Level 1 Self-Assessment Guide

Source of Reference: The official CMMC Level 1 Self-Assessment Guide Version 2.13, September 2024 from the Department of Defense Chief Information Officer (DoD CIO).

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NOTICES

The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or departmental policies.

DISTRIBUTION STATEMENT A. Approved for public release. Distribution is unlimited.

Introduction

This document provides guidance in the preparation for and execution of a Level 1 self-assessment under the Cybersecurity Maturity Model Certification (CMMC) Program as set forth in section 170.15 of title 32, Code of Federal Regulations (CFR). Guidance for conducting a Level 2 self-assessment or certification assessment can be found in CMMC Assessment Guide – Level 2. Guidance for conducting a Level 3 certification assessment can be found in CMMC Assessment Guide – Level 3. More details on the CMMC Model can be found in CMMC Model Overview.

Level 1 focuses on the protection of Federal Contract Information (FCI), which is defined in 32 CFR § 170.4 and 48 CFR § 4.1901:

Federal contract information means information, not intended for public release, that is provided by or generated for the Government under a contract to develop or deliver a product or service to the Government, but not including information provided by the Government to the public (such as on public websites) or simple transactional information, such as necessary to process payments.

Level 1 is comprised of the 15 basic safeguarding requirements specified in Federal Acquisition Regulation (FAR) Clause 52.204-21.

Purpose and Audience

This guide is intended for Organizations Seeking Assessment (OSAs), cybersecurity professionals, and individuals and companies that support CMMC efforts. This document can be used as part of preparation for and conducting a Level 1 self-assessment.

Document Organization

This document is organized into the following sections:

• Assessment and Compliance: provides an overview of the Level 1 self-assessment process set forth in 32 CFR § 170.15, describes ways of documenting compliance, and provides guidance regarding OSA size and the self-assessment scope requirements set forth in 32 CFR § 170.19.
• CMMC-Custom Terms: incorporates definitions from 32 CFR § 170.4 and definitions included by reference from 32 CFR § 170.2, and provides clarification of the intent and scope of custom terms as used in the context of CMMC.
• Assessment Criteria and Methodology: provides guidance on criteria and methodology (i.e., interview, examine, and test) that may be employed during a Level 1 self-assessment, as well as on assessment findings.
• Requirement Descriptions: provides guidance specific to each Level 1 security requirement.

Assessment and Compliance

Level 1 self-assessment requirements are set forth in 32 CFR § 170.15. The OSA will assess its own contractor information system(s) to determine if it meet all the basic safeguarding requirements for FCI specified in FAR Clause 52.204-21. OSAs should use the self-assessment methods as described in 32 CFR § 170.15.

Level 1 requirements may apply to an entire enterprise infrastructure or to a particular enclave(s), depending upon where the FCI will be processed, stored, or transmitted.

OSAs can choose to perform the annual self-assessment internally or engage a third party to assist. Use of a third party to assist is still considered a self-assessment and does not result in a certification. The primary result of a self-assessment is the submission of Level 1 compliance results into the Supplier Performance Risk System (SPRS) and a self-assessment report, which contains the findings associated with the self- assessment.

Assessment Scope

Prior to conducting a Level 1 self-assessment, the OSA must specify the CMMC Assessment Scope as defined in 32 CFR § 170.19(a). The CMMC Assessment Scope identifies which assets within the OSA’s environment will be assessed and the details of the self-assessment. In accordance with §170.19, for a Level 1 self-assessment, the assets that process, store, or transmit FCI are considered in-scope and should be assessed against the Level 1 requirements. See the CMMC Scoping Guide – Level 1 document for additional information.

CMMC-Custom Terms

The CMMC Program has custom terms that align with program requirements. Although some terms may have other definitions in open forums, it is important to understand these terms as they apply to the CMMC Program.

