CCSFP Certified CSF Practitioner 2025 Exam Questions and Answers

HITRUST does not mandate that all required CAPs be remediated within a strictsix-month deadline. Instead, CAPs must include arealistic remediation planwith target dates, owners, and milestones. Some CAPs may be resolved quickly, while others (such as large-scale encryption rollouts) may take longer. HITRUST requires that CAPs are tracked and updated until completion, and progress is reviewed at interim assessments. While assessors may encourage timely remediation (often aiming for six months where feasible), HITRUST does not impose a universal time limit. What matters is that CAPs are properly documented, tracked, and eventually closed. Therefore, the statement that all required CAPs must be remediated within six months isFalse.

When performing scoping for an r2 assessment, HITRUST requires consideration ofrisk factorsthat tailor requirement statements. Four categories are applied:Technical, Organizational, Compliance, and Operational.

Technical Risk Factorsconsider measurable characteristics such as number of users, systems, or transactions, which directly influence the size and complexity of the control environment.

Organizational Risk Factorsaddress the type of business, industry sector, and whether the entity is a covered entity or business associate.

Compliance Risk Factorsincorporate regulatory drivers (e.g., HIPAA, PCI DSS, state laws) that generate additional requirement statements.

Operational Risk Factorsconsider how data is used, stored, and transmitted, including exposure points like internet-facing systems.

“General” and “Privacy” are not categories formally recognized in the HITRUST methodology. Privacy obligations are accounted for under compliance drivers such as HIPAA, GDPR, or state laws. These categories ensure that control requirements are right-sized to the entity’s unique environment, reducing both over-scoping and under-scoping.

Thee1 assessmentfocuses on essential cybersecurity hygiene controls. To achieve certification, the Implemented maturity level must demonstratefull (100%) compliancefor each requirement statement. Partial implementation (such as 50%) indicates that the control is not consistently applied or lacks complete coverage across systems and users. HITRUST emphasizes the Implemented level in e1 because it represents proof that foundational safeguards are actively functioning. Scoring 50% would fall into the “Partially Compliant” category, which is insufficient for certification. Even if policies and procedures exist, HITRUST requires controls to be fully implemented for an e1 certification outcome. This strict requirement helps ensure that entities with lower assurance models still achieve a baseline of strong operational security.

When a relying party requests anInsights Report covering AI risks, the appropriate selection in MyCSF is theA1 Risk Assessment. The A1 Security Assessment adds AI-related requirements to evaluate technical and governance safeguards for artificial intelligence systems. However, the A1 Risk Assessment is specifically designed to generateInsights Reportsthat highlight AI-related risk exposures, model governance practices, and data usage concerns. HITRUST distinguishes between these two factors to ensure organizations scope their assessment appropriately. By selecting the A1 Risk Assessment, the assessment object will include additional requirement statements aligned with AI risks, enabling the Insights Report output. This ensures stakeholders receive the necessary assurance information about the organization’s risk environment in relation to AI.

The HITRUST CSF is structured into19 domainsthat provide comprehensive coverage of information security and privacy practices. These domains represent major categories of controls such as Information Security Management, Endpoint Protection, Network Security, Access Control, Configuration Management, Incident Management, and Data Protection. Each domain contains multiplecontrol referencesmapped to requirement statements, which are tailored to organizational and regulatory factors. This domain structure ensures that assessments address administrative, technical, and organizational safeguards consistently across industries. All assessment types—whether e1, i1, or r2—utilize these 19 domains, although the number of requirement statements varies depending on the scope. The domain-based structure also supports HITRUST’s mapping to authoritative sources like NIST, HIPAA, and ISO, ensuring consistency across compliance obligations.

HITRUST CSF’srisk-based levelswere adapted fromNIST SP 800-53, which organizes controls into baseline categories based on impact levels:low, moderate, and high. Similarly, HITRUST assigns requirement statements across multiple implementation levels (Level 1, Level 2, and Level 3) depending on organizational, technical, and regulatory risk factors. This approach ensures scalability, so smaller organizations or lower-risk environments face fewer requirements, while larger, high-risk entities face more. HITRUST harmonized this concept with mappings to other frameworks (ISO, HIPAA, PCI-DSS), but the structure of escalating control rigor by risk exposure is directly derived from NIST’s model. This alignment reinforces HITRUST’s credibility as a risk-based framework consistent with widely accepted standards.

