CMMC scoping focuses on assets that process, store, transmit, or protect CUI. A smoke detector connected to the OSC network is an IoT device with no impact on CUI, so it is considered Out-of-Scope. The other items (data centers used by the OSC, MSP SIEM tools, and MSP offices handling OSC management) all directly affect the OSC’s CUI environment and therefore fall within scope.
Exact extracts:
“CUI Assets are those that process, store, or transmit CUI.”
“Security Protection Assets are those that provide security functions for CUI Assets.”
“External Service Providers (e.g., MSPs, data centers, SIEMs) that support CUI Assets are in-scope.”
“Assets that cannot affect the confidentiality of CUI (e.g., unrelated IoT devices) are considered Out-of-Scope.”
Expanded explanation:
Data centers (A): If OSC CUI is stored or processed there, they are in-scope.
SIEM tools (C): Provide security monitoring of OSC networks — a clear Security Protection Asset.
MSP office (D): MSPs providing services that affect CUI are in-scope, including their management locations.
Smoke detector (B): Despite being network-connected, it does not interact with CUI or provide protective functions; it is explicitly out-of-scope.
Why the other options are in scope:
They either process, protect, or manage CUI directly.
Excluding them would improperly narrow the assessment boundary.
[References:, CMMC Scoping Guide – Level 2, definitions of CUI Assets, Security Protection Assets, and Out-of-Scope Assets., , ]
