A shared Internet connection indicates that Security Protection Assets (SPAs) are present and serving both the CUI environment and other parts of the enterprise. SPAs are always in-scope regardless of where they are located, because they provide security protections for CUI. Therefore, if documentation or diagrams show that the commercial and federal environments share a single Internet connection, the assessor must request access to the other building to confirm proper implementation and isolation.
Exact Extracts (from CMMC Assessor/Study documents):
“Security Protection Assets provide security functions or capabilities within the OSA’s CMMC Assessment Scope. Security Protection Assets are part of the CMMC Assessment Scope and are assessed against Level 2 security requirements that are relevant to the capabilities provided.”
“Contractor Risk Managed Assets are not required to be physically or logically separated from CUI Assets… If documentation or other findings raise questions about these assets, the assessor can conduct a limited check to identify deficiencies.”
“Separation… is required only for Out-of-Scope Assets. Isolation can be achieved… by implementing subnetworks with firewalls or other boundary protection devices.”
“The CMMC Assessment Scope includes all assets in the OSA’s environment that will be assessed… OSAs will be required to provide a network diagram of the CMMC Assessment Scope to facilitate scoping discussions during pre-assessment.”
“An OSC can obtain a Level 2 certification assessment for an entire enterprise network or for a specific enclave(s), depending upon how the CMMC Assessment Scope is defined…”
Why the other options are not correct:
A (locked cases): Physical movement of materials does not establish scope. Scoping is determined by CUI flow and security protection assets, not incidental observation of personnel activities.
B (underground passageway): Physical tunnels or building connections do not affect scope unless they result in shared IT/security functions.
D (HR location): HR is not a SPA because it does not provide security functions to protect CUI. Unless HR systems process or store CUI directly, they remain out of scope.
References (official CCA/CMMC documents):
CMMC Assessment Scope – Level 2, Version 2.13 (Scoping Guide): Asset Categories, SPA definitions and examples; CRMA limited-check language; Separation requirements; network diagram requirements (pp. 3–13).
CMMC Assessment Guide – Level 2, Version 2.13: Assessment scope, enclave validation, and assessor methods (pp. 1–4, 8–10).