Unified Scoping Guide: NIST SP 800-171 & CMMC Assessment Boundary Scoping Guide
We put together this free guide to help organizations identify what is in scope for NIST 800-171 and Cybersecurity Maturity Model Certification (CMMC), but it applies more broadly than just Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). Without scoping being accurate, your efforts towards CMMC/NIST SP 800-171 compliance are in jeopardy, since scoping is foundational to implementing controls to ensure what needs to be protected is identified. NIST SP 800-171 R2, Chapter One, Section 1.1, Paragraph 2 specifies “The requirements apply to components of nonfederal systems that process, store, or transmit CUI, or that provide security protection for such components. If nonfederal organizations designate specific system components for the processing, storage, or transmission of CUI, those organizations may limit the scope of the security requirements by isolating the designated system components in a separate CUI security domain. Isolation can be achieved by applying architectural and design concepts (e.g., implementing subnetworks with firewalls or other boundary protection devices and using information flow control mechanisms). Security domains may employ physical separation, logical separation, or a combination of both. This approach can provide adequate security for the CUI and avoid increasing the organization’s security posture to a level beyond that which it requires for protecting its missions, operations, and assets.”
If you are not sure what CUI is or if you have CUI on your network, you need to go to the US government's authoritative source on the matter, the US Archives CUI Registry at https://www.archives.gov/cui/registry. ComplianceForge also put together a guide to understanding CUI.
When you look at NIST 800-171 compliance, it has some similarities to the Payment Card Industry Data Security Standard (PCI DSS). That may sound odd to you, but from the perspective of PCI DSS, if scoping is done poorly, a company's entire network may be in-scope as the Cardholder Data Environment (CDE), which means PCI DSS requirements would apply uniformly throughout the entire company. The same holds true for CUI environments. In these scenarios, PCI DSS compliance can be prohibitively expensive or even technically impossible. However, when the network is intelligently-designed with security in mind, the CDE can be a small fraction of the company's network, which makes compliance much more achievable and affordable.
Based on a lack of scoping guidance from the DoD, outside of what NIST already provides, our assessment of scoping NIST SP 800-171 is that it should following a similar, structured approach to scoping that is used for PCI DSS compliance. The reason for this is the proposed approach is a reasonable method, based on accepted practices to comply with cybersecurity requirements. This guide is meant to help companies identify assets within scope for NIST 800-171 and potentially find ways to minimize scope through isolation or controlled access.
You can download the "Unified Scoping Guide" that will help you scope NIST SP 800-171 & Cybersecurity Maturity Model Certification (CMMC) for Controlled Unclassified Information (CUI) & Federal Contract Information (FCI). It is a zone-based model for a data-centric security approach to defining the assessment boundary for both NIST 800-171 and CMMC.
ComplianceForge is an industry-leader in NIST 800-171 compliance documentation and have been evolving our DFARS-specific cybersecurity solutions since 2016. We specialize in cybersecurity compliance documentation and our products include the policies, standards, procedures and POA&M/SSP templates that companies (small, medium and large) need to comply with NIST 800-171 and CMMC. We've been writing cybersecurity documentation since 2005 and we are here to help make NIST 800-171 / CMMC compliance as easy and as affordable as possible.
Documentation Done Right - Our CMMC Solutions Are Scalable, Comprehensive & Efficient
We leverage the Hierarchical Cybersecurity Governance Framework to develop the necessary documentation components that are key to being able to demonstrate evidence of due diligence and due care for our clients. This methodology towards documentation acknowledges the interconnectivity that exists between policies, control objectives, standards, guidelines, controls, risks, procedures & metrics. This documentation model works well with ISO 27002, NIST CSF, NIST 800-171, NIST 800-53, FedRAMP, CIS CSC Top 20, PCI DSS, Secure Controls Framework (SCF) and other control frameworks.
Essentially, ComplianceForge simplified the concept of the hierarchical nature of cybersecurity and privacy documentation that you can see in the downloadable diagram shown below. This helps demonstrate the unique nature of these components, as well as the dependencies that exist. You can download the example to better understand how we write our documentation that links policies all the way down to metrics. This is a great solution for any organization currently using or migrating to a Governance, Risk & Compliance (GRC) or Integrated Risk Management (IRM) platform to help automate their governance practices.
