Yes. A C3PAO can fail an OSC if documentation is not accurate or does not reflect CMMC 2.0 Language. However, the DoD is still drafting the Plan of Actions and Milestones (POA&M) policy, which may allow the OSC to include the failed practice. The OSC would then have up to 180 days to remediate the POA&M. The Certification Assessment Process (CAP) will cover this area for assessors. It is currently in draft form and should be released by the end of March 2022.