How NIST 800-171 and CMMC Work Together

Adhering to cybersecurity and information security requirements is more complex for defense contractors than it is for their commercial counterparts. The sensitivity of the information handled necessitates strict compliance with established frameworks to protect this data in the interest of national security. In the ever-evolving threat landscape of the 21st century, navigating regularly updated regulations to ensure the security of both prime and subcontractors can be overwhelming. Understanding the relationship between NIST (National Institute of Standards and Technology) Special Publication 800-171 and the Cybersecurity Maturity Model Certification (CMMC) is crucial for achieving and maintaining compliance. This guide will help you explore how these frameworks work together.

Understanding NIST 800-171

NIST 800-171 outlines 110 security controls across 14 control families and was originally published in 2015. Within these controls there are 320 objectives that must be met to reach compliance. Put simply, these controls are designed to protect Controlled Unclassified Information (CUI) from cyber threats. For Department of Defense (DoD) contractors, compliance with NIST 800-171 is mandatory to ensure that sensitive information remains secure. It is important to note NIST 800-171 compliance was initially assessed through self-assessment to generate a Supplier Performance Risk Score (SPRS).

Understanding CMMC

CMMC was introduced to address widespread non-compliance with NIST 800-171 among DoD contractors. In its latest version, CMMC 2.0, there are three unique maturity levels designed to protect both CUI and Federal Contract Information (FCI). Each level represents a step up in cybersecurity requirements and practices, with higher levels requiring greater security assurances. Level 1 focuses on basic cyber hygiene and requires an annual self-assessment. Levels 2 and 3 incorporate more advanced practices and processes. Level 2 requires a triennial third-party assessment by Certified Third-Party Assessment Organizations (C3PAOs).  For Level 3, the Department of Defense mandates a government-led assessment by the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC). This structured approach ensures progressive enhancement of cybersecurity measures across the defense industrial base.

The Relationship Between NIST 800-171 and CMMC

NIST 800-171 and CMMC are complementary standards that work together to secure the Pentagon’s supply chain. The security controls outlined in NIST 800-171 lay the groundwork for protecting CUI. Implementing these controls fulfills major requirements in preparation for a successful CMMC assessment. While NIST 800-171 compliance can be achieved through self-assessment, CMMC requires a third-party audit to achieve certification.

Preparing for DoD Compliance

To prepare for DoD compliance, organizations should:

  1. Identify the Appropriate CMMC Level: The first step in preparing for compliance is identifying which of the three levels of CMMC 2.0 you fall into.
  2. Conduct a Gap Analysis: Identify gaps in current cybersecurity practices compared to the requirements of both frameworks.
  3. Develop a Plan: Create a System Security Plan (SSP) and a Plan of Action and Milestones (POA&M) to outline steps for achieving compliance.
  4. Implement Controls: Apply the necessary controls and document their implementation.
  5. Engage with C3PAOs: For CMMC Levels 2 and 3, work with certified C3PAOs to undergo third-party assessments.

Understanding and integrating the requirements of NIST 800-171 is essential for DoD contractors preparing for the finalization of CMMC 2.0. These security controls not only provide a comprehensive approach to safeguarding sensitive information, but they also ensure that organizations are equipped to meet the stringent demands of the DoD so they can bid on new contracts and maintain existing ones. 

By leveraging the expertise of our compliance experts, you can streamline your compliance journey, mitigate risks, and focus on your core business objectives while maintaining a robust cybersecurity posture. Our comprehensive managed services ensure you remain compliant and ahead of evolving regulations, making IsI an invaluable partner in your compliance efforts.