The custom terms associated with Level 1 are:

• Assessment: As defined in 32 CFR § 170.4 means the testing or evaluation of security controls to determine the extent to which the controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for an information system or organization, as defined in 32 CFR § 170.15 to 32 CFR § 170.18.
  • Level 1 self-assessment is the term for the activity performed by an OSA to evaluate its own information system, when seeking a CMMC Status of Final Level 1 (Self).
• Assessment Objective: A set of determination statements that, taken together, expresses the desired outcome for the assessment of a security requirement. Successful implementation of the corresponding CMMC security requirement requires meeting all applicable assessment objectives defined in NIST SP 800–171A or NIST SP 800-172A.
• Asset: An item of value to stakeholders. An asset may be tangible (e.g., a physical item such as hardware, firmware, computing platform, network device, or other technology component) or intangible (e.g., humans, data, information, software, capability, function, service, trademark, copyright, patent, intellectual property, image, or reputation). The value of an asset is determined by stakeholders in consideration of loss concerns across the entire system life cycle. Such concerns include but are not limited to business or mission concerns, as defined in NIST SP 800-160 Rev 1.
• CMMC Status: As defined in 32 CFR § 170.4 is the result of meeting or exceeding the minimum required score for the corresponding assessment. The CMMC Status of an OSA information system is officially stored in SPRS and additionally presented on a Certificate of CMMC Status, if the assessment was conducted by a C3PAO or DCMA DIBCAC.
  • Final Level 1 (Self) is defined in § 170.15(c)(1). To achieve a CMMC Status of Final Level 1 (Self) the OSA must conduct a Level 1 self-assessment scored in accordance with the CMMC Scoring Methodology described in § 170.24. The Level 1 self-assessment must be performed in accordance with the Level 1 scope requirements set forth in § 170.19(a) and (b). In instances where an objective addresses CUI, the term FCI should be substituted for CUI.
• Component: A discrete identifiable information technology asset that represents a building block of a system and may include hardware, software, and firmware. A component is one type of asset.
• Enduring Exception: A special circumstance or system where remediation and full compliance with CMMC security requirements is not feasible. Examples include systems required to replicate the configuration of ‘fielded’ systems, medical devices, test equipment, OT, and IoT. No operational plan of action is required but the circumstance must be documented within a system security plan. Specialized Assets and GFE may be Enduring Exceptions.
• Information System (IS): A discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information [NIST 800-171 Rev. 2]. An IS is one type of asset.
• Monitoring: Continual checking, supervising, critically observing, or determining the status in order to identify change from the performance level required or expected [NIST SP 800-160 Vol 1].
• Operational plan of action: As used in security requirement CA.L2-3.12.2, means the formal artifact which identifies temporary vulnerabilities and temporary deficiencies in implementation of requirements and documents how and when they will be mitigated, corrected, or eliminated. The OSA defines the format (e.g., document, spreadsheet, database) and specific content of its operational plan of action. An operational plan of action is not the same as a POA&M associated with an assessment.
• Organization-Defined: As determined by the OSA being assessed except as defined in the case of Organization-Defined Parameter (ODP). This can be applied to a frequency or rate at which something occurs within a given time period, or it could be associated with describing the configuration of an OSA’s solution.
• Temporary deficiency: As defined in 32 CFR § 170.4 means a condition where remediation of a discovered deficiency is feasible and a known fix is available or is in process. The deficiency must be documented in an operational plan of action. A temporary deficiency is not based on an ‘in progress’ initial implementation of a CMMC security requirement but arises after implementation. A temporary deficiency may apply during the initial implementation of a security requirement if, during roll-out, specific issues with a very limited subset of equipment is discovered that must be separately addressed. There is no standard duration for which a temporary deficiency may be active. For example, FIPS-validated cryptography that requires a patch and the patched version is no longer the validated version may be a temporary deficiency.

Assessment Criteria and Methodology

This CMMC Assessment Guide – Level 1 provides guidance regarding the assessment procedures required by 32 CFR § 170.15, which requires the Level 1 self-assessment to be performed using the objectives defined in NIST Special Publication (SP) 800-171A. NIST SP 800-171A Section 2.1 says the following:

An assessment procedure consists of an assessment objective and a set of potential assessment methods and assessment objects that can be used to conduct the assessment. Each assessment objective includes a determination statement related to the requirement that is the subject of the assessment. The determination statements are linked to the content of the requirement to ensure traceability of the assessment results to the requirements. The application of an assessment procedure to a requirement produces assessment findings. These findings reflect, or are subsequently used, to help determine if the requirement has been satisfied.

