While not mandatory, NIST 800-171 becomes a requirement for organizations if: They are working on a federal government contract that involves handling CUI. They are part of the supply chain for a federal contractor that handles CUI.
If you want to work as a federal contractor, it's time to get familiar with this publication.
What is NIST SP 800-171?
NIST SP 800-171, also known as 800-171, is a set of codified requirements that non-federal computer systems must adhere to. The purpose of these requirements is to ensure the secure storage, processing, and transmission of Controlled Unclassified Information (CUI).
The standards were first published in 2015 by the National Institute of Standards and Technology (NIST), a US government agency dedicated to strengthening cybersecurity resilience. The latest version, Revision 2, was released in February 2020, reflecting the evolving landscape of cyber threats and technological advancements.
The document is based on the Federal Information Security Management Act of 2002 (FISMA) Moderate level requirements. Compliance with NIST SP 800-171 is mandatory for some Department of Defense contracts and is overseen by the Office of Sponsored Programs.
The Purpose of NIST SP 800-171
The primary purpose of NIST SP 800-171 is to ensure the security and protection of Controlled Unclassified Information (CUI) that resides on nonfederal systems and organizations. This sensitive, unclassified information is often processed or stored by entities working on behalf of the US government, such as Department of Defense contractors, universities receiving federal grants, or service providers to government agencies. Any government contractors handling sensitive data must meet CUI security requirements and ensure its physical and environmental protection.
The NIST SP 800-171 standards are designed to fortify the cybersecurity resilience of the entire federal supply chain. By enforcing these standards, the US government aims to safeguard federal contractors' IT systems and networks, thereby enhancing the security of the information they handle.
NIST-SP 800-171 and Cybersecurity Maturity Model Certification Compliance
NIST 800-171 and CMMC are intertwined when it comes to Department of Defense (DoD) contracts that handle Controlled Unclassified Information (CUI).
NIST 800-171 is a framework with recommended security controls for protecting CUI on non-federal systems. It’s mandatory for DoD contractors since 2018 (through the DFARS clause) and lays out a basic set of security expectations for handling CUI.
CMMC is a certification program that assesses a contractor's cybersecurity maturity level and is soon to be mandatory for DoD contracts. CMMC builds on NIST 800-171, particularly CMMC level 2, which aligns with NIST 800-171 controls. It provides a tiered approach with different levels of security requirements.
In a nutshell, the Department of Defense requires contractors to safeguard CUI. NIST 800-171 details how to achieve that protection, CMMC verifies compliance with those security requirements through audits.
Essentially, NIST 800-171 sets the security bar, and CMMC checks if you're reaching that bar. You can’t fulfill any contracts with the DoD without a CMMC certification, and you can’t achieve that certification without adhering to NIST 800-171.
Meeting these requirements is crucial for securing and maintaining DoD contracts that involve CUI.
How Organizations Comply with NIST SP 800-171
Compliance with NIST SP 800-171 is not optional; it's a contractual obligation for organizations handling CUI. These organizations are expected to conduct self-assessments to ensure they meet the security requirements and maintain compliance. This underscores the importance of fully understanding and implementing the 110 requirements outlined in the NIST SP 800-171. The compliance process is not overseen by a certification body or official audit. Instead, organizations are required to self-assess and self-attest to their adherence to the NIST SP 800-171 requirements. This self-assessment process involves an audit against the list of requirements found in the publication for all aspects of their network and systems that store or process CUI.
To ensure contractors are up to par, the DoD leverages two key tools: the NIST special publication NIST 800-171 (which we've covered) and the Supplier Performance Risk System (SPRS).
SPRS is a separate DoD system that builds upon NIST 800-171. Contractors assess their own compliance with NIST 800-171 controls and submit the results to SPRS. SPRS assigns a score based on this self-assessment, providing the DoD with a clear picture of a contractor's cybersecurity risk posture and security control when handling sensitive information.
Control Families Documentation Topics in NIST SP 800-171
The publication outlines a set of security controls categorized into 14 different families, covering various aspects of information security, such as:
- Access Control
- Awareness and Training
- Audit and Accountability
- Security Assessment and Configuration Management
As of the time of publication, June 4, 2024, the latest version is NIST 800-171 Revision 3, published in May 2024. It's important to use the most recent revision for the most up-to-date security recommendations.
