TheCybersecurity Maturity Model Certification (CMMC) Assessment Process (CAP)outlines strict guidelines regardingconflicts of interest (COI)to ensure the integrity and impartiality of assessments conducted byCertified Third-Party Assessment Organizations (C3PAOs)andCertified Assessors (CAs).
The scenario presented involves apotential conflict of interestdue to a prior relationship (former college roommate) between thecertified assessorand an individual at theOrganization Seeking Certification (OSC). While this prior relationship does not automatically disqualify the assessor, it must bedisclosed, documented, and mitigated appropriately.
Inform the OSC and C3PAO of the Potential Conflict of Interest
TheCMMC Code of Professional Conduct (CoPC)requires assessors to disclose any potential conflicts of interest.
Transparency ensures that all parties, including theOSC and C3PAO, are aware of the situation.
Document the Conflict and Mitigation Actions in the Assessment Plan
PerCMMC CAP documentation, potential conflicts should be assessed based on their material impact on the objectivity of the assessment.
The conflict and proposed mitigation strategies must beformally recorded in the assessment planto provide an audit trail.
Determine If the Mitigation Actions Are Acceptable
If theOSC and C3PAOdetermine that the mitigation actions adequatelyeliminate or reduce the risk of bias, the assessment may proceed.
Common mitigation strategies include:
Assigning another assessor forinterviews with the conflicted individual.
Ensuring thatdecisions regarding the OSC’s compliance are reviewed independently.
Proceed with the Assessment If Mitigation Is Acceptable
If the mitigation actions sufficiently address the conflict, the assessment may continue understrict adherence to documented procedures.
CMMC Conflict of Interest Handling Process
A. Do not inform the OSC and the C3PAO of the possible conflict of interest, and continue as planned.❌Incorrect. This violates CMMC’s integrity requirements and could result indisciplinary actions against the assessor or invalidation of the assessment. Transparency is mandatory.
B. Inform the OSC and the C3PAO of the possible conflict of interest, and start the entire process over without the conflicted team member.❌Incorrect. The CAP doesnotmandate immediate reassignment unless the conflict isunresolvable. Instead, mitigation strategies should be considered first.
C. Inform the OSC and the C3PAO of the possible conflict of interest but since it has been an acceptable amount of time since college, no conflict of interest exists, and continue as planned.❌Incorrect.The passage of time alone does not automatically eliminate a conflict of interest. Proper documentation and mitigation are still required.
Why the Other Answers Are Incorrect
CMMC Assessment Process (CAP) Document– Defines COI requirements and mitigation actions.
CMMC Code of Professional Conduct (CoPC)– Outlines ethical responsibilities of assessors.
CMMC Accreditation Body (Cyber-AB) Guidance– Provides rules on conflict resolution.
CMMC Official ReferencesThus,option D is the most correct choice, as it aligns with the official CMMC conflict of interest procedures.
