How NIST 800-171 and CMMC Work Together

In the ever-evolving cyber threat landscape of the 21st century, navigating regularly updated regulations 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 DoD prime and subcontractors to achieve and maintain compliance. This guide explains how these frameworks work together.

CMMC and NIST 800-171 Compared

Understanding NIST 800-171

NIST 800-171 was originally published in 2015. It outlines 110 security controls across 14 control groups. Within these controls there are 320 objectives that must be met to reach compliance. 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’s important to note that NIST 800-171 compliance was is assessed through self-assessment to generate a Supplier Performance Risk Score (SPRS).

Understanding CMMC

CMMC was introduced in 2020 and updated in December, 2023 to address widespread non-compliance with NIST 800-171 among DoD contractors. In its current updated 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).
• Level 3 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 DIB.

The Relationship Between CMMC and NIST 800-171

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.

However, while NIST 800-171 compliance can be achieved through self-assessment, CMMC requires a third-party audit to achieve certification at Levels 2 and 3. Furthermore, Level 3 CMMC compliance requires meeting additional guidelines, including standards from NIST 800-172.

Preparing for DoD Compliance

To prepare for DoD compliance, organizations should:

1. Identify Your 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. 

DFARS and NIST 800-171

DFARS and NIST 800-171 are closely connected, with the former mandating the protection of CUI and the latter providing the technical roadmap for achieving that goal. If you’re bidding on a contract or you’ve been awarded work, you’ll need to be compliant with all 110 NIST 800-171 security controls in order to fulfill the DFARS clause.

ISI Helps You Achieve CMMC Compliance

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. Schedule a free consultation today to find out how we can help you achieve and maintain compliance.

FAQs about CMMC and NIST 800-171

Is NIST 800-171 a requirement for CMMC?

CMMC uses NIST 800-171 practices, but it expands on the requirements, and introduces a certification process to verify compliance. Organizations seeking Level 2 compliance will have to meet all of NIST 800-171’s regulations in order to comply, but Level 3 certification introduces additional requirements.

What are the NIST 800-171 controls?

NIST 800-171 establishes 110 security controls that can be divided up into 14 different categories: These are: Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Identification and Authentication, Incident Response, Maintenance, Media Protection, Personnel Security, Physical Protection, Risk Assessment, Security Assessment, System and Communications Protection, and System and Information Integrity.

How long does it typically take to achieve NIST 800-171 compliance and CMMC certification?

Generally, contractors should expect preparation for CMMC certification to take 9-12 months. This timeline will vary based on several factors, mainly the organization’s current cybersecurity standing and the level of certification sought. The other primary variable is the scheduling of an assessment with a C3PAO. As of August 2024, there are just 54 assessors that must assess ~80,000 contractors in level 2.