Documentation Topics for Compliance
The NIST SP 800-171 provides a comprehensive guide for organizations to protect Controlled Unclassified Information (CUI). It outlines several documentation topics that are essential for compliance.
SP Revision: This refers to the updated version of the NIST SP 800-171. The latest revision, Revision 2, includes corrections and improvements to enhance readability and interpretation without introducing new technical information or requirements.
SSP Template: There is no prescribed format for system security plans. However, organizations are required to ensure that the information in the SP 800-171 Requirement 3.12.4 is included in their plans.
Recommend Security: The guide provides recommended security requirements for protecting the confidentiality of CUI when the information is resident in nonfederal systems and organizations.
Nonfederal Organization: The guide applies to nonfederal organizations that are not collecting or maintaining information on behalf of a federal agency or using or operating a system on behalf of an agency.
Maintain Information: The guide emphasizes the importance of maintaining the confidentiality of CUI in nonfederal systems and organizations.
Safeguarding Requirement: The guide provides specific safeguarding requirements for protecting the confidentiality of CUI.
Law Regulation: The guide is consistent with the authorizing law, governmentwide policy, and CUI category list in the CUI registry.
Transmit CUI: The guide provides protection measures for transmitting CUI, especially through file sharing and email.
These documentation topics are crucial for organizations to understand and adhere to in order to achieve NIST 800-171 compliance.
Who Needs to Comply with NIST SP 800-171?
Understanding who needs to comply with NIST SP 800-171 is crucial for both federal and nonfederal systems and organizations:
Requirements for Federal Agencies
Federal agencies are at the forefront of those who need to comply with NIST SP 800-171. This is because they handle Controlled Unclassified Information (CUI) which is of utmost importance to the federal government. The guidelines directly impact the ability of these agencies to perform their mission and function. Non-compliance can lead to serious consequences, including loss of federal contracts.
Requirements for Nonfederal Organizations
Nonfederal organizations that process, store, or transmit Controlled Unclassified Information (CUI) are mandated to comply with NIST SP 800-171. This includes a broad range of entities such as defense contractors, research institutes, and universities that receive federal grants.
These organizations play a critical role in the federal supply chain and their ability to achieve compliance directly impacts the ability of the federal government to carry out its mission and functions.
The security requirements of NIST SP 800-171 are not just guidelines, but contractual obligations. These organizations are expected to conduct self-assessments to ensure their systems and processes meet the standards set out in the publication.
Achieving Compliance with NIST SP 800-171
Achieving compliance with NIST SP 800-171 is of paramount importance for organizations handling Controlled Unclassified Information (CUI). Cybersecurity compliance is a complex process, involving a thorough understanding of the requirements and a strategic approach to meet them.
Steps to Achieve NIST SP 800-171 Compliance
Form an Assessment Team: Include senior information security stakeholders to ensure a comprehensive approach to compliance.
Set an Assessment Plan: Define clear objectives and a realistic timeframe to keep the process on track.
Spread Awareness: Launch an internal communication campaign to ensure everyone understands the importance of the project.
Identify Key Personnel: Create a contact list of personnel with relevant responsibilities, such as system administrators and information security specialists.
Collect Relevant Documents: Gather existing security policies, system records, audit results, and other pertinent documents.
Assess Individual Requirements: Evaluate each of the 110 requirements in the NIST SP 800-171 document and record a statement for each.
Create a Plan of Action: Outline how any unmet requirements will be achieved.
Compile Evidence for Compliance: Include all evidence for compliance into a System Security Plan (SSP) document.
The Importance of NIST SP 800-171 Compliance
The NIST SP 800-171 plays a critical role in safeguarding Controlled Unclassified Information (CUI) that resides in nonfederal systems and organizations. Its compliance is not just a legal obligation, but a strategic necessity for any organization handling CUI. Noncompliance can result in severe consequences, including loss of contracts, legal penalties, and reputational damage.
If you need assistance with achieving compliance in the federal sector, it's time to get in touch. Site2 has worked with contractors and vendors in highly regulated industries, including National Defense and healthcare, and can help you meet your compliance requirements.