As of December 31, 2017, companies that provide parts and services for suppliers serving the government were required to be compliant with the NIST 800-171 mandate. The Department of Defense is gradually transitioning from the NIST 800-171 mandate to the Cybersecurity Maturity Model Certification (CMMC).
NIST Special Publication 800-171 covers the protection of "Controlled Unclassified Information" (CUI) defined as information created by the government, or an entity on behalf of the government, that is unclassified, but needs safeguarding.
Cybersecurity Maturity Model Certification Explained
In an effort for more companies to achieve compliance with NIST 800-171, a new certification was created, Cybersecurity Maturity Model Certification (CMMC). Version 1.0 was released in January 2020.
To enhance the cybersecurity posture of companies participating in government supply chains, the Department of Defense is transitioning from the NIST 800-171 mandate to the CMMC framework. By 2026, all new DoD contracts will require compliance with CMMC.
The CMMC is intended to verify compliance in order to protect CUI.
The CMMC framework requires all companies seeking compliance to work with an accredited and independent third-party organization, a CMMC Third Party Assessment Organization, or C3PAO.
How to Comply with NIST 800-171
December 31, 2017 – That Was Then
Previously, there were two ways to achieve compliance with the NIST 800-171 mandate.
You would then develop and maintain formal documents for submission to DoD prime contractors or subcontractors upon contract initiation or renewal. These documents included a System Security Plan (SSP) and Plan of Action with Milestones (POA&M).
To help companies perform their own assessments, NIST provided several free, online resources. However, many companies struggled to perform their own assessments and create the documents highlighting what changes needed to be made to achieve NIST compliance and how to make those changes.
2020 – This is Now
The CMMC framework requires all companies seeking compliance to have a CMMC assessment performed by a C3PAO.
One aspect that is unique to CMMC compared to NIST 800-171 is that CMMC will implement multiple maturity levels that range from 1 to 5.
- Levels 1 and 2 will only cover parts of NIST 800-171.
- Level 3 will cover NIST 800-171 plus a few other security controls.
- Levels 4 and 5 will expand even further to include additional security controls.
Can We Do It Ourselves?
No. Unlike NIST 800-171, there is no longer an option for self-attestation with the CMMC framework. Work you may have done towards an SSP and POA&M will still be helpful to you on your path to compliance.
Who Needs to Comply?
All DoD contractors will need to obtain CMMC or comply with NIST 800-171, depending upon the contract under which you are working. By 2026, all new DoD contracts will require compliance with CMMC.
When Does This Become Effective?
Version 1.0 of the CMMC framework was published and made available to the public in January 2020.
The Department of Defense is gradually transitioning from the NIST 800-171 mandate to the CMMC framework. By 2026, all new DoD contracts will require compliance with CMMC.
What Does This Mean If We Already Achieved NIST 800-171 Compliance?
The goals behind the NIST 800-171 mandate have not changed — to protect CUI within government supply chains. Only the method for providing evidence of compliance has changed.
For contracts requiring CMMC, you will need to work with a C3PAO, who will perform an assessment of your organization. You will need to pass the assessment to be eligible for that contract.
With CMMC, there is no longer an option for self-attestation.
If you had previously achieved NIST 800-171 compliance, either through a security assessment by a third-party or through your own self-attestation, that work was not in vain. The documents created in the past to achieve compliance will still be of value.
Gap analysis (reports)
Plan of Action with Milestones (POA&M)
System Security Plan (SSP)
Corserva can prepare you for a CMMC assessment by a C3PAO.
Corserva is a CMMC-AB Registered Provider Organization™ (RPO) and we are listed on the CMMC-AB Marketplace.
As an RPO, Corserva is authorized by the CMMC-AB to provide pre-assessment consulting services to government contractors and other Organizations Seeking Certification (OSC).
Corserva has created an easy process to enable you to get ready for a CMMC assessment and protect your government contracts.
To prepare you for your CMMC assessment, these are the steps we follow:
- Identify the relevant requirements of CMMC you will need to meet.
- Perform an "as is" gap analysis of your processes and security controls, identifying areas to be corrected.
- Create a list of remediation steps to be taken prior to your certification assessment being performed by a C3PAO.
The end deliverable to you is a clear set of corrective actions to take before your CMMC assessment.
Get started today by requesting a quote for CMMC readiness.