According to the CMMC Scoping Guidance, Level 1, the scope of an assessment includes all assets that process, store, or transmit Federal Contract Information (FCI). CMMC is " information-centric, " meaning the security requirements apply to the information itself, regardless of the media it resides on (digital or physical).
Asset Identification: In a Level 1 assessment, assets are categorized as either FCI Assets or Out-of-Scope Assets. Since the file cabinet is explicitly identified as containing paper FCI, it meets the definition of an asset that stores the protected information.
Basic Safeguarding (FAR 52.204-21): The 17 practices of CMMC Level 1 are derived from the FAR clause for the " Basic Safeguarding of Covered Contractor Information Systems. " However, the physical protection requirements within that set (such as PE.L1-3.10.1, which requires limiting physical access to organizational information systems and equipment) extend to the physical storage locations of that data.
Media Neutrality: CMMC documentation emphasizes that " information systems " include the physical components and the information processed by them. If FCI is printed and stored in a cabinet, that cabinet becomes a physical storage asset within the assessment boundary.
Why other options are incorrect:
Option B: Physical location alone does not bring an asset into scope. For example, a coffee machine in the same room as an FCI computer remains out of scope because it doesn ' t handle FCI. Thecontent(FCI) makes the cabinet in-scope, not its proximity.
Option C: CMMC and the underlying FAR clause do not exempt paper-based information. Protected data must be secured whether it is on a hard drive or a printed sheet.
Option D: While a file cabinet may not " process " or " transmit " data like a computer does, it absolutely stores it. The definition of the scope includes all three functions (process, store, or transmit).
Reference Documents:
CMMC Scoping Guidance, Level 1: Section 2.0 (CMMC Level 1 Asset Categories), which defines FCI Assets as those that process, store, or transmit FCI.
CMMC Assessment Guide, Level 1: Discussion on Physical Protection (PE) practices and their application to physical media.
32 CFR Part 170 (CMMC Program Rule): Definitions of FCI and the requirements for contractor self-assessments.
