While FedRAMP Moderate aligns closely with CMMC Level 2, they are separate frameworks. The CCP must still perform due diligence by mapping the FedRAMP controls to the applicable CMMC practices and verifying through assessment (e.g., reviewing the CSP’s customer responsibility matrix, security assessment report) that the practices are implemented and meet CMMC’s specific objectives. Blind inheritance is not permitted.

The core issue is the uncontrolled flow of CUI to an external, unauthorized system. Practice AC.L2-3.1.20 explicitly requires limiting data flows to manage and control the transfer of information between authorized endpoints. The use of an unsanctioned service violates this control by creating an unmanaged and potentially insecure data flow.

CMMC recognizes that not all systems can meet every technical requirement. The correct process is to formally document the limitation, conduct a risk assessment (as part of the Risk Management process, RM.L2-3.11.1), and establish a plan of action & milestones (POA&M) with approved compensating controls (like increased monitoring, network segmentation, or multi-factor authentication) to mitigate the increased risk. Outright denial or approval without analysis is not a professional risk management approach.

You cannot protect what you do not know exists. The asset inventory is the foundational security control that defines the scope of your CMMC assessment. It allows you to systematically apply other practices (like vulnerability management, configuration management, and access control) to all assets that process, store, or transmit CUI. While it may serve secondary purposes, its core security function is scope definition and targeted protection.

This is a classic phishing attempt (note the slight domain mismatch: ‘yourcompany-support.com’ vs. the legitimate domain). Practice AT.L2-3.2.3 requires providing literacy training on recognizing and reporting indicators of malicious activity, such as phishing. While IR deals with responding after an incident, and IA deals with credential systems, the first line of defense is user awareness trained under the AT family.

MP.L2-3.8.3 requires protecting and controlling access to media. Using default credentials is a severe security flaw explicitly prohibited by controls like IA.L2-3.5.10, which requires changing default passwords. Physical access does not mitigate this logical access vulnerability. The other options are positive controls: sanitization (MP.L2-3.8.4), authentication (AC.L2-3.1.5), and controlling data flow (AC.L2-3.1.20).

This is a fundamental distinction in the CMMC model. Practices (e.g., ‘Employ spam protection mechanisms’) are the specific activities/controls an assessor will check for evidence of implementation. Processes (maturity levels 4-5) refer to the organization’s established, documented, resourced, and reviewed methodologies for managing and improving its capabilities. The CCP must understand that achieving a level requires implementing the specified practices through institutionalized processes.

Practice IR.L2-3.6.1 requires establishing a capable incident-handling program. A key component of capability is availability. If the primary point of contact is not available as defined in the plan’s timeline, the capability is not fully operational. The exercise (testing per IR.L2-3.6.3) revealed this flaw. The finding should lead to updating the plan to include a backup contact or escalation path to ensure 24/7 capability.

This scenario tests the principle of least privilege and timely access revocation (AC.L2-3.1.3, 3.1.5). The most secure and compliant method is to have a formal, approved process for elevating privileges temporarily. This process should include proper authorization, logging of the grant (AU.L2-3.3.1), and automatic or prompt revocation once the need is fulfilled. Permanent grants, informal requests, and credential sharing violate core access control practices.

While FedRAMP Moderate aligns closely with CMMC Level 2, they are separate frameworks. The CCP must still perform due diligence by mapping the FedRAMP controls to the applicable CMMC practices and verifying through assessment (e.g., reviewing the CSP’s customer responsibility matrix, security assessment report) that the practices are implemented and meet CMMC’s specific objectives. Blind inheritance is not permitted.0