TheMeasured maturity levelrequires organizations to demonstrate structured metrics, analysis, and reporting across seven defined criteria. If these criteria arenot met, the Measured level cannot receive any positive score. Instead, it defaults toTier 0, representingNon-Compliant (0%)at this maturity level. This ensures that organizations cannot claim credit for partial or informal measurement practices. For example, if firewall logs are collected but never analyzed or reported, the criteria are not satisfied, and the Measured score remains Tier 0. Only once all seven criteria are satisfied can scoring begin at Tier 4 and be adjusted based on coverage and strength.

HITRUST does not issue certifications limited solely toprivacy-related requirements. While privacy is a critical part of the CSF—reflected in domains such asData Protection & Privacy—HITRUST certifications require coverage ofall 19 domains. This is because security and privacy are interdependent: without robust security, privacy cannot be protected. An entity may emphasize privacy controls during scoping and reporting, but certification itself is always tied to a full CSF assessment. Privacy-related frameworks, such as GDPR or HIPAA Privacy Rule, can be added as regulatory factors, which introduce additional privacy-focused requirements. However, the output will still be a standard HITRUST validated report or certification covering the entire environment, not a “privacy-only certification.”

In HITRUST scoring, deficiencies are identified when maturity levels fall below required thresholds for certification. In this case, the Policy, Procedure, and Implementation levels are not fully compliant, with scores of 50%, 50%, and 75% respectively. For certification-critical controls, HITRUST requires 100% Implementation, supported by adequate Policy and Procedure. Since the Implementation score is not at 100% and supporting maturity levels are below full compliance, this results in aRequired Corrective Action Plan (CAP). The CAP ensures the organization addresses deficiencies through remediation. Unlike optional CAPs, which may apply to non-critical requirements, required CAPs must be documented and remediated to achieve certification. Thus, the correct classification of this scoring outcome is aRequired CAP.

MyCSF Analyticsis a feature that allows organizations to create dashboards, charts, and reports from their assessment data. Analytics can be appliedwithin a single assessment objectto track scoring, evidence linkage, CAPs, and requirement coverage. Additionally, analytics can be appliedacross multiple assessments(e.g., e1, i1, and r2 objects) within the same subscriber organization. This cross-assessment capability is especially valuable for large enterprises performing multiple assessments for different business units or regulatory drivers. It enables comparisons, benchmarking, and enterprise-wide risk visibility. The analytics feature enhances MyCSF’s role as not only an assessment tool but also acontinuous risk management platform, giving organizations insight into trends and performance over time.

The HITRUSTe1andi1assessments are streamlined, moderate-effort assurance models designed to evaluate an entity’s implementation ofessential cybersecurity hygiene controls. These assessments focus on baseline security practices recognized across industries as foundational for protecting sensitive information. The e1 is intended for smaller organizations or those with limited resources, covering a subset of controls that address basic hygiene. The i1 provides expanded coverage beyond e1, testing against controls deemed critical for medium assurance levels. By contrast, the r2 is the most rigorous and risk-tailored assessment, covering a broader and more detailed control set. Targeted assessments are specialized and do not focus broadly on hygiene. Therefore, the e1 and i1 assessments are the correct answers.

In ani1 assessment, scoring follows a pass/fail logic tied to CAP requirements. If aControl Referencescores below the defined threshold (typically83for i1 assessments), any gaps within its requirement statements must be addressed with arequired Corrective Action Plan (CAP). A score of62is below the threshold, meaning it cannot be accepted without remediation. This ensures organizations remediate key cybersecurity hygiene gaps, even in a moderate assurance assessment. Optional CAPs are not used in i1 assessments, as the assurance program emphasizes mandatory remediation for below-threshold controls. Certification cannot be granted with unresolved required CAPs. Therefore, the correct outcome for a score of 62 in an i1 Control Reference is arequired CAP.

