CMMC Vendor Assessment Template

CMMC compliance extends beyond your four walls. Every vendor processing, storing, or transmitting CUI must demonstrate equivalent security maturity—making vendor assessment non-negotiable for defense contractors.

The CMMC Vendor Assessment Template translates the Department of Defense's security requirements into actionable vendor evaluation criteria. Unlike generic security questionnaires, this template directly maps to CMMC practices and processes, allowing you to verify third-party compliance before contract execution.

For TPRM managers juggling multiple frameworks, the template serves double duty: it satisfies CMMC flow-down requirements while providing evidence for broader compliance programs. Financial services firms use it to assess fintech vendors handling sensitive data. Healthcare organizations adapt it for medical device manufacturers. Technology companies apply it to cloud service providers accessing customer environments.

The template's structure mirrors CMMC's domain organization, simplifying control mapping and gap identification. Each section includes specific evidence requests, acceptable documentation types, and scoring criteria aligned with maturity level requirements.

Core Components of the CMMC Vendor Assessment Template

Access Control (AC) Domain Assessment

The template evaluates 22 distinct access control practices across maturity levels. Level 1 focuses on basic authentication—does the vendor enforce unique user IDs and passwords? Level 2 examines privileged access management, session controls, and remote access protocols. Level 3+ requires evidence of advanced controls: risk-based authentication, privileged access workflows, and automated de-provisioning.

Evidence collection for AC controls demands specificity. Request screenshots of identity provider configurations, sample access reviews from the past 90 days, and privileged access management (PAM) tool reports. Vendors claiming Level 3 maturity must demonstrate cryptographic verification of remote sessions and documented approval chains for elevated permissions.

Asset Management (AM) and Configuration Management (CM)

These domains reveal operational maturity through inventory accuracy and change control discipline. The template requires vendors to provide:

• Current hardware and software inventories with classification tags
• Configuration baseline documentation for CUI-processing systems
• Change advisory board (CAB) meeting minutes from the past quarter
• Automated configuration monitoring tool outputs

Red flags include Excel-based inventories updated "as needed" or change processes that bypass security review for "emergency" updates. Strong vendors provide real-time dashboards, automated discovery outputs, and change failure rates below 5%.

Incident Response (IR) and Recovery (RE) Capabilities

CMMC Levels 2-5 mandate documented incident response plans with defined escalation paths. The template tests these claims through scenario-based questions and evidence requests:

Scenario Questions:

• Describe your response to a ransomware attack affecting CUI systems
• Detail notification procedures for customer data exposure
• Explain recovery time objectives (RTO) for critical systems

Required Evidence:

• Incident response plan with contact trees
• Post-incident review reports from actual events
• Tabletop exercise results from the past 12 months
• Backup restoration test results

Risk Management (RM) Framework Integration

The template evaluates how vendors identify, assess, and mitigate risks to CUI. Strong responses include:

• Risk register excerpts showing CUI-related entries
• Supply chain risk assessment methodologies
• Continuous monitoring dashboards
• Remediation timelines for identified vulnerabilities

Pay attention to risk appetite statements and exception processes. Vendors accepting high risks to CUI systems or maintaining numerous policy exceptions raise immediate concerns.

Industry-Specific Applications

Financial Services Adaptation

Banks and investment firms modify the template to address Interagency Guidelines and FFIEC requirements. Additional controls cover:

• Gramm-Leach-Bliley Act (GLBA) safeguards for non-public personal information
• SOX controls for financial reporting systems
• PCI DSS requirements for payment processors

Evidence requests expand to include examination reports, audit findings, and regulatory correspondence. Risk tiering incorporates systemic importance and transaction volumes alongside CUI access levels.

Healthcare Sector Modifications

Healthcare entities layer HIPAA requirements onto CMMC controls. The template adapts to evaluate:

• Business Associate Agreement (BAA) compliance
• PHI encryption standards (beyond CUI requirements)
• Medical device cybersecurity per FDA guidance
• Breach notification procedures under HITECH

Evidence collection emphasizes operational controls: access logs, encryption certificates, and workforce training records. Vendors must demonstrate HIPAA-compliant incident response separate from CMMC requirements.

Technology Industry Customization

SaaS providers and technology integrators focus on API security, multi-tenancy controls, and development practices. The template expands to cover:

• Secure SDLC implementation evidence
• Penetration testing results for customer-facing systems
• API authentication mechanisms and rate limiting
• Container and orchestration platform security

Compliance Framework Alignment

SOC 2 Mapping

CMMC practices align with multiple SOC 2 criteria:

• CC6.1 (Logical Access Controls) maps to AC domain
• CC7.2 (System Monitoring) aligns with AU practices
• CC7.3-7.5 (Incident Management) corresponds to IR domain
• A1.1 (Availability Commitments) relates to RE capabilities

Vendors with SOC 2 Type II reports can reference specific control tests as evidence. The template includes crosswalk tables to minimize redundant requests.

