NIST 800-171 Compliance: The Start-to-Finish Guide
Whether you're beginning your compliance journey or refining existing measures, this guide simplifies the process, ensuring you're well-equipped to protect CUI and solidify your partnership with federal agencies.
In today’s digital age, protecting sensitive data is crucial, especially for organizations collaborating with the U.S. Federal Government. The cybersecurity framework NIST SP 800-171, created and maintained by the National Institute of Standards and Technology (NIST), addresses this need. It's designed for non-federal entities handling Controlled Unclassified Information (CUI), which is any information that needs to be safeguarded to protect the nation's interests.
What makes NIST 800-171 compliance essential? For any entity working with federal agencies, it's a gateway to trust and opportunity. Compliance with NIST 800-171 safeguards CUI and demonstrates your commitment to data security, a critical factor in securing and maintaining federal contracts. Non-compliance, conversely, risks legal issues and loss of business.
This guide offers a clear path to understanding and implementing NIST 800-171. We break down the journey into manageable steps:
- NIST 800-171 Requirements: Unpacking the 14 control families and their significance.
- The Path to NIST 800-171 Compliance: Practical advice on applying these controls within your organization.
- Achieving Continuous Compliance: Tips for maintaining compliance amidst evolving challenges.
What is NIST 800-171?
NIST 800-171 is a critical set of guidelines designed by the National Institute of Standards and Technology (NIST) to secure Controlled Unclassified Information (CUI) in non-federal information systems and organizations. It's a framework that provides a standardized approach for safeguarding sensitive government data that non-federal entities, such as contractors and subcontractors, handle as part of their federal work.
NIST 800-171 is built around 14 families of security requirements, each focusing on a different aspect of information security. These families include access control, incident response, and system and information integrity, among others. The framework is designed to ensure that sensitive data is accessed only by authorized individuals and that it remains confidential and unaltered during its lifecycle.
Who Needs to Be Compliant with NIST 800-171?
As a non-federal organization working with a federal agency, if you process, store, or transmit CUI, you are expected to comply with the Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS).
FAR and DFARS outline requirements for all U.S. government acquisition and contract processes. As a result, NIST 800-171 provides recommendations and controls your organization can implement to ensure that you successfully protect and secure all controlled unclassified information (CUI). The government mandates that all contractors and subcontractors implement NIST requirements to effectively demonstrate that they adhere to the controls required in DFARS 252.204-7012, which became effective in December 2017.
If your organization fails to demonstrate you meet the appropriate requirements, you may not be able to work with federal agencies, and compliance failure could mean the end of your contracts with the U.S. government.
It’s also important to note that, if you are a prime contractor who works with subcontractors to complete terms of your DoD or other federal relationships, you are expected to ensure that all of those subcontractors also meet NIST 800-171 compliance.
To evaluate if you are NIST 800-171 compliant, you can use cybersecurity compliance software like Apptega, which offers streamlined templates to evaluate each of the controls and subcontrols this framework is comprised of.
When and Why Was NIST 800-171 Created?
The creation of NIST 800-171 was driven by a growing need to protect sensitive government information residing outside of federal systems and networks.
This need was formally recognized with the issuance of Executive Order 13556 in 2010, which called for the standardization of how federal agencies handle and protect CUI. In response, NIST developed these guidelines to extend the protection of sensitive data to non-federal systems that interact with federal agencies,
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The Scope of CUI
Controlled Unclassified Information (CUI) encompasses a wide range of data types that the U.S. government deems sensitive but not classified. This can include financial records, legal documents, and other information that, while not classified, requires protection due to its potential impact on national security, privacy, or other critical areas.
NIST 800-171 Compliance Versus Certification
Unlike some cybersecurity frameworks, NIST 800-171 does not require formal certification. Instead, organizations are expected to self-assess their compliance and provide assurance that they meet the framework's requirements.
This self-assessment process involves a thorough review of an organization's information systems and security protocols against the NIST 800-171 standards. Read on to find the easiest, most affordable way to conduct a NIST 800-171 self-assessment.
