Executive Brief
- Your System Security Plan (SSP) is the backbone of NIST 800-171 compliance
- Your Supplier Performance Risk System (SPRS) score depends on it
- Certified Third-Party Assessment Organizations (C3PAOs) will validate it during Cybersecurity Maturity Model Certification (CMMC) assessments
- Common mistakes include outdated policies, generic language, and missing control mappings
- Contractor takeaway: A current SSP is critical to both contract eligibility and audit success
Dig deeper below for practical steps to keep your SSP current and aligned with CMMC expectations.
An SSP isn’t just paperwork, it’s a living document that demonstrates how your systems, policies, and processes align with NIST 800-171. With CMMC enforcement underway, assessors are paying closer attention to whether your SSP reflects real, current practices.
Why the SSP Is Central to Compliance
Your SSP isn’t just a formality. It’s the blueprint that ties your environment directly to NIST 800-171 and CMMC requirements.
- The SSP documents how your environment meets each of the 110 NIST 800-171 controls.
- It is the foundation of your SPRS score submission.
- During a CMMC Level 2 assessment, the SSP is the first place assessors look for proof that your policies and technical controls are implemented.
- An incomplete or outdated SSP can disqualify your bid or fail you in an audit.
Common SSP Pitfalls
Many contractors fail audits not because they ignore controls, but because their SSP doesn’t reflect reality. These are the most common mistakes.
- Stale content: SSPs created years ago that no longer reflect current systems or tools.
- Copy-paste language: Using generic templates without tailoring to your environment.
- Control gaps: Failing to map SSP sections directly to each NIST 800-171 requirement.
- No update process: Treating the SSP as a compliance artifact instead of a living document.
Practical Steps to Keep Your SSP Audit-Ready
Updating your SSP doesn’t need to be overwhelming. A few disciplined practices will keep it accurate and ready for assessment.
- Review quarterly: Update to reflect changes in systems, policies, and environments.
- Map to objectives: Ensure every SSP section ties directly to NIST 800-171 Rev 2 assessment objectives.
- Integrate remediation: Update SSP entries alongside Plans of Action and Milestones (POA&Ms) to show progress.
- Document evidence: Link policies, configurations, and screenshots to controls for audit verification.
- Assign ownership: Designate a responsible party for maintaining the SSP.
ISI Insight: For the first time in nearly two decades, NIST is beginning the process to update SP 800-18, their guide to creating an SSP. Keep track with the changes here.
Why It Matters for Your SPRS Score
Your SSP and your SPRS score are inseparable. If your SSP is weak or outdated, your score won’t hold up under scrutiny.
- The SSP anchors your SPRS submission. Without a current SSP, your score lacks credibility.
- Inaccurate scores tied to outdated SSPs can expose contractors to False Claims Act risk.
- A high SPRS score with an outdated SSP will raise red flags during your C3PAO assessment.
Your SSP is not just a compliance box. It’s the living evidence that connects your policies, practices, and systems to NIST 800-171 and CMMC requirements. Treating it as a static document puts both contracts and certifications at risk.
FAQ
How often should I update my SSP?
DFARS 252.204-7019 requires your SPRS score to be updated at least every three years. But due to annual self-attestations required for both Level 2 and Level 3 certification, your SPRS score should be realistically updated every year at a minimum.
Does a POA&M replace SSP updates?
No. A Plan of Action and Milestones shows remediation in progress, but your SSP must always reflect your current posture.
Will NIST 800-171 Rev. 3 make my SSP obsolete?
Not immediately. CMMC currently benchmarks Rev. 2, but preparing your SSP for Rev. 3 alignment now will save rework later.
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