MP.L2-3.8.1: Media Protection Assessment Guide

Official reference

The requirement

Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.

DoD CMMC Assessment Guide, Level 2, version 2.13. MP.L2-3.8.1; requirement and objectives, printed page 157 ↗

Assessment objectives

What must be established

Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.

[a]
paper media containing CUI is physically controlled;
[b]
digital media containing CUI is physically controlled;
[c]
paper media containing CUI is securely stored; and
CAP location planning flagged ↓
[d]
digital media containing CUI is securely stored.
CAP location planning flagged ↓

MET requires evidence that all applicable objectives are satisfied. Final, approved evidence is needed. A NOT APPLICABLE determination needs a scope-based basis and is equivalent to MET for scoring. Enduring exceptions and temporary deficiencies have specific conditions under 32 CFR 170.24; they are not a general permission to defer implementation.

GAVII Cybersecurity assessment approach

Connect the objective to the evidence

Inventory the forms in which CUI exists, including printouts, removable media, and offline copies. Electronic access permissions do not establish physical storage protection.

Assessment focus: objectives [a], [b], [c], [d]. Use the methods together; a single example does not establish every objective.

Examine

Inspect media-handling procedures, storage arrangements, access restrictions, and custody records.

Interview

Where are paper and digital CUI kept when not in active use, including during temporary handling?

Demonstrate or test

Arrange an appropriate observation of representative storage and handling conditions without exposing actual CUI.

Evidence gaps to look for

Digital access is controlled while printouts remain unattended.
Storage controls cover the main office but not another location.

GAVII Cybersecurity’s examples illustrate ways to examine, interview, and test. They are not a mandatory artifact list or a guarantee of an assessment result. Combine methods and address every applicable objective in the actual scope.

Assessment constraints

Scoring and POA&M eligibility

Score: 3

If this requirement is NOT MET, deduct 3 points from the Level 2 maximum of 110. The deduction applies to the requirement, not separately to each objective.

Scoring rule ↗

POA&M: Not eligible

This requirement has a deduction greater than 1 point and does not qualify for the limited encryption exception. It cannot be deferred on the POA&M used for Conditional Level 2 status.

POA&M rule ↗

Conditional Level 2 requires a score of at least 88 out of 110 and satisfaction of every eligibility condition. A 1-point requirement is not automatically eligible. The permitted POA&M must be closed through the appropriate closeout assessment within 180 days of the Conditional CMMC Status Date. An operational remediation plan does not confer Conditional Status.

Assessment planning

Location and observation

Location planning flagged

CAP P.11 specifically highlights the marked objectives for assessment-location planning. Agree with the C3PAO how the environment can be adequately observed, including any scope-specific need for on-site activity. These markers do not establish a universal in-person requirement.

Flagged objectives: [c], [d].

CAP §P.11, pages 10–11 ↗

Check the source

References and related requirements

DoD CMMC Assessment Guide, Level 2 ↗MP.L2-3.8.1; requirement and objectives, printed page 157. 2.13, September 2024.
32 CFR 170.24: Assessment findings and scoring ↗170.24(b) and (c)(2). Current electronic Code of Federal Regulations.
32 CFR 170.21: POA&M eligibility and closeout ↗170.21(a)(2) and (b). Current electronic Code of Federal Regulations.
NIST SP 800-171 Rev. 2 ↗Requirement 3.8.1. February 2020, updated January 2021.
NIST SP 800-171A ↗Assessment procedure 3.8.1. June 2018.
Cyber AB CMMC Assessment Process (CAP) ↗P.11, printed pages 10-11; Level 2 certification assessment-location planning. 2.0, December 2024.

Program timing and contract applicability can change independently of these requirements. Check current DoD program notices and your solicitation or contract before making a compliance decision. Open the official DoD resource hub.

Media Protection