Fully Compliant = 100

Mostly Compliant = 75

Partially Compliant = 50

Somewhat Compliant = 25

Non-Compliant = 0

HITRUST assigns specific numeric values to compliance categories within the scoring rubric to standardize assessments. These categories translate qualitative assessments intoquantitative scores:

Fully Compliant (100):All criteria met with complete and verified evidence.

Mostly Compliant (75):Most criteria met; minor gaps exist.

Partially Compliant (50):Roughly half of the evaluative elements are met.

Somewhat Compliant (25):Only a small fraction of the evaluative elements are satisfied.

Non-Compliant (0):No evidence of compliance.

These values are applied at the Requirement Statement level and then averaged upward into Control Reference and Domain scores. This quantification ensures consistency and supports certification thresholds such as the domain-level requirement of 71 for r2 certification.

When an assessor submits a validated assessment object to HITRUST, theQA intake processbegins. HITRUST typically takes3–5 business daysto complete an initial review and decide whether to accept the submission into the QA pipeline or reject it due to deficiencies (such as missing evidence, incomplete CAPs, or improper scoping). Acceptance at this stage does not mean certification—it simply indicates that the assessment meets the minimum requirements to enter QA. If rejected, the assessor must correct the issues before resubmission. The 3–5 day timeframe ensures efficiency while maintaining rigor in intake quality checks.

The A1 Security Assessment factor is an optional module that introduces requirements for evaluating the security and governance of AI-based systems. These requirements are mapped into HITRUST CSF across domains like risk management, monitoring, and governance. Importantly, the A1 factor is not restricted solely to r2 assessments. While r2 provides the most comprehensive assurance model, A1 can also be added to other eligible assessment types such as i1 when the scope involves AI risks. The factor is treated like any other regulatory or organizational factor in MyCSF—its selection generates additional tailored requirement statements. Therefore, the claim that A1 canonlybe added to r2 is inaccurate. The correct understanding is that A1 can apply tomultiple assessment types, depending on scoping decisions.

Organizations may conduct multiple assessments simultaneously in MyCSF. This may occur when an organization is pursuing different assurance levels (e.g., an r2 assessment for certification while also preparing an i1 for a customer request). It can also happen when separate business units or subsidiaries perform assessments concurrently. MyCSF supports multiple active assessment objects, allowing organizations to scope them independently while managing shared evidence, inheritance, and CAPs across assessments. However, care must be taken to ensure that evidence collection, assessor validation, and QA submissions do not overlap in a way that confuses reporting. HITRUST also provides analytics and dashboards that allow organizations to track multiple assessments at once.

In HITRUST assessments, grouping is allowed when multiple primary components (like firewalls) arefunctionally identicalin terms of configuration, management, and security controls. If all firewalls share the same rule sets, firmware, patching schedule, and are managed consistently, they can be grouped as one for testing purposes. This prevents repetitive validation work across systems that present no material differences in control design or operation. However, grouping requires justification and supporting documentation, showing that the systems are identical. If variations exist (e.g., differing rule sets or management practices), each firewall must be treated as a separate component. Grouping improves efficiency in large environments but must be applied cautiously to maintain the accuracy and integrity of testing results.

The HITRUST CSF scoring rubric evaluates maturity across five levels: Policy, Procedure, Implemented, Measured, and Managed. To achieve certification in an r2 assessment, each domain must meet aminimum aggregate threshold of 71. Full compliance in Policy, Procedure, and Implementation (100% each) results in high scores that exceed the certification threshold. The Measured and Managed levels, while valuable for demonstrating monitoring and governance, are not required to be scored above zero to achieve certification. In this scenario, the organization demonstrates complete documentation and implementation of controls, which satisfies HITRUST’s certification criteria. Therefore, even with Measured and Managed at zero, the assessment can achieve certification because the foundational maturity levels provide sufficient assurance.

