If your organization is mulling entering an official contract with the United States Department of Defense (DoD), then you’ll need to familiarize yourself with NIST 800-171 security protocols. The US government enforced NIST 800-171 in 2018, and since then, contractors handling Controlled Unclassified Information (CUI) have been legally obligated to comply with the laid-down security requirements or risk various specified consequences.  

However, despite enforcing NIST 800-171, there have been widespread reports of non-compliance across the Defense Industrial Base (DIB). These incidents have severely compromised the safety and integrity of sensitive information, besides occasioning costly downtimes across DoD-related supply chains. It’s against that backdrop that the Department of Defense created the CMMC program.  

CMMC serves as a tiered approach that spells out three critical maturity levels for cybersecurity compliance, which organizations that deal with CUI must satisfy to secure DoD contracts. The program was formally unveiled in October 2020 through the DoD’s Interim Final Rule.  

However, mastering NIST 800-171 and CMMC remains a major challenge for many organizations due to inadequate information. In this blog, we shall expound on these critical security protocols and how to achieve full compliance. 

Unpacking NIST 800-171 

The National Institute of Standards and Technology (NIST) SP 800-171 is a framework that details the guidelines for safeguarding the confidentiality of controlled unclassified information.  

All organizations that handle CUI must comply with NIST 800-171 protocols or risk losing their contracts. There may be additional penalties, depending on the nature of non-compliance.  

Although widely associated with the Department of Defense, NIST 800-171 compliance is a requirement for all companies that conduct official business with the federal government. Compliance is mandatory for both contractors and subcontractors.  

What Is CMMC? 

The Cybersecurity Maturity Model Certification (CMMC) is a framework used to assess and certify the maturity of organizations’ cybersecurity programs. The DoD developed this certification model to prevent sensitive CUI handled by DIB contractors from slipping into potentially malicious hands. Its creation was in response to rising reports of significant compromises of sensitive defense information.  

For context, cybersecurity threats have risen astronomically in the recent past. These breaches largely target agencies that still maintain legacy IT infrastructures. A notable example is the 2017 Equifax breach, in which over 147 million people had their personal information dangerously exposed.  

Updating and upgrading existing cybersecurity protocols is the most effective way to ward off threats. However, while the DoD can implement robust IT architectures internally, controlling how companies handle CUI is more of a challenge. In that light, the agency formulated CMMC to foster compliance within and beyond its administrative frameworks.  

Aspiring DoD contractors must achieve three CMMC 2.0 compliance certification levels as a prerequisite for securing state contracts. CMMC aligns perfectly with NIST 800-171, making it imperative for organizations to achieve compliance across both protocols. 

Similarities Between NIST 800-171 and CMMC 

Both NIST 800-171 and the CMMC aim to protect the safety and integrity of controlled unclassified information. CUI comes in diverse forms, including;

1. Classified Information

Classified information is one that the U.S. government has determined requires the highest level of security protection. As such, it cannot be released to the general public without proper authorization. 

2. Sensitive Information

Sensitive information isn’t classified. However, it’s imperative to handle it judiciously to prevent any reputational damage to national security. 

3. Proprietary Information

Proprietary information is owned by private entities. While not classified or sensitive within the context of the federal government, releasing such information without proper safeguards could compromise the owner’s security.  

By enforcing NIST 800-171 and CMMC compliance, the federal government aims to protect CUI from various forms of threats. The risks may also take different forms, including theft, sabotage, espionage, cyber-attacks, and accidental loss.  

Besides protecting controlled unclassified information, NIST 800-171 and CMMC define the eligibility criteria for securing lucrative federal contracts. Both security protocols passively sift through potential defense contractors, knocking non-compliant organizations off the merit list.  

Differences Between NIST 800-171 and CMMC 

The primary distinction between NIST 800-171 and the CMMC is that NIST 800 is the cybersecurity standard that federal contractors must meet. At the same time, CMMC is a certification framework that defines whether (or to what extent) organizations meet NIST requirements. However, this difference is more nuanced as the two protocols are largely interwoven.  

Another point of divergence between NIST 800-171 and CMMC relates to assessment.  

Federal contractors can achieve NIST 800-171 through basic self-assessments, which evaluate the robustness of their CUI security protocols. Meanwhile, CMMC requires companies to undertake third-party assessments of their existing cybersecurity models. Incorporating third-party assessors, known within the industry as certified third-party assessment organizations (C3PAO), provides an extra layer of confidence that the subject company has achieved total compliance.  

Lastly, NIST 800-171 and CMMC differ in their scoring methodologies.  