Why NIST 800-171 Compliance Matters
Understanding the significance of NIST 800-171 compliance is crucial for any organization aspiring to collaborate with the U.S. Federal Government. Let’s explore the different reasons why you should not underestimate the importance of this security framework:
While adhering to NIST 800-171 is a regulatory requirement, it can be a strategic move to grow your businesses as it can open the doors to a host of opportunities in the federal marketplace.
In a market where costly data breaches are happening daily, compliance with NIST 800-171 can be used as a competitive differentiator. It signals to potential clients and partners that your organization prioritizes data security and adheres to stringent standards. This advantage is crucial not just for securing government contracts but also for establishing credibility in the broader marketplace.
If you don’t comply with NIST 800-171, you risk severe consequences, including legal penalties and financial losses. The failure to protect CUI can lead to data breaches, resulting in substantial fines, litigation, and a tarnished reputation. In contrast, compliance with NIST 800-171 mitigates these risks, safeguarding your organization against potential legal and financial pitfalls.
Adopting NIST 800-171 compliance is not a one-time effort but a continuous journey towards improving your organization's data security posture. It encourages the implementation of best practices in information security, fostering a culture of continuous improvement and vigilance against emerging cyber threats.
If you’re an MSSP offering NIST 800-171 compliance services to your customers, focusing on this framework also means longer customer relationships.
Understanding the Requirements for NIST 800-171 Compliance
The key NIST 800-171 requirements and controls can be easily understood by putting them into a few core buckets: controls and processes, monitoring and management, practices and procedures, and implementation.
It looks like this:
1. Design controls and procedures to establish how you will manage and protect CUI.
2. Continuously monitor and manage all of your IT systems to ensure compliance.
3. Ensure all users understand your security practices and procedures.
4. Implement and maintain security practices both for your data, technology, and physical locations.
But to analyze it at a more granular level, NIST 800-171 is structured around 14 control families, each encompassing specific requirements that organizations must meet to protect Controlled Unclassified Information (CUI).
These families represent a comprehensive approach to data security, addressing various aspects of information handling and protection.
Here’s a breakdown of each of them:
- Access Control: This family focuses on limiting access to CUI only to authorized users. It includes requirements for user identification, secure authentication, and the management of access permissions.
- Awareness and Training: Employees must be aware of the security risks associated with their activities and the importance of complying with organizational policies. This control involves regular training on security protocols and best practices.
- Audit and Accountability: Organizations must create and retain system audit logs and records to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity.
- Configuration Management: This ensures that systems are set up and maintained in a way that protects CUI. It includes the management of security features and the oversight of changes to system configurations.
- Identification and Authentication: This requires implementing measures to verify the identity of users, processes, or devices as a prerequisite to allowing access to organizational systems.
- Incident Response: Organizations need to establish an operational incident-handling capability for CUI, including preparation, detection, analysis, containment, recovery, and user response activities.
- Maintenance: Regular maintenance of information systems is essential to ensure the continued effectiveness of security controls.
- Media Protection: Safeguards must be in place for media containing CUI, both digital and non-digital formats. This includes access, transport, and disposal of media.
- Personnel Security: This involves screening procedures for individuals who have access to CUI and ensuring that personnel can carry out their roles without posing a security threat.
- Physical Protection: Physical measures are needed to protect facilities, equipment, and resources against unauthorized access to, and damage or theft of, CUI.
- Risk Assessment: Organizations should periodically assess the risk to organizational operations, assets, and individuals, resulting from the operation of information systems.
- Security Assessment: Regular assessments of security controls in information systems must be conducted to ensure they are effective and comply with organizational security policies.
- System and Communications Protection: This requires safeguarding information in networks and protecting the confidentiality and integrity of CUI.
- System and Information Integrity: Organizations must protect information systems from malware and monitor system security alerts to detect and respond to information security incidents.
Understanding and implementing all of these requirements can be a convoluted and time-consuming task. That’s why using cybersecurity and compliance software for NIST 800-171 can greatly accelerate your process while reducing costs. If you’re a security provider, using a tool like Apptega will open internal bandwidth so you can serve more clients, while allowing you to create a stickier offering with ongoing compliance services. Read on for more details on how Apptega makes NIST 800-171 night and day easier.
