously and consistently. They ensure that NIST SP 800-171 and CMMC assessments are objective and standardized across different assessors and organizations.
For organizations preparing for an assessment, understanding and addressing all relevant assessment objectives is essential for passing the evaluation. Simply implementing the 110 practices isn’t enough – organizations must also demonstrate that each practice is fully operational, properly documented, and consistently enforced through artifacts supporting the assessment objectives.
Common Challenges and Misconceptions
Many organizations are caught off guard by the depth of evidence required for assessment objectives. Common challenges include:
Insufficient Documentation: Organizations often implement security measures but fail to document policies, procedures, and configurations adequately.
Lack of Objective Evidence: Verbal explanations of security practices aren’t enough. Assessors require objective evidence, such as system logs, screenshots, and configuration files.
Overlooking Interdependencies: Some assessment objectives overlap across multiple practices, requiring a coordinated approach to satisfy all criteria.
Neglecting to address all assessment objectives can lead to incomplete compliance preparations, which can result in delays or even failures during a formal assessment.
How to Prepare for Assessment Objectives
To successfully meet assessment objectives, organizations should:
Conduct a Gap Analysis: Compare current security controls against the assessment objectives to identify gaps in documentation, implementation, and evidence collection.
Develop Thorough Document: Comprehensive documentation is crucial to compliance as it gives assessors a starting point to understand your organization's practices. This includes policies, standard operating procedures, and evidence artifacts.
Test and Validate Controls: Regularly test security controls to ensure they work as intended and generate the required objective evidence.
Train Staff and Stakeholders: Ensure that personnel understand their roles in maintaining compliance and are familiar with documented processes.
By proactively addressing assessment objectives, organizations can reduce the risk of non-compliance and increase their readiness for a successful assessment.
How Triumvirate Cybersecurity Can Help
Triumvirate Cybersecurity is dedicated to helping organizations achieve and maintain compliance with NIST SP 800-171 confidently and efficiently. Our team of certified consultants has deep expertise in both implementing and demonstrating compliance with the NIST SP 800-171 and CMMC assessment objectives.
With Triumvirate Cybersecurity’s expert guidance, you can navigate the complexities of assessment objectives and achieve full compliance, positioning your business for success in the government supply chain. Contact us today to learn how we can help you achieve compliance and develop confidence in your cybersecurity posture!
