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, and Version 2.0 was announced in November 2021.
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 to protect CUI.
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.
- Hire a third-party organization to perform a NIST 800-171 assessment and make recommendations
- Perform your own self-assessment and self-attestation
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 a Plan of Action with Milestones (POA&M).
NIST provided several free online resources to help companies perform their own assessments. However, many companies struggled to perform their own assessments and create documents highlighting what changes needed to be made to achieve NIST compliance and how to make those changes.
2020 – This is Now
In the initial release of CMMC, there was no option for self-attestation. That has changed with the announcement of Version 2.0 of CMMC.
Can We Do It Ourselves?
Depending on the level of CMMC to which you need to comply and the type of information you are handling in the performance of a contract, you may be able to self-attest to CMMC.
Who Needs to Comply?
Depending upon the contract under which you are working, all DoD contractors will need to obtain CMMC or comply with NIST 800-171.
When Does This Become Effective?
The Department of Defense is gradually transitioning from the NIST 800-171 mandate to the CMMC framework. By October 1, 2025, 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, depending on the level of CMMC for which you need to meet.
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 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 or self-attest to CMMC.
To prepare you for your CMMC assessment, these are the steps we follow:
- Identify the relevant requirements of CMMC that 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 before your certification assessment is 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.