The Definitive NIST 800-171 Compliance Checklist
Achieving NIST 800-171 compliance can be a streamlined process with the right approach and the right compliance software. This section provides a step-by-step checklist to guide organizations through the essential phases of compliance, ensuring that every requirement is met systematically.
Here are the 9 steps you need to follow to get compliant with NIST 800-171:
1. Understand NIST 800-171 Requirements
Determine your or your clients’ obligations related to NIST 800-171 based on existing or future contracts with federal agencies.
2. Assign Roles and Responsibilities
Designate a Compliance Lead: Whether you’re an MSSP handling NIST 800-171 compliance for a company or you’re starting the process internally, having a main point of contact who owns the project is key for success.
Collaborate with Key Personnel: Work with IT, HR, legal, financial personnel, and others handling CUI to manage tasks and collect evidence.
4. Map All CUI
Understand CUI Flow: Determine how CUI is used, shared, and stored within your organization.
Limit Access: Restrict access to CUI only to essential personnel.
5. Conduct a NIST 800-171 Gap Analysis
If you haven’t already, you can greatly accelerate your process by working with an MSSP to help you run a NIST 800-171 gap assessment and help remediate any outstanding issues.
Either you or your third party should also leverage compliance automation software like Apptega to easily breeze through simplified templates to assess compliance with the NIST 800-171 framework and automate the collection of evidence.
A tool like this will also allow you to get real-time visibility and control of your NIST 800-171 compliance assessment process with intuitive reports and dashboards.
6. Create a System Security Plan (SSP)
Outline how your organization meets NIST 800-171 controls through various measures. Here’s a quick look at what that SSP might look like:
- Outline requirements and controls
- Describe your operating environment-related to each control
- Demonstrate (with documentation) how you’ve successfully implemented those controls
- Explain your testing procedures and results
- Outline interconnectivity with other systems
7. Establish a Plan of Action and Milestones (POA&M)
Lay out steps for remediation of compliance gaps and a timeline for implementation.
8. Conduct Your Self-Assessment
While previously a self-assessment has been a pass or fail scenario based on the 110 security requirements outlined in NIST 800-171, the new assessment methodology now includes a scoring system based on those 110 controls. DoD intends to use this methodology to standardize assessments of NIST implementation.
In this assessment methodology, there are three assessment levels designed to determine the level of confidence discovered in assessment results:
Basic: Self-assessment a contractor completes. Includes SSP review. Because it’s a self-generated score, it results in a “low” level of confidence.
Medium: DoD completes assessment of contractor’s SSP, resulting a medium level of confidence.
High: Government completes on-site or virtual assessment of contractor, including examination, verification, and demonstration of SSP and implementation of NIST 800-171 requirements. This results in a high-level of confidence. To begin the process of earning a high level of confidence, the contractor must first do a basic self-assessment and then submit that to DoD.
If all security requirements are met, then the contractor can earn a score of 110, representing that all 100 security controls are met. For every control not met, it’s subtracted from the 110 total.
9. Implement Remediations
Quickly rectify any areas of non-compliance identified during assessments or audits.
This enhanced checklist provides a comprehensive roadmap for achieving and maintaining compliance. By systematically following these steps, organizations can ensure they effectively protect CUI and remain in good standing for federal contracts.
10. Stay Informed on Updates
Regularly check for updates in NIST 800-171 standards and requirements to maintain ongoing compliance
Accelerating NIST 800-171 Compliance with Software
In the journey toward NIST 800-171 compliance, leveraging the right software tools can significantly streamline the process. Here’s how specialized compliance software, like Apptega, can facilitate achieving and maintaining NIST 800-171 standards.
The Advantages of Using Cybersecurity and Compliance Software
NIST 800-171 compliance software provides an integrated platform for managing all aspects of compliance, from identifying CUI to implementing required controls and getting real-time visibility into the progress to achieving compliance.
Some key features and capabilities available in a tool like Apptega are:
Simplified framework management: With questionnaire-based templates covering all the contros and subcontrols of the NIST 800-171, running your assessments and identifying gaps becomes dead simple.
Real-time reporting: Give you instant access to the data and information you need to report on your cybersecurity posture and compliance at any time.
Framework crosswalking: By crosswalking your current frameworks (such as CMMC 2.0 and NIST 800-171, for example) through Apptega Harmony, you can quickly improve your program efficiencies by 50% or more.
