To develop an assessment contract and establish a scope of work, which organization does an...

Under the official CMMC Assessment Process (CAP) v2.0 , the OSC contracts directly with a C3PAO to arrange a Level 2 certification assessment, including the practical scope-of-work elements (timing, logistics, and the terms of performance). CAP v2.0 explicitly states that “The C3PAO shall execute a written contractual agreement for the CMMC Level 2 certification assessment with the OSC” and further clarifies that neither the Cyber AB nor DoD are parties to that contract.

Because the C3PAO is the assessment organization that conducts the certification assessment, it is also the entity the OSC coordinates with during the pre-assessment activities that shape the engagement and scope. CAP v2.0 places key Phase 1 responsibilities on the C3PAO/Lead CCA, including validating the OSC’s assessment scope against applicable scoping requirements and coordinating access to evidence and personnel needed for Phase 2.

By contrast, OUSD provides DoD-level oversight/policy, RPOs and the Cyber AB support the ecosystem, but they do not form the contractual relationship for a specific Level 2 certification assessment. CAP v2.0 is unambiguous that the contract (and any mutually agreed scope-of-work terms) is between the OSC and the C3PAO .

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