OSC — What do I document?

Advisory • Assurance • Audit — The Foundation of Readiness

The CMMC SSP that survives a C3PAO review is an objective-level document, paired with an evidence matrix that points the assessor to the relevant artifacts for each of the ~320 NIST SP 800-171A objectives. NIST SP 800-171 sets the floor; 32 CFR and the CMMC Assessment Process v2.0 layer additional requirements on top. ESP/CSP documentation, the Customer Responsibility Matrix, and Pre-Assessment Form completeness. For a small contractor with a contained CUI scope, a defensible SSP can easily run up to 80 to 150 pages.

What Goes In a CMMC System Security Plan That Survives a C3PAO Review

The CMMC SSP that survives a C3PAO review is an objective-level document, paired with an evidence matrix that points the assessor to the relevant artifacts for each of the ~320 NIST SP 800-171A objectives. NIST SP 800-171 sets the floor; 32 CFR and the CMMC Assessment Process v2.0 layer additional requirements on top. ESP/CSP documentation, the Customer Responsibility Matrix, and Pre-Assessment Form completeness. For a small contractor with a contained CUI scope, a defensible SSP can easily run up to 80 to 150 pages.
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The CMMC Verb Test: How to Decode What Your Assessor Is Actually Looking For

The CMMC Level 2 Assessment Guide does not score 110 controls — it scores ~320 individual NIST SP 800-171A objectives, and each objective contains a single verb that tells the assessor exactly what evidence type is required. Documentation verbs (“defined,” “specified,” “documented,” “established,” “identified”) demand written artifacts. Operational verbs (“monitored,” “implemented,” “enforced,” “performed,” “tested”) demand live evidence — logs, configs, dated records. Context-dependent verbs (“controlled,” “authorized,” “reviewed”) require both. A policy can never satisfy an operational verb; a log can never satisfy a documentation verb. Match the evidence to the verb and you have 80% of the readiness work done.
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Heather Smith

Herrington Editor Post Blog

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