Increased visibility: Demonstrate to your clients, key stakeholders, and the public that you meet standards to keep CUI safe.
For a detailed explanation of how you can use Apptega to simplify your NIST 800-171 assessment, watch this 4-minute demo video:
In short, software solutions like Apptega play a crucial role in simplifying and accelerating the NIST 800-171 compliance process. They provide a comprehensive, efficient, and user-friendly approach to managing the various facets of compliance, from initial assessment to ongoing monitoring and reporting.
NIST 800-171 FAQs
NIST 800-171 is a set of controls created by the National Institute of Standards and Technology (NIST) to protect all controlled unclassified information in non-federal systems and within non-federal organizations. The purpose of the standards is standardizing and improving cybersecurity practices to protect sensitive data and decrease the likelihood of a successful cyber breach. NIST 800-171 is a requirement for every non-federal agency that processes, transmits, or stores CUI.
NIST 800-171 comprises 110 security controls spread across 14 families of requirements.
Microsoft Office 365 offers configurations and features that can support NIST 800-171 compliance, but it requires proper setup and management by the user to fully meet the compliance standards.
CMMC (Cybersecurity Maturity Model Certification) is a tiered cybersecurity framework for DoD contractors, incorporating NIST 800-171 requirements but adding additional practices and processes. NIST 800-171 is a specific set of guidelines for protecting Controlled Unclassified Information in non-federal systems.
FedRAMP compliance does not guarantee NIST 800-171 compliance, as each has distinct requirements; however, there is significant overlap, and FedRAMP compliance can contribute to meeting many NIST 800-171 requirements.
The National Institute of Standards and Technology (NIST) oversees NIST 800-171. NIST is a part of the U.S. Department of Commerce and throughout its existence since 1901 has been responsible for establishing standards guiding security for everything from atomic clocks to technology.
Executive Order 13556 is a presidential order issued in November 2010 to create a unified program to manage the safeguarding and dissemination controls for CUI. The order requires these controls be consistent with applicable laws, regulations, and government policies. All third-parties working with government agencies with access to CUI are expected to meet guidelines stemming from the executive order.
The Defense Federal Acquisition Regulation Supplement (DRARS) mandate requires all non-federal organizations within the DoD’s supply chain to meet NIST 800-171 requirements to protect and secure CUI. This applies to all non-federal systems and non-federal organizations, including both prime contractors and subcontractors.
FISMA is short for the Federal Information Security Management Act. The government passed the act in 2003 as a way to improve cybersecurity practices for federal agencies. FISMA applies specifically to federal agencies but is a driver of the NIST 800-171 standards to protect CUI, which relates specifically to non-federal agencies.
NIST 800-171 and NIST 800-53 are not the same, but both are frameworks you can implement to improve your cybersecurity practices. NIST 800-53 is part of FISMA, which relates to federal information security systems, whereas NIST 800-171 is part of DFARS and relates to non-federal systems and organizations.
If you are a non-federal organization, there are several steps you can take to become NIST 800-171 compliant, which is important if you are an organization that processes, stores, or transmits controlled unclassified information from a federal agency. To become NIST 800-171 compliant, you will need to apply appropriate security controls outlined within the requirements, test those controls, provide documentation those controls are effective, outline what your plans are to meet controls not yet in place, and complete, at a minimum, a compliance self-assessment. Also, you’ll need to ensure you adhere to DoD’s assessment methodology, and where appropriate, complete an assessment with a DoD official. Further, beginning in 2020, some contractors and subcontractors wishing to bid on or renew contracts will need to be CMMC-certified at a minimum of level 1; however, each new RFP or RFI will outline which certification level you need to secure a specific contract.
Unlike other frameworks, while NIST 800-171 is a requirement, there isn’t an official NIST 800-171 certification. Instead, you’ll need to complete an assessment that attests to your NIST 800-171 controls, and, where appropriate, complete a CMMC certification for future contracts.
Yes. NIST 800-171 and CMMC are related. Essentially, CMMC builds off NIST 800-171 controls. It’s a way for organizations to more effectively prove their adherence and compliance to NIST 800-171 controls beyond a self-assessment.
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