NIST 800-171 Compliance Made Easier
The focus of NIST 800-171 is to protect Controlled Unclassified Information (CUI) anywhere it is stored, transmitted and processed. ComplianceForge has NIST 800-171 compliance documentation that applies if you are a prime or sub-contractor. NIST 800-171 is a requirement for contractors and subcontractors to the US government, including the Department of Defense. Its requirements are close to what is expected by the NIST 800-53 moderate baseline, so it is a relatively robust set of requirements for contractors that have to implement all the controls to protect CUI.
What ComplianceForge Products Apply To NIST 800-171 Compliance?
Complying with the requirements from DFARS goes beyond just having policies and standards. When you break down the requirements to comply with DFARS / NIST 800-171, you will see how ComplianceForge's products address a specific DFARS compliance need. In the chart, "NFO" stands for Non-Federal Organization. NFO controls are required for contractors and are called out in Appendix E of NIST 800-171.
|ComplianceForge Product||DFARS Requirement|
|Cybersecurity & Data Protection Program (CDPP) or
Digital Security Program (DSP)
NIST 800-171 (multiple NFO controls)
|Vendor Compliance Program (VCP)||252.204-7008
NIST 800-171 NFO PS-7
|Cybersecurity Risk Management Program (RMP)||252.204-7008
NIST 800-171 NFO RA-1
|Cybersecurity Risk Assessment Template (CRA)||252.204-7008
NIST 800-171 3.11.1
|Vulnerability & Patch Management Program (VPMP)||252.204-7008
NIST 800-171 3.11.2
|Integrated Incident Response Program (IIRP)||252.204-7008
NIST 800-171 3.6.1
|Security & Privacy By Design (SPBD)||252.204-7008
NIST 800-171 NFO SA-3
|System Security Plan (SSP)||252.204-7008
NIST 800-171 3.12.4
|Cybersecurity Standardized Operating Procedures (CSOP)||252.204-7008
NIST 800-171 (multiple NFO controls)
|Continuity of Operations Plan (COOP)||252.204-7008
NIST 800-171 3.6.1
|Secure Baseline Configurations (SBC)||252.204-7008
NIST 800-171 3.4.1
|Information Assurance Program (IAP)||252.204-7008
NIST 800-171 NFO CA-1
Comprehensive NIST 800-171 Compliance Documentation
As a quick summary of your requirements to comply with NIST 800-171, your is expected to have several different documentation artifacts to prove that your cybersecurity program exists. The reality with compliance assessments is that if something is not documented, you cannot prove it exists. Given that documentation expectation, you need to ensure your company has the proper cybersecurity documentation in place and NIST 800-171 requires the following documentation to exist, at a minimum:
- NIST 800-53 based cybersecurity policies, standards & procedures
- System Security Plan (SSP) (requirement #3.12.4)
- Plan of Action & Milestones (POA&M) (requirements #3.12.1, 3.12.2, 3.12.3 & 3.12.4)
Solutions for NIST 800-171 Compliance
ComplianceForge currently offers several products that are designed to assist companies with NIST 800-171:
- NIST 800-171 Compliance Criteria (NCC)
- Cybersecurity & Data Protection Program (CDPP) - NIST 800-53 Version
- Digital Security Program (DSP)
We do offer discounted bundles to tie together our products into packages that can meet your unique needs, since each product serves a different purpose. Each of these products has a detailed product page that you can read more about the products and see examples:
- We have different products that cover the policies and standards component, but our most common is the NIST 800-53 version of the Cybersecurity & Data Protection Program (CDPP)
- We have one product that is a templatized set of NIST 800-171 procedures and that is the Cybersecurity Standardized Operating Procedures (CSOP)
- We have one product that is a template for both a SSP & POA&M and that is the System Security Plan (SSP)
- The NIST 800-171 Compliance Criteria (NCC) is essentially a “consultant in a box” that gets you the equivalent of 80 hours worth of a consultant’s time to break down the NIST 800-171 requirements into real criteria for you to implement.
The diagram below depicts all NIST 800-171 requirements and every one has some form of documentation requirement to demonstrate how the control is implemented:
NIST 800-171 & CMMC Compliance Criteria (NC3)
The NC3 product is considered a "consultant in a box" product to provide consultant-level guidance on how to comply with NIST 800-171. The CDPP and DSP are program-level policies and standards that will provide you with evidence you need to demonstrate compliance. What do you get if you buy the NIST 800-171 & CMMC Compliance Criteria (NC3) product?
NIST 800-171 Compliance
- The NC3 is a “consultant in a box” solution that is essentially a NIST 800-171 checklist in an editable Microsoft Excel format.
- The NC3 covers all controls in Appendix D of NIST 800-171.
- It also covers Appendix E Non-Federal Organization (NFO) controls, which are required by contractors.
- Each of the NIST 800-171 controls is mapped to its corresponding NIST 800-53 control.
- Each of the NIST 800-53 controls are broken down to identify:
- Reasonably-expected criteria to address the control.
- Applicable compliance guidance;
- Methods to address the requirement; and
- Status of compliance for each control so you can use it for a self-assessment.
- The NC3 maps into the Cybersecurity & Data Protection Program (CDPP) and Digital Security Program (DSP) products, so they can work in concert together to make it easier to comply with NIST 800-171 since your organization can have NIST-based policies and standards to support NIST 800-171 compliance efforts.
NIST 800-171 Scoping Considerations
We put together a guide to help companies scope their computing environment to help identify what is in scope for NIST 800-171 and was falls outside of scope.
Click here for a FREE GUIDE
When you look at NIST 800-171 rev 1 compliance, it has some similarities to the Payment Card Industry Data Security Standard (PCI DSS).
From the perspective of PCI DSS, if scoping is done poorly, a company's entire network may be in-scope as the CDE, which means PCI DSS requirements would apply uniformly throughout the entire company. 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.
We feel that NIST 800-171 should be viewed in the very same manner. 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.
Not sure what CUI is or if you have CUI on your network? Go to the US Government's authoritative source on the matter, the US Archives CUI Registry at https://www.archives.gov/cui/registry/category-list.