NIST 800-171 vs. CMMC: How Are They Different?

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NIST and CMMC are two of the most common cybersecurity frameworks U.S. government agencies use. If your firm provides services to one or more government entities, you need to understand both of these frameworks. This article distills, compares, and contrasts their key aspects to facilitate your understanding.

• What is NIST? Part of the U.S. Department of Commerce, the National Institute of Standards and Technology (NIST) helps businesses understand, manage, and protect their networks and data. NIST 800-171 applies to the agency’s framework for protecting Controlled Unclassified Information (CUI) in nonfederal systems and organizations.
• What is CMMC? Established by the U.S. Department of Defense (DoD), the Cybersecurity Maturity Model Certification (CMMC) is the framework designed to enhance cybersecurity measures and ensure the protection of CUI within its supply chain. Businesses seeking to collaborate with the DoD must attain a compliance rating at one of three levels and adhere to its guidelines and best practices.

NIST vs. CMMS quick comparison chart

The chart below outlines the key points and distinctions between NIST and CMMC frameworks.

Who needs to comply with NIST vs. CMMC?

All federal government agencies, federal contractors, and their subcontractors that handle CUI government data must be NIST-compliant. Federal and nonfederal organizations that do not handle CUI may optionally pursue NIST compliance.

All contractors, subcontractors, and their supply chain partners working with the U.S. DoD who handle CUI or Federal Contract Information (FCI) must be CMMC compliant at one of three maturity levels based on the sensitivity of the information handled and the potential impact of a security breach.

How to be compliant with NIST and CMMC

Depending on the certification your organization seeks, the steps provided below will help you gain that certification.

What is NIST compliance?

NIST compliance ensures adherence to the guidelines outlined in NIST Special Publication 800-171. If your organization is entrusted with handling U.S. government CUI, these guidelines provide the foundation for establishing a secure information system enterprise-wide.

Overview of compliance

NIST compliance is organized into 14 families that you are required to comply with.

1. Access control: Prevent unauthorized access to CUI through measures like user authentication and access control lists.
2. Audit and accountability: Ensure traceability of actions and events through comprehensive audit logging and review.
3. Awareness and training: Reinforce security awareness among personnel through formal training on information handling and system security.
4. Configuration management: Ensure consistent and secure system configurations across the organization and specify requirements for user authentication and access, including multi-factor authentication (MFA).
5. Incident response: Prepare for and respond to security incidents, covering incident detection, containment, and recovery.
6. Maintenance: Maintain system components to enhance security, including patching and antivirus protection.
7. Media protection: Protect physical media containing CUI through labeling, tracking, and sanitization.
8. Physical protection: Secure the physical environment where CUI is stored, including alternate site security and access control.
9. Risk assessment: Identify and address system risks through vulnerability scanning and risk mitigation.
10. System and communications protection: Protect communication channels and systems through encryption and network device hardening.
11. System and information integrity: Protect the integrity of the system and its information against malicious activities.
12. System Security Plan (SSP): Develop steps for creating a comprehensive SSP for protecting CUI.
13. System and services acquisition: Ensure the secure acquisition of systems and services, covering requirements and acquisition practices.

NIST 800-171 compliance checklist

Sourced and condensed from CUI security firm Cuick Trak’s guide, here is a comprehensive checklist to help you establish robust security policies and strengthen your organization’s security posture.

These eight steps will streamline the process for meeting NIST SP 800-171 compliance requirements.

5 NIST compliance best practices

Best practices for NIST compliance fall into five essential buckets: identify, protect, detect, respond, and recover. Here’s how each of those buckets are applied:

1. Identify

Review your organization’s practices to ensure your cybersecurity program is consistent with your client’s needs and ensure safeguards are in place for these areas:

• Asset management: Identify crucial assets.
• Business environment: Identify business context.
• Governance: Identify established practices.
• Risk assessment: Identify vulnerabilities and risks.
• Risk management strategy: Identify a tactical mitigation plan.
• Supply chain risk management: Identifying a plan to manage supply chain disruptions.

2. Protect

Take proactive measures to ensure safeguards are in place for these areas:

• Identity management and access control: Restrict access to critical systems and information.
• Awareness and training: Educate the team to minimize human error breaches.
• Data security: Protect confidentiality, integrity, and availability of sensitive information using encryption, firewalls, and other effective methods.
• Information protection processes and procedures: Protect information systems and assets with robust security processes.
• Maintenance: Protect organizational resources through regular maintenance and data backups.
• Protective technology: Ensure organizational resilience by procuring the right technology.