NIST 800-171 self-assessments should turn in a minimum score of 88 out of 110. Aiming for an even higher percentage is essential, as each score would still need to be interrogated by a C3PAO while undertaking the more extensive CMMC audits.  

When it comes to CMMC, scores are awarded depending on the level achieved. CMMC certification levels were originally five but have since been collapsed into three.  

Level 1 demonstrates that an organization has achieved basic cybersecurity hygiene within the context of 48 CFR 52.204-21 while also establishing the security foundation for higher CMMC levels. It comprises 15 distinct practices and adheres mostly to Federal Acquisition Regulation (FAR) 52.204-21 protocols. 

CMMC Level 2 is more advanced. It consists of 110 practices, most aligning with NIST 800-171 requirements. It’s the level at which NIST 800-171 and CMMC cybersecurity protocols intersect.  

Finally, CMMC Level 3 is an expert. It comprises 110+ practices, blending NIST 800-171 and NIST 800-172 requirements.  

Why Should I Consider NIST 800-171 and CMMC Compliance? 

1. Compliance Is a Regulatory Requirement for DoD Contractors

Complying with NIST 800-171 and CMMC security protocols is a regulatory requirement for all Department of Defense contractors. As previously hinted, the regulations apply to premium contractors who engage directly with the DoD and subcontractors.  

The need for compliance isn’t exclusive to for-profit companies either. It applies to all organizations that handle controlled unclassified information, including those that may be further down the DIB supply chain, like colleges, universities, and research institutions.  

If your organization deals with CUI in any capacity, it’s imperative to seek CMMC certification services as a way of achieving complete regulatory compliance. The saving grace is that you don’t need to meet all three CMMC certification levels at once. You can enlist professional cyber assistance to establish the CMMC levels your organization must meet. 

2. Compliance Is Mandatory To Secure DoD Tenders

Complying with both NIST 800-171 and CMMC security protocols increases your eligibility for coveted federal contracts. Note that all bidders of DoD tenders must be NIST 800-171 and CMMC-compliant.  

However, compliance with the Cybersecurity Maturity Model isn’t just a prerequisite for aspiring DoD contractors. Organizations currently engaging with the department must keep up with these requirements or risk penalties.  

Upon obtaining definitive proof of non-compliance, the Department of Defense may withhold your payments. This can severely impact your company’s cash flow, especially if the withheld payouts are millions of dollars.  

The DoD may also terminate your contract and bar you from bidding on future tenders. Again, the financial implications can be devastating for your organization. 

3. Compliance Can Avert Criminal Penalties

In certain instances, failure to comply with NIST 800-171 and CMMC protocols might have criminal charges preferred against you. The penalties may include fines, jail terms, or both.  

If it’s established that more heinous crimes like espionage were committed because of your negligence, you could be looking at lengthy prison sentences.  

Further, it’s important to point out that the DoD isn’t the only agency that may penalize you for NIST 800-171 and CMMC non-compliance. Many other state departments and private entities require proof of compliance with both protocols.

4. Compliance Can Prevent Reputational Damage

Maintaining NIST and CMMC compliance improves your company’s reputation and its overall security posture.  

In the digital age where information is power, customers prefer organizations with a proven track record of safeguarding sensitive information. Maintaining NIST 800-171 and CMMC compliance might be the one extra incentive your business needs to outpace the competition. 

How to Become NIST 800-171 and CMMC Compliant 

For NIST 800-171, you may opt to self-assess your compliance and provide assurance that your organization handles all CUI in line with NIST’s framework. This entails scoping your company to uncover where CUI data is stored, evaluating the fortitude of your storage platforms, and issuing a detailed report of NIST 800-171 compliance.  

When it comes to CMMC compliance, you’ll have better luck enlisting professional assistance through a C3PAO.  

A certified cybersecurity technician will begin by evaluating your company’s operations vis-à-vis its existing cyber framework.  

Next, the C3PAO will help you identify the maturity level for which you wish to be certified. If there are any security gaps, the technician will help you seal them before moving forward.  

Finally, the CPAO will bring you (and your employees) up to speed on the revised CMMC framework and what you must constantly do to maintain compliance.   

Final Word 

Achieving NIST 800-171 and CMMC compliance is a regulatory requirement for any organization that handles controlled unclassified information. Further, complying with both protocols may boost your company’s cybersecurity posture and avert publicity nightmares associated with significant data breaches.  

Note that the NIST 800-171 and the CMMC are frequently subjected to revisions. To maintain full compliance, staying abreast of all emerging regulatory and policy trends around both protocols is imperative.