Assessment objects identify the specific items being assessed and can include specifications, mechanisms, activities, and individuals.

• Specifications are the document-based artifacts (e.g., policies, procedures, security plans, security requirements, functional specifications, and architectural designs) associated with a system.
• Mechanisms are the specific hardware, software, or firmware safeguards employed within a system.
• Activities are the protection-related actions supporting a system that involve people (e.g., conducting system backup operations, exercising a contingency plan, and monitoring network traffic).
• Individuals, or groups of individuals, are people applying the specifications, mechanisms, or activities described above.

The assessment methods define the nature and the extent of the assessor’s actions. The methods include examine, interview, and test.

• The examine method is the process of reviewing, inspecting, observing, studying, or analyzing assessment objects (i.e., specifications, mechanisms, activities). The purpose of the examine method is to facilitate understanding, achieve clarification, or obtain evidence.
• The interview method is the process of holding discussions with individuals or groups of individuals to facilitate understanding, achieve clarification, or obtain evidence.
• And finally, the test method is the process of exercising assessment objects (i.e., activities, mechanisms) under specified conditions to compare actual with expected behavior.

In all three assessment methods, the results are used in making specific determinations called for in the determination statements and thereby achieving the objectives for the assessment procedure.

The guidance specified in NIST SP 800-171A focuses on Controlled Unclassified Information (CUI). Since Level 1 focuses on safeguarding FCI, the applicable self-assessment objectives for Level 1 are modified to address FCI rather than CUI as set forth in 32 CFR § 170.15(c)(1)(i). Where CUI is noted in a NIST SP 800-171A assessment objective, [FCI] has been substituted in the Level 1 objective description. Level 1 security requirement descriptions align with FAR Clause 52.204-21.

Criteria

Assessment objectives are provided for each Level 1 requirement and are based on existing criteria in NIST SP 800-171A modified for FCI rather than CUI as set forth in 32 CFR § 170.15(c)(1)(i). The criteria are authoritative and provide the basis for the self-assessment of a requirement.

Methodology

To verify and validate that an OSA is meeting CMMC requirements, evidence needs to exist demonstrating that the OSA has fulfilled the objectives of the Level 1 requirements. Because different self-assessment objectives can be met in different ways (e.g., through documentation, computer configuration, network configuration, or training), a variety of techniques may be used to determine if the OSA meets the Level 1 requirements, including any of the three assessment methods from NIST SP 800-171A.

Follow the guidance in NIST SP 800-171A when determining which assessment methods to use:

Organizations [OSAs] are not expected to employ all assessment methods and objects contained within the assessment procedures identified in this publication. Rather, organizations have the flexibility to determine the level of effort needed and the assurance required for an assessment (e.g., which assessment methods and assessment objects are deemed to be the most useful in obtaining the desired results). This determination is made based on how the organization can accomplish the assessment objectives in the most cost-effective manner and with sufficient confidence to support the determination that the [FCI] requirements have been satisfied.

For more detailed information on assessment methods, see NIST SP 800-171A Appendix D.

Who Is Interviewed

Interviews of applicable staff (possibly at different organizational levels) may provide information to help an entity determine if Level 1 security requirements have been implemented, as well as if adequate resourcing, training, and planning have occurred for individuals to implement the security requirements.

What Is Examined

Examination includes reviewing, inspecting, observing, studying, or analyzing assessment objects. The objects can be documents, mechanisms, or activities.

For some security requirements, review of documentation may assist an entity in determining if the assessment objectives have been met. Interviews with staff may help identify relevant documents. As set forth in 32 CFR § 170.24, documents need to be in their final forms; drafts of policies or documentation are not eligible to be used as evidence because they are not yet official and still subject to change. Common types of documents that may be used as evidence include:

• policy, process, and procedure documents;
• training materials;
• plans and planning documents; and
• system, network, and data flow diagrams.

This list of documents is not exhaustive or prescriptive. An OSA may not have these specific documents, and other documents may be reviewed.

In other cases, the security requirement is best self-assessed by observing that safeguards are in place by viewing hardware, associated configuration information, or observing staff following a process.