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When it comes to being "audit ready" for a company with NIST 800-171 and CMMC, there is no such thing as "Bronze, Silver or Gold" levels of compliance since a standard is a standard for a reason. This is where documentation is king, since in cybersecurity compliance audits, if it is not documented then it does not exist. ComplianceForge can provide you with the documentation you need to demonstrate evidence of due care and due diligence to be considered compliant (e.g., policies, standards, procedures, SSP & POA&M). Our affordable solutions range from cybersecurity policies & standards documentation to program-level documentation, such as near "turn key" incident response, risk management or vulnerability management program documents. Our focus is on helping you become audit ready!
NIST 800-171 is intended to force contractors to adhere with reasonably-expected security requirements that have been in use by the US government for years. NIST 800-171 establishes a basic set of expectations and maps these requirements to NIST 800-53, which is the de facto standard for US government cybersecurity controls. In some ways, this is a good thing since the US government is not reinventing the wheel with new requirements. Instead, the DoD selected moderate-level controls from an existing set of recognized best practices, commonly used throughout the DoD and Federal agencies. In the long run, this will help both the US government and private businesses speak the same language for cybersecurity.
The bottom line is NIST 800-171 creates a standardized and uniform set of requirements for all Controlled Unclassified Information (CUI) security needs. This is designed to address common deficiencies in managing and protecting unclassified information by that is being stored, transmitted or processed by private businesses.
Cost of Non-Compliance With NIST 800-171 & Cybersecurity Maturity Model Certification (CMMC)
What can possibly go wrong with non-compliance in a contract with the U.S. Government?
- Contract Termination. It is reasonably expected that the U.S. Government will terminate contracts with prime contractors over non-compliance with DFARS / NIST 800-171 requirements since it is a failure to uphold contract requirements. Subcontractor non-compliance will cause a prime contractor to be non-compliant, as a whole.
- Criminal Fraud. If a company states it is compliant when it knowingly is not compliant, that is misrepresentation of material facts. This is a criminal act that is defined as any act intended to deceive through a false representation of some fact, resulting in the legal detriment of the person who relies upon the false information (e.g., False Claims Act).
- Breach of Contract Lawsuits. Both prime contractors and subcontractors could be exposed legally. A tort is a civil breach committed against another in which the injured party can sue for damages. The likely scenario for a DFARS / NIST 800-171-related tort would be around negligence on behalf of the accused party by not maintaining a specific code of conduct (e.g., DFARS / NIST 800-171 cybersecurity controls).
As you can see from those examples, the cost of non-compliance is quite significant. As always, seek competent legal counsel for any pertinent questions on your specific compliance obligations.
What Problem Does ComplianceForge Solve?
We sell cybersecurity documentation - policies, standards, procedures and more! Our documentation is meant to help companies become audit-ready!
- Lack of In House Security Experience - Writing security documentation is a skill that many good cybersecurity professionals simply are not proficient at and avoid the task at all cost. Tasking your security analysts and engineers to write comprehensive NIST 800-171 compliance documentation means you are actively taking them away from protecting and defending your network, which is not a wise use of their time. ComplianceForge offers NIST 800-171 documentation solutions that can save your organization significant time and money!
- Compliance Requirements - The reality of non-compliance with NIST 800-171 requirements means lost business and potential fines. In addition to losing contracts, charges of fraud may be leveled on companies that claim to be compliant with NIST 800-171 but cannot provide evidence. Our documentation can help you become and stay compliant with NIST 800-171 where you have documented evidence to prove it!
- Audit Failures - Security documentation does not age gracefully like a fine wine. Outdated documentation leads to gaps that expose organizations to audit failures and system compromises. Our documentation provides mapping to NIST 800-53 and other leading security frameworks to show you exactly what is required to both stay secure and compliant. Being editable documentation, you are able to easily maintain it as your needs or technologies change.
How Does ComplianceForge Solve It?
We take a holistic approach to creating comprehensive cybersecurity documentation that is both scalable and affordable. This is beyond just generic policies and allows you to build out an audit-ready cybersecurity program for your organization!
- Clear Documentation - In an audit, clear and concise documentation is half the battle. ComplianceForge provides comprehensive documentation that can prove your NIST 800-171 compliant security program exists. This equates to a time saving of hundreds of hours and tens of thousands of dollars in staff and consultant expenses!
- Time Savings - Time is money! Our cybersecurity documentation addresses DFARS and FAR requirements and this can provide your organization with a semi-customized solution that requires minimal resources to fine tune for your organization's specific needs.
- Alignment With Leading Practices - We did the heavy lifting. Our documentation is mapped to the NIST 800-53, as well as other leading security frameworks!