Recently, the CMMC-AB released the online training modules for those who signed up to become Registered Practitioners (RP’s) within the CMMC-AB environment. 2 members of TechSage Solutions, John Hill and myself (Warren Hylton), put in applications to become RPs back in July, so we were very excited to see this training released.

Although the training material is proprietary to the CMMC-AB and confidential, there are several takeaways from this training that I can share, and I do believe these insights are extremely beneficial to any organization seeking certification (OSC) from the CMMC-AB.

To keep things in perspective, the CMMC-AB only recently trained the first class of Assessors, known temporarily as Provisional Assessors, and only recently, authorized 11 organizations as Licensed Partner Publishers (LPPs) to produce the CMMC training materials for general usage. The RP training then is one of the first few training processes of the CMMC-AB. Registered Practitioner Organizations (RPOs) and Certified Third Party Assessor Organizations (C3PAOs) have yet to receive guidance on training, so the overall training provided from the CMMC-AB is still early in its deployment.

But instead of the information gained from the RP training being limited due to the early positioning in the overall CMMC-AB training deployment, this RP training was full of great information on how the pre-assessment and assessment procedures will play out.

A note to any OSC (organization seeking certification) reading this, the CMMC-AB has stated that Registered Practitioners will be trained to provide correct assistance to OSCs as they prepare for a CMMC assessment. This means that the RP training information speaks directly to many of the questions that OSCs currently have.

Instead of relating module by module the content that was covered (which I couldn’t do anyways), I will share 3 key takeaways that matter to OSCs today at the end of calendar year 2020.

First, evidence, evidence, evidence! There is going to be an excellent opportunity for OSCs to prepare for an assessment before contacting a C3PAO for an official one. The CMMC-AB is really leaving the door open for work that is done before an assessment to help contribute to the work needed for the actual assessment. This should be taken as excellent news for any OSC as reducing costs and time related to the assessment is going to be critical since the original assessors are not going to come cheap. Keep in mind that the CMMC-AB has only trained a limited number of assessors and has set the experience for these first professionals quite high. This means an OSC can expect to pay for far travel and an experienced professional when it comes to their CMMC assessment. Doing work before the assessment that can be used during the official assessment will be an excellent opportunity for cost savings.

Second, all OSCs need to be aware that there will continue to be many organizations and individuals that will over-promise and under-deliver when it comes to CMMC related services. There has already been much of this with some companies promising things that no one is authorized to provide. Unfortunately for the OSC, the CMMC-AB is lowering the bar when it comes to who can perform pre-assessment services. At this point, any individual will be able to “help” an OSC prepare for a CMMC assessment, and although this sounds like it would actually benefit the OSC, it actually setups a situation where an OSC can pay someone for services that are going to be worthless. If the CMMC-AB said that pre-assessment work and assessment work had to be done by recognized entities, then OSCs could have more confidence in the services they will receive. But the CMMC-AB has not, so as an OSC, be very careful to ensure the person “helping” you is doing work that will count down the road when the professionals get involved.

Third, there is going to be an opportunity for competitive advantage in the early days of CMMC. The CMMC-AB has already said the first OSCs to get assessments will be OSCs that are bidding on contracts with a CMMC requirement. But the CMMC-AB will also allow other OSCs to request an assessment. Being that the whole roll out of CMMC requirements across all DoD contracts will take 5 years, there is going to be an opportunity for early adopters to differentiate themselves from their competition. In an industry as competitive as federal contracting, this should be seen as an excellent, yet fleeting opportunity.

All in all, the Registered Practitioner training was extremely beneficial and helped to show more clearly the path going forward for OSCs and other entities involved in the CMMC ecosystem. The other professional roles within the CMMC ecosystem will be getting trained between now and the early part of 2021, and if those trainings are of the same quality as the RP training, then the professionals registered and certified by the CMMC-AB will really know what they are doing.