What Is Tested

Testing is an important part of the self-assessment process. Interviews provide information about what the OSA staff believe to be true, documentation provides evidence of implementing policies and procedures, and testing demonstrates what has or has not been done. For example, OSA staff may talk about how users are identified, documentation may provide details on how users are identified, but seeing a demonstration of identifying users provides evidence that the requirement is met. Not all security requirements utilize testing to allow an entity to determine if whether the assessment objective has been met.

Assessment Findings

The self-assessment of a CMMC requirement results in one of three possible findings: MET, NOT MET, or NOT APPLICABLE as defined in 32 CFR § 170.24. To demonstrate Level 1 compliance, the OSA will need a finding of MET or NOT APPLICABLE on all Level 1 security requirements.

• MET: All applicable objectives for the security requirement are satisfied based on evidence. All evidence must be in final form and not draft. Unacceptable forms of evidence include working papers, drafts, and unofficial or unapproved policies. For each security requirement marked MET, it is best practice to record statements that indicate the response conforms to all objectives and document the appropriate evidence to support the response.
  • Enduring Exceptions when described, along with any mitigations, in the system security plan shall be assessed as MET.
  • Temporary deficiencies that are appropriately addressed in operational plans of action (i.e., include deficiency reviews, milestones, and show progress towards the implementation of corrections to reduce or eliminate identified vulnerabilities) shall be assessed as MET.
• NOT MET: One or more objectives of the security requirement is not satisfied. For each security requirement marked NOT MET, it is best practice to record statements that explain why and document the appropriate evidence showing that the OSA does not conform fully to all of the objectives.
• NOT APPLICABLE (N/A): A security requirement and/or objective do not apply at the time of the assessment. For each security requirement marked N/A, it is best practice to record a statement that explains why the requirement does not apply to the OSA. For example, SC.L1-b.1.xi might be N/A if there are no publicly accessible systems within the CMMC Assessment Scope. During an assessment, an assessment objective assessed as N/A is equivalent to the same assessment objective being assessed as MET.

Each assessment objective in NIST SP 800-171A must yield a finding of MET or NOT APPLICABLE in order for the overall security requirement to be scored as MET. Assessors exercise judgment in determining when sufficient and adequate evidence has been presented to make an assessment finding.

CMMC assessments are conducted and results are captured at the assessment objective level. One NOT MET Assessment Objective results in a failure of the entire security requirement.

A security requirement can be applicable even when assessment objectives included in the security requirement are scored N/A. The security requirement is NOT MET when one or more applicable assessment objectives is NOT MET.

Satisfaction of security requirements may be accomplished by other parts of the enterprise or an External Service Provider (ESP), as defined in 32 CFR § 170.4. A security requirement is considered MET if adequate evidence is provided that the enterprise or ESP implements the requirement objectives. An ESP may be external people, technology, or facilities that the OSA uses, including cloud service providers, managed service providers, managed security service providers, or cybersecurity-as-a-service providers.

Requirement Descriptions

Introduction

This section provides detailed information and guidance for assessing each Level 1 security requirement. The section is organized first by domain and then by individual security requirement. Each security requirement description contains the following elements as described in 32 CFR § 170.14(c):