3. Detect

Analyze enterprise data to detect malicious patterns, provide real-time alerts and ensure safeguards are in place for these areas:

• Anomalies and events: Detect abnormal behavior using reliable tools and technologies.
• Continuous monitoring: Detect indications of compromise by continuously monitoring network traffic and user behavior.
• Detection processes: Maintain detection processes for timely intrusion response.

4. Respond
Implement countermeasures to prevent incident spread, reduce downtime, and restore normal business operations. Identify roles and responsibilities for required response activities and ensure safeguards for these areas:

• Response planning: Maintain an incident response plan.
• Communication: Notify appropriate stakeholders of incidents.
• Analysis: Analyze the nature and impact of the incident.
• Mitigation: Perform mitigation.
• Improvements: Implement continuous improvement measures.

5. Recover

Establish a process that begins with recovery planning and extends to repairing, replacing affected systems, testing fixes, and instituting a change management process when procedures are updated to ensure safeguards in the following areas:

• Recovery planning: Develop plans and procedures for recovering systems and operations after a disruption or incident.
• Repair and replacement: Repair damaged systems or replace irreparable components to restore functionality.
• Testing: Conduct tests to verify the effectiveness of your recovery plans and procedures, ensuring systems can be restored as intended.
• Communication: Maintain communication with stakeholders, including employees, customers, and partners, to provide updates on recovery efforts and restore confidence.
• Continuous improvement: Identify lessons learned from recovery efforts and implement improvements to enhance future recovery capabilities.

NIST compliance tools and resources

Navigating NIST’s standards and its various critical components can be overwhelming. Fortunately, there are some useful tools and resources available to help you through the process.

• NIST publications: Start by exploring NIST’s collection of over 1,100 cybersecurity publications, covering various standards, advice, and expert insights. Key recent publications include guides on mobile device security and the Risk Management Framework. Regularly check for updates to stay informed.
• Information Technology Laboratory (ITL): The NIST ITL establishes IT standards, including in cybersecurity. Pay attention particularly to the following areas:
  • Publications: Explore NIST Special Publications, categorized into 500, 800, and 1800 series, offering guidelines and recommendations for aligning with U.S. government information security standards and creating security standards.
  • Cybersecurity: NIST highlights practical best practices and implementations on its Cybersecurity priority page.
• Computer Security Resource Center (CSRC): A longstanding resource, the CSRC provides updates, publications, and events related to NIST cybersecurity. Sections cover projects, publications, topics, news, events, glossary, and information about CSRC divisions.
• NIST FAQ page: The NIST FAQ page contains common questions and answers on framework basics, perspectives, success stories, online learning modules, and many additional resources.
• Small Business Cybersecurity Corner: This page contains resources specifically tailored for small businesses, addressing cybersecurity basics, planning guides, guidance by topic, incident response guidelines, training, a contributor directory, FAQs, and a blog.
• Video Gallery: The NIST Video Gallery provides videos covering various cybersecurity topics, offering insights and advice for aligning with NIST security standards.

What is CMMC compliance?

CMMC compliance certifies that service providers working with DoD can safeguard sensitive defense information, whether CUI or FCI.

Overview of CMMC compliance

CMMC 2.0 has three maturity levels you must maintain based on the type of information you handle:

• Level 1 (Foundational): Establishes fundamental cybersecurity practices to ward off unauthorized access to FCI.
• Level 2 (Advanced): Elevates the standards with more stringent requirements and the adoption of more sophisticated cybersecurity measures.
• Level 3 (Expert): requires the implementation of highly advanced cybersecurity practices and capabilities to ensure the utmost security for DoD contracts.

CMMC compliance checklist

Sourced and condensed from encryption authority Preveil’s guide, here is a comprehensive checklist to help you track your CMMC compliance progress.

9 CMMC compliance best practices

Given the complexity of its implementation, best practices for CMMC compliance are more intricate than those for NIST. Here are some tips to help ensure you maintain compliance with CMMC 2.0:

1. Risk assessment

• Analyze established systems to identify gaps.
• Perform a risk assessment to prioritize fixing any vulnerabilities.

2. Access control

• Limit data access to authorized users and processes.
• Establish rights and privileges for each user/role.

