The Signed Roster
You are the CCI for a private, eight-hour CMMC Level 2 course delivered for a defense contractor. Eighteen employees were enrolled. Only nine attended the live session. Four watched part of the recording but did not complete the final knowledge check; three did not attend at all; two attended only the first two hours. The client's purchase order says payment depends on '18 completed learners.' The LTP operations manager hands you a roster and asks you to sign it as complete for all 18, saying, 'The recordings are available, and the client needs this for their contract. No one audits attendance.' One of the nine live attendees also failed the knowledge check twice.
1. What should you do with the roster and completion records?
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Do not sign the roster as delivered for all 18. Completion must be based on defined criteria: attendance or equivalent participation, completion of required learning activities, and a passing knowledge check. Record the truth: nine live, four partial recordings, three no-shows, two partial attendance, and the failed checks. Offer a makeup path-recorded sessions plus a proctored or supervised knowledge check-and sign only for learners who complete it. Tell the operations manager in writing that you cannot certify false completion. If the LTP insists, escalate to compliance and the certifying body; a contract payment term does not override accurate records.
2. Why does this matter beyond the client's contract?
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False completion records damage the CMMC ecosystem, not just one invoice. The LTP's authorization and your CCI depend on trustworthy delivery and assessment. Clients rely on training records to show workforce competence; DoD relies on the ecosystem's integrity. If an instructor signs for people who did not complete, the certificate becomes marketing fiction and can expose the LTP to sanctions, the client to contract risk, and you to decertification. It also disadvantages learners who did the work. The issue is not whether anyone audits attendance; it is whether the record is true.
3. How would you handle the client and LTP expectations while preserving learning?
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Communicate the criteria before the next cohort and in writing to the client. Separate attendance from completion; explain that recordings are an input, not automatic completion. Give a concrete remediation plan: a two-week window, module quizzes, a final knowledge check, and documentation. For the learner who failed twice, offer tutoring and a different form of the check if policy allows, not a free pass. If the client needs 18 completions by a date, offer additional live sessions rather than falsifying records. Escalate any pressure to the LTP and certifying body.