• Requirement Number, Name, and Statement: Headed by the requirement identification number in the format, DD.L#-REQ (e.g., AC.L1-b.1.i); followed by the requirement short name identifier, meant to be used for quick reference only; and finally followed by the complete CMMC security requirement statement.
• Assessment Objectives [NIST SP 800-171A]: Identifies the specific set of objectives that must be met to receive MET for the requirement as defined in NIST SP 800-171A.
• Potential Assessment Methods and Objects [NIST SP 800-171A]: Describes the nature and the extent of the self-assessment actions as set forth in NIST SP 800-171A. The methods include examine, interview, and test. Self-assessment objects identify the items being assessed and can include specifications, mechanisms, activities, and individuals.
• Discussion [NIST SP 800-171 Rev. 2]: Contains discussion from the associated NIST SP 800-171 security requirement. Level 1 aligns with FAR Clause 52.204-21, which focuses on FCI, and the NIST text has been modified, as set forth in 32 CFR § 170.15(c)(1), to reflect this.
• Further Discussion:
  • Expands upon the NIST SP 800-171 Rev. 2 discussion content to provide additional guidance.
  • Contains examples illustrating application of the requirements. These examples are intended to provide insight but are not intended to be prescriptive of how the requirement must be implemented, nor are they comprehensive of all assessment objectives necessary to achieve the requirement. The assessment objectives met within the example are referenced by letter in a bracket (e.g., [a,d] for objectives “a” and “d”) within the text.
  • Examples are written from the perspective of an organization or an employee of an organization implementing solutions or researching approaches to satisfy CMMC requirements. The objective is to put the reader into the role of implementing or maintaining alternatives to satisfy security requirements. Examples are not all-inclusive or prescriptive and do not imply any personal responsibility for complying with CMMC requirements.
  • Provides potential assessment considerations. These may include common considerations for assessing the requirement and potential questions that may be asked when assessing the objectives.
• Key References: Lists the identical basic safeguarding requirement from FAR clause 52.204-21 and the pertinent security requirement from NIST SP 800-171 Rev. 2.

Access Control (AC)

AC.L1-B.1.I – Authorized Access Control [FCI Data]

SECURITY REQUIREMENT Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).

ASSESSMENT OBJECTIVES [a] authorized users are identified; [b] processes acting on behalf of authorized users are identified; [c] devices (and other systems) authorized to connect to the system are identified; [d] system access is limited to authorized users; [e] system access is limited to processes acting on behalf of authorized users; and [f] system access is limited to authorized devices (including other systems).

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AC.L1-B.1.II – Transaction & Function Control [FCI Data]

SECURITY REQUIREMENT Limit information system access to the types of transactions and functions that authorized users are permitted to execute.

ASSESSMENT OBJECTIVES [a] the types of transactions and functions that authorized users are permitted to execute are defined; and [b] system access is limited to the defined types of transactions and functions for authorized users.

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AC.L1-B.1.III – External Connections [FCI Data]

SECURITY REQUIREMENT Verify and control/limit connections to and use of external information systems.

ASSESSMENT OBJECTIVES [a] connections to external systems are identified; [b] the use of external systems is identified; [c] connections to external systems are verified; [d] the use of external systems is verified; [e] connections to external systems are controlled/limited; and [f] the use of external systems is controlled/limited.

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AC.L1-B.1.IV – Control Public Information [FCI Data]

SECURITY REQUIREMENT Control information posted or processed on publicly accessible information systems.

ASSESSMENT OBJECTIVES [a] individuals authorized to post or process information on publicly accessible systems are identified; [b] procedures to ensure FCI is not posted or processed on publicly accessible systems are identified; [c] a review process is in place prior to posting of any content to publicly accessible systems; [d] content on publicly accessible systems is reviewed to ensure that it does not include FCI; and [e] mechanisms are in place to remove and address improper posting of FCI.

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Identification and Authentication (IA)

IA.L1-B.1.V – Identification [FCI Data]

SECURITY REQUIREMENT Identify information system users, processes acting on behalf of users, or devices.

ASSESSMENT OBJECTIVES [a] system users are identified; [b] processes acting on behalf of users are identified; and [c] devices accessing the system are identified.

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IA.L1-B.1.VI – Authentication [FCI Data]

SECURITY REQUIREMENT Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.

ASSESSMENT OBJECTIVES [a] the identity of each user is authenticated or verified as a prerequisite to system access; [b] the identity of each process acting on behalf of a user is authenticated or verified as a prerequisite to system access; and [c] the identity of each device accessing or connecting to the system is authenticated or verified as a prerequisite to system access.

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Media Protection (MP)

MP.L1-B.1.VII – Media Disposal [FCI Data]

SECURITY REQUIREMENT Sanitize or destroy information system media containing Federal Contract Information before disposal or release for reuse.

ASSESSMENT OBJECTIVES [a] system media containing FCI is sanitized or destroyed before disposal; and [b] system media containing FCI is sanitized before it is released for reuse.

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Physical Protection (PE)

PE.L1-B.1.VIII – Limit Physical Access [FCI Data]

SECURITY REQUIREMENT Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.

