EXECUTIVE BRIEF
The revised Cybersecurity Maturity Model Certification (CMMC 2.0) requires defense contractors handling CUI to implement all 110 security controls and 320 objectives of NIST 800-171A Rev2. Here's what defense contractors need to know about the most commonly failed objectives:
Dig deeper and continue learning below!
NIST SP 800-171 is a critical framework developed by the National Institute of Standards and Technology to help organizations protect Controlled Unclassified Information (CUI) in non-federal systems—a must for defense contractors working with the Department of Defense (DoD) and other federal agencies. Compliance isn’t optional; it’s mandated by DFARS regulations and forms the foundation of the Cybersecurity Maturity Model Certification (CMMC). Failure to meet key NIST 800-171 assessment objectives is one of the most common reasons contractors lose out on DoD contracts, as it directly affects CMMC 2.0 eligibility.
In this article, we’ll break down what NIST 800-171 is, why it matters, and how to avoid the most commonly failed assessment objectives that could cost you valuable business.
One of the biggest challenges contractors face during a NIST SP 800-171 assessment isn’t always the technical controls—it’s the documentation needed to prove compliance. While implementing security tools and access controls can be straightforward, documenting processes like System Security Plans (SSPs), incident response plans, and audit log reviews often proves more difficult. Below are some of the most frequently failed objectives that can jeopardize both NIST compliance and CMMC certification:
Several common themes contribute to these failures:
These issues aren’t just theoretical. Many of the recent False Claims settlements point to contractors failing to update documentation and misrepresenting their SPRS score. In the case of MORSECORP, Inc., they allegedly failed to meet basic NIST 800-171 controls including an updated SSP. The settlement cost the contractor $4.6 million.
Achieving compliance with NIST 800-171 doesn’t have to be overwhelming. Here’s how to set yourself up for success:
Familiarize yourself with the 14 control families outlined in NIST SP 800-171 and understand the assessment process as defined in NIST SP 800-171A.
Take the time to assess your current compliance status. Identify where you meet requirements and where there are gaps that need to be addressed.
Create detailed documentation, such as a System Security Plan (SSP) and Plan of Action and Milestones (POA&M), that outlines how you’ll address, remediate, and implement each objective.
Training is key. Ensure your staff understands their role in maintaining security and compliance, particularly in areas like Personnel Security and Awareness Training.
Leverage tools that automate compliance tasks, such as continuous monitoring alerts audit tracking, and vulnerability scanning. This will save you time and reduce human error.
If you need additional guidance, don’t hesitate to reach out to professionals, such as ISI’s compliance advisory team, who can offer hands-on support in meeting NIST 800-171 requirements.
Achieving compliance with NIST 800-171 is not just about meeting regulatory requirements—it's about protecting sensitive information and building trust with federal clients. Non-compliance can lead to serious consequences, such as losing contracts, facing fines, or being barred from bidding on future contracts.
By following these steps, you can confidently meet NIST 800-171 objectives and set your organization up for success in the federal contracting space.
If you need expert assistance in achieving NIST 800-171 compliance and preparing for CMMC certification, reach out to ISI today. We’re here to help you navigate the complexities of compliance with ease.
Begin by performing a self-assessment against the controls and objectives in NIST 800-171a to identify any gaps in compliance. If you’re preparing for certification, it’s recommended to have a third-party assessor conduct a full evaluation.
Protecting CUI is a shared responsibility between the organization and its personnel. It’s essential to provide proper training, oversight, and implement policies that ensure everyone follows the correct procedures.
The cost of an assessment can vary depending on factors like the size of your company, the scope of your operations, and whether you use internal or external resources for the assessment.
It’s important to conduct regular reviews, especially when systems are updated or when new regulations are introduced. At a minimum, an annual review is recommended.
NIST 800-171 provides the baseline cybersecurity requirements for protecting CUI, while CMMC builds on these standards with additional controls to assess the maturity of an organization’s cybersecurity practices. CMMC certification is required for many DoD contracts.