Understanding the Difference Between NIST 800-171 Framework and CMMC Compliance in Detail

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Since the end of 2017, all suppliers operating inside DoD supply chains have been expected to abide by the NIST 800-171 regulation. The Cybersecurity Maturity Model Certification (CMMC) has since been released. Suppliers must understand the distinctions between NIST 800-171 and CMMC and how they affect DoD contracts with which they are involved. With several cybersecurity compliance regulations coming into effect, CMMC government contracting is drastically changing for good. DoD contractors will eyeing for DoD contracts must be compliant before making a bid.

Controlling Unclassified Data

Subcontractors must secure unclassified data, which is Controlled Unclassified Information (CUI) and Federal Contract Information, as defined in DFARS 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting (FCI). 

NIST 800-171

NIST Special Publication (SP) 800-171 demands compliance by all subcontractors functioning inside the government supply chain, regardless of whether they operate for a prime or another subordinate. NIST 800-171 requirement specifies how CUI should be retrieved, disseminated, and stored.

CMMC

The Department of Defense developed CMMC, a new unified cybersecurity standard, to improve the security posture of enterprises working in DoD supply chains. CMMC is being phased in and will soon replace NIST 800-171.

NIST 800-171 Vs. CMMC

Since CMMC is being phased in, there’ll be a phase when both NIST 800-171 and CMMC are in operation. All prospective DoD agreements will need CMMC by October 1, 2025. While we are aware of DFARS vs CMMC, very few DoD contractors know the difference between NIST and CMMC compliance.

Vendors who work under several agreements may be required to comply with NIST 800-171 on specific contracts and CMMC on others.

NIST 800-171 was concerned with compliance, but CMMC is concerned with decreasing threats in DoD supply chains. Something that hasn’t changed is the goal to safeguard data.

Dates of Application

NIST 800-171: On December 31, 2017, all DoD vendors were in NIST 800-171 compliance.

CMMC: The document was issued in January 2020 as Version 1.0, with a slight upgrade to Release 1.02 in March 2020. Version 2.0 was released in November 2021. The DoD is progressively moving from NIST 800-171 to CMMC, and all new DoD agreements will need CMMC by October 1, 2025. CMMC requirements will not be incorporated into current contracts. Only new futures contracts have the possibility for CMMC requirements.

  • Compliance Techniques

NIST 800-171: Adherence with NIST 800-171 can be accomplished on your own or with the assistance of a third party. It is possible to self-certify.

CMMC: To satisfy CMMC, you can self-attest or be obliged to pass an evaluation done by an outside business (C3PAO), which will deliver the evaluation report to the CMMC-AB for clearance. The ability to self-attest to CMMC varies depending on the CMMC level you must comply with and the sort of information you must safeguard to complete a contract.

  • Security Requirements

NIST 800-171: NIST 800-171 has 14 families of criteria, with a total of 110 distinct requirements spread over the 14 families.

CMMC: The CMMC model comprises 14 domains corresponding to the families stated in NIST SP 800-171.

  • Levels

NIST 800-171: NIST 800-171 has no levels.

CMMC: There are three stages of maturity in CMMC.

Confirmation of Compliance

NIST 800-171: To adhere to NIST 800-171, you must disclose your SSP and POA&M to your DoD primary contractor or subcontractor at the point of contract commencement or renewal. These documents are evidence of compliance.
CMMC: For CMMC, you may either self-attest or have a third-party assessment organization analyze you (C3PAO). The approach for CMMC compliance differs according to the CMMC level. A senior officer from your organization must submit your self-authorization to the DoD Supplier Risk System for self-assessments. For firms that require C3PAO evaluations, the C3PAO provides the evaluation report for clearance to the CMMC-AB. Before the contract may be issued, the authorized assessment report acts as proof of compliance.

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