ASSESSMENT OBJECTIVES [a] authorized individuals allowed physical access are identified; [b] physical access to organizational systems is limited to authorized individuals; [c] physical access to equipment is limited to authorized individuals; and [d] physical access to operating environments is limited to authorized.

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PE.L1-B.1.IX – Manage Visitors & Physical Access [FCI Data]

SECURITY REQUIREMENT Escort visitors and monitor visitor activity.

ASSESSMENT OBJECTIVES [a] visitors are escorted; and [b] visitor activity is monitored.

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SECURITY REQUIREMENT Maintain audit logs of physical access.

ASSESSMENT OBJECTIVES [a] audit logs of physical access are maintained.

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SECURITY REQUIREMENT Control and manage physical access devices.

ASSESSMENT OBJECTIVES [a] physical access devices are identified; [b] physical access devices are controlled; and [c] physical access devices are managed.

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System and Communications Protection (SC)

SC.L1-B.1.X – Boundary Protection [FCI Data]

SECURITY REQUIREMENT Monitor, control, and protect organizational communications (i.e., information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of the information systems.

ASSESSMENT OBJECTIVES [a] the external system boundary is defined; [b] key internal system boundaries are defined; [c] communications are monitored at the external system boundary; [d] communications are monitored at key internal boundaries; [e] communications are controlled at the external system boundary; [f] communications are controlled at key internal boundaries; [g] communications are protected at the external system boundary; and [h] communications are protected at key internal boundaries.

DoD Assessment Scoring Value: 5

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SC.L1-B.1.XI – Public-Access System Separation [FCI Data]

SECURITY REQUIREMENT Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.

ASSESSMENT OBJECTIVES [a] publicly accessible system components are identified; and [b] subnetworks for publicly accessible system components are physically or logically separated from internal networks.

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System and Information Integrity (SI)

SI.L1-B.1.XII – Flaw Remediation [FCI Data]

SECURITY REQUIREMENT Identify, report, and correct information and information system flaws in a timely manner.

ASSESSMENT OBJECTIVES [a] the time within which to identify system flaws is specified; [b] system flaws are identified within the specified time frame; [c] the time within which to report system flaws is specified; [d] system flaws are reported within the specified time frame; [e] the time within which to correct system flaws is specified; and [f] system flaws are corrected within the specified time frame.

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SI.L1-B.1.XIII – Malicious Code ProTection [FCI Data]

SECURITY REQUIREMENT Provide protection from malicious code at appropriate locations within organizational information systems.

ASSESSMENT OBJECTIVES [a] designated locations for malicious code protection are identified; and [b] protection from malicious code at designated locations is provided.

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SI.L1-B.1.XIV – Update Malicious Code Protection [FCI Data]

SECURITY REQUIREMENT Update malicious code protection mechanisms when new releases are available.

ASSESSMENT OBJECTIVES [a] malicious code protection mechanisms are updated when new releases are available.

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SI.L1-B.1.XV – System & File Scanning [FCI Data]

SECURITY REQUIREMENT Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed.

ASSESSMENT OBJECTIVES [a] the frequency for malicious code scans is defined; [b] malicious code scans are performed with the defined frequency; and [c] real-time malicious code scans of files from external sources as files are downloaded, opened, or executed are performed.

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Appendix A – Acronyms and Abbreviations

AC	Access Control
CD-ROM	Compact Disk Read-Only Memory
CFR	Code of Federal Regulations
CMMC	Cybersecurity Maturity Model Certification
CUI	Controlled Unclassified Information
CVE	Common Vulnerabilities and Exposures
CWE	Common Weakness Enumeration
DFARS	Defense Federal Acquisition Regulation Supplement
DMZ	Demilitarized Zone
DoD	Department of Defense
ESP	External Service Provider
FAR	Federal Acquisition Regulation
FCI	Federal Contract Information
IT	Information Technology
NIST	National Institute of Standards and Technology
OSA	Organization Seeking Assessment
PIV	Personal Identity Verification
SC	System and Communications Protection
SI	System and Information Integrity
SP	Special Publication
SPRS	Supplier Performance Risk System
USB	Universal Serial Bus
UUENCODE	Unix-to-Unix Encode
VLAN	Virtual Local Area Network