3. Identification and authentication

• Implement strong authentication systems to identify users/devices accessing systems.
• Use methods like MFA and train users on password protection.

4. Media protection

• Sanitize information before processing it into system media to ensure confidentiality and integrity.
• Establish procedures for data encryption and secure backups.

5. Physical protection

• Limit unauthorized physical access to servers, systems, and operating environments.
• Implement security mechanisms to restrict visitor access and monitor activity.

6. System and communications protection

• Secure communication channels and data transfer mechanisms.
• Set up monitoring solutions, intrusion detection, and threat detection systems.

7. System integrity

• Update data discrepancies promptly and establish reporting processes for security incidents.
• Conduct periodic system and file scans.
• Establish regular auditing processes.
• Continuously improve solutions, update security patches, and keep up with evolving cyberthreats.
• Perform regular internal and third-party security audits to evaluate processes objectively.

8. Training and awareness

• Train users on security best practices and common cyberattack patterns.
• Conduct sessions on scams, phishing attacks, and data protection methods.

9. Additional security practices

• Employ email protection systems and train employees on secure email usage.
• Install antivirus and malware protection software on devices.
• Ensure physical devices are attended to and not left unsecured.
• Connect only to secured networks, wired or wireless.
• Train employees on securing information during virtual meetings.
• Dispose of data and old equipment securely when no longer required.

CMMC compliance tools and resources

Like NIST, there is a huge trove of tools and resources to inform and guide you on CMMC compliance. Here is a list to help you get started:

• CMMC model documents: Access the CMMC Model v2.0 and associated appendices on the official CMMC website or through the CMMC-AB website. You’ll find detailed information about the maturity levels, practices, and processes required for compliance.
• Training programs: Look for training programs and courses offered by accredited training providers that cater specifically to MSPs and end users seeking CMMC compliance. Programs like those administered by the National Initiative for Cybersecurity Careers and Studies and Learning Tree International cover topics such as understanding CMMC requirements, implementation strategies, and assessment preparation.
• Consulting services: Many consulting firms like TestPros, KLC Consulting, and others provide guidance and support to organizations, including MSPs, seeking CMMC compliance. These firms can offer tailored advice, conduct readiness assessments, assist with implementation efforts, and prepare MSPs for CMMC assessments.
• Online communities and forums: Participate in online communities, forums, and discussion groups such as the CMMC Users’ Group and Spiceworks that focus on CMMC compliance. These platforms enable you to connect with peers, ask questions, share experiences, and learn from the insights of others who are also navigating the compliance process.
• Vendor solutions: Explore software vendors that offer tools and solutions designed to streamline the CMMC compliance process for end-users. These solutions may include compliance management platforms, assessment tools, and documentation templates tailored to MSPs’ needs.
• Government resources: You can view a list of resources provided by the Department of Defense and the Office of the Under Secretary of Defense for Acquisition and Sustainment. These resources provide valuable information and updates related to CMMC compliance.

What is the most recent NIST compliance update?

On August 15, 2023, NIST announced the launch of its new Cybersecurity Framework (CSF) 2.0 Reference Tool which provides users access to the Draft CSF 2.0 Core in both human and machine-readable formats, including JSON and Excel. It enables you to explore functions, categories, subcategories, and implementation examples, with options to export specific sections using key search terms and customize your own version of the CSF 2.0.

Note: Additional features are planned for early 2024.

What is the most recent CMMC compliance update?

CMMC 2.0 is the latest iteration of the Department’s CMMC cybersecurity model. On December 26, 2023, the DoD released its long-awaited Proposed Final Rule concerning the CMMC program. The feedback phase on this proposed final rule closed February 26, 2024, and is now being reviewed.

Bottom line: Comparing CMMC vs. NIST compliance

Your decision to pursue CMMC versus NIST compliance depends on factors unique to the services you provide your federal government clients.

• Pursue CMMC certification to meet the DoD’s stringent cybersecurity requirements for handling CUI and FCI.
• Pursue NIST compliance to obtain a broader, more widely recognized set of guidelines applicable across various industries and government agencies.

By assessing your organization’s specific contractual obligations, industry standards, and client requirements you can determine which framework aligns best with your organization’s objectives.

Tego VP of Marketing Jennifer Vosburgh spoke with Channel Insider’s Katie Bavoso about how MSPs can navigate evolving CMMC compliance requirements, working with an RPO, and achieving lasting success.