ISO 27001:2022 Correlation

Annex A controls map directly to CMMC practices:

• A.8 (Asset Management) → AM domain
• A.9 (Access Control) → AC domain
• A.12 (Operations Security) → SC and SI domains
• A.16 (Incident Management) → IR domain

ISO-certified vendors submit their Statement of Applicability and recent surveillance audit results. Gap analysis focuses on CMMC-specific requirements absent from ISO 27001.

GDPR Considerations

For vendors processing EU personal data alongside CUI, the template incorporates:

• Article 32 technical measures mapping
• Data processor security obligations
• Breach notification timelines (72-hour requirement)
• Cross-border transfer mechanisms

Implementation Best Practices

1. Pre-Assessment Scoping

Define CUI boundaries before sending questionnaires. Document:

• Specific data types shared with each vendor
• System interconnections and data flows
• Geographic processing locations
• Subcontractor involvement

2. Evidence Validation Strategy

Implement three-tier validation:

• Tier 1: Document review for completeness
• Tier 2: Technical validation of submitted evidence
• Tier 3: Optional on-site assessment for critical vendors

Accept alternative evidence formats when appropriate. Smaller vendors might lack formal documentation but demonstrate strong controls through technical implementations.

3. Scoring and Risk Tiering Methodology

Develop quantitative scoring that reflects your risk tolerance:

Vendor Category	Required CMMC Level	Evidence Depth	Assessment Frequency
CUI Processors	Level 2 minimum	Full technical validation	Annual + changes
CUI Storage Only	Level 1-2 based on volume	Document review	Annual
FCI Access Only	Level 1	Self-attestation + sampling	Biennial
No Government Data	Adapted controls	Risk-based	Triennial

4. Continuous Monitoring Integration

Static assessments provide point-in-time assurance. Mature programs incorporate:

• Automated control monitoring via APIs
• Quarterly attestation updates
• Change-triggered reassessments
• Performance metric tracking

Common Implementation Mistakes

Over-Reliance on Self-Attestation

Vendors claiming CMMC readiness without evidence often fail technical validation. Require specific artifacts:

• Policy documents alone prove nothing—demand procedural evidence
• "We use MFA" requires configuration screenshots
• "Encrypted at rest" needs key management documentation

Ignoring Subcontractor Risks

Fourth-party risks multiply when vendors outsource CUI processing. The template must capture:

• Complete subcontractor inventories
• Flow-down agreement evidence
• Subcontractor assessment results
• Incident notification chains including all parties

Misaligned Scoring Models

Generic high/medium/low ratings obscure actual risk. Develop scoring that reflects:

• CMMC maturity level gaps
• Compensating control effectiveness
• Business impact of vendor failure
• Remediation timelines and vendor commitment

Assessment Fatigue Without Automation

Manual questionnaire processing burns analyst time on low-value tasks. Prioritize automation for:

• Evidence collection and storage
• Control mapping across frameworks
• Score calculation and reporting
• Remediation tracking

Frequently Asked Questions

How does the CMMC vendor assessment differ from standard security questionnaires?

CMMC assessments require evidence of specific practices tied to handling Controlled Unclassified Information, not general security posture. Each control maps to Department of Defense requirements with defined maturity levels and acceptable evidence types.

Can vendors substitute SOC 2 reports for CMMC assessment responses?

SOC 2 reports provide partial evidence for overlapping controls, but CMMC includes unique requirements for CUI handling, incident reporting to DIB-CS, and specific NIST 800-171 implementations that SOC 2 doesn't address.

What evidence should I require for Level 2 versus Level 3 maturity claims?

Level 2 requires documented processes and consistent implementation evidence. Level 3 demands proof of managed, measured processes with quantitative performance data and continuous improvement mechanisms.

How do I assess cloud service providers who refuse to complete lengthy questionnaires?

Focus on their FedRAMP authorization status, request their CMMC System Security Plan (SSP) excerpts, and use their standard security documentation mapped to CMMC controls rather than demanding custom responses.

Should international vendors complete CMMC assessments if they don't directly contract with DoD?

Yes, if they process, store, or transmit CUI as part of your supply chain. CMMC requirements flow down regardless of geographic location or direct DoD relationships.

How often should I reassess vendors after initial CMMC evaluation?

Annual reassessment for CUI processors, triggered reassessment for significant changes, and continuous monitoring through automated feeds when available. FCI-only vendors may extend to 24-month cycles.

What remediation timelines should I enforce for identified gaps?

Critical controls (authentication, encryption, incident response): 30 days. Infrastructure changes: 90 days. Process maturity improvements: 180 days. Document POA&Ms with monthly progress requirements.