In MyCSF, organizational performance dashboards are available under theAnalytics tab. This section provides interactive reporting features, including trend charts, compliance scores, domain comparisons, CAP summaries, and benchmarking across multiple assessment objects. Unlike theReference LibraryorAdministration tab, which are used for framework access and account management, the Analytics tab focuses onreporting and visualization. It allows management and assessors to monitor both single-assessment results and enterprise-wide metrics. Importantly, dashboards are not restricted to certified reports; they are a built-in feature of MyCSF, accessible during preparation, readiness, and validated assessments. This makes the Analytics tab essential for organizations using HITRUST as an ongoing governance and risk management tool.

HITRUST provides sampling guidance in theCSF Assessment Methodologyand scoring rubric for manual controls. Sample sizes are determined by the population of items and the control’s frequency. For a population of56 items, the expected sample size is8, following HITRUST’s defined sampling table. This approach is based on statistical sampling principles but simplified for consistent assessor use. The sample must be randomly selected and representative of the entire population to avoid bias. Larger populations require larger sample sizes, but at certain thresholds, the increase is incremental. For example, a population between 26–100 items requires a sample size of 8. This ensures sufficient testing coverage without requiring a full census. Therefore, the correct sample size for 56 items is8.

In an r2 assessment, CAP requirements are determined at the Control Reference level. If the aggregate score falls below the certification threshold of 71, and the Implementation maturity level is not at 100%, a Corrective Action Plan (CAP) must be documented. This ensures that organizations commit to remediating critical control deficiencies before certification can be finalized. CAPs must include clear details such as responsible parties, remediation steps, and timelines. Without CAPs, HITRUST will not accept the assessment for certification. Even if Policy or Procedure scores are strong, missing implementation creates unacceptable risk. Therefore, HITRUST mandates CAPs in these cases to close certification-critical gaps.

When performing HITRUST scoping, organizations must includeregulatory factorsrelevant to their operational and geographic context. Since this entity operates inMassachusettsandNevada, two state-specific privacy and security laws apply:

Massachusetts Data Protection Act(201 CMR 17.00): Requires businesses handling personal data of Massachusetts residents to maintain a written information security program (WISP), including encryption and monitoring controls.

Nevada Security of Personal Information Law(NRS 603A): Mandates encryption for personal information stored or transmitted electronically and requires reasonable security measures.

TheCMS Minimum Security Requirements (High)(B) would apply only if the entity processes Medicare/Medicaid-related data. TheTexas Health and Safety Code(D) applies only to Texas-based covered entities.Subject to De-ID Requirements(E) is a general data-handling condition, not a state-specific regulatory factor.

Therefore, onlyMassachusetts Data Protection ActandNevada Security of Personal Information Requirementsapply in this scenario.

HITRUST defines sample sizes for manual controls based on thefrequency of operation. For controls that operateweekly, the required sample size is5 items. This ensures that the assessor can evaluate consistency over multiple weeks without excessive burden. For example, if access logs are reviewed weekly, five weeks of logs must be tested. A higher frequency (e.g., daily controls) requires larger samples, such as 25. Conversely, less frequent controls (e.g., monthly or quarterly) may only require 2 or 1 sample. The structured sampling methodology provides consistency across assessments, ensures sufficient evidence for scoring, and prevents under-testing of critical controls.

Corrective Action Plans (CAPs) represent identified gaps that must be tracked until they are fully remediated. Even if an organization remediates a CAP after an assessment is completed, the CAP remains part of thefinal validated reportfor transparency. The report will show the CAP along with its remediation status and closure details, but it cannot be deleted or excluded. This ensures stakeholders have a complete history of deficiencies and the corrective actions taken. CAPs demonstrate accountability and continuous improvement, which are central to HITRUST’s assurance model. Removing them would diminish trust and obscure the remediation journey, which is why HITRUST prohibits their removal post-assessment.

HITRUST conducts a QA review of every validated assessment to confirm that assessors followed the methodology and applied consistent testing. QA does not re-test every control; instead, HITRUST selects a sample of Control Objectives across the assessment. For each sample, HITRUST reviews assessor notes, evidence, and testing procedures to ensure accuracy and completeness. This sampling approach balances efficiency with assurance, allowing HITRUST to evaluate the assessor’s work without duplicating the entire validation process. If issues are found, QA may expand its review or return the assessment for clarification. This process ensures that validated assessments meet HITRUST’s quality standards before reports or certifications are issued.