NIST 800-171 & CMMC Levels 1-3 "Easy Button" Solution - Editable & Affordable Cybersecurity Documentation
We get the question a lot about "Do I buy the NCP or CMMC bundle #1 to address CMMC level 3?" and it really comes down to your other compliance needs. The CMMC Bundle #1 is similar to the NIST 800-171 Compliance Program (NCP), in that both products cover CMMC levels 1-3. Both equally cover CMMC 1-3 and NIST 800-171 requirements. However, the main differences are in coverage and framework alignment:
- The NCP is a pared-down version of the Digital Security Program (DSP) that is designed to just address NIST 800-171 and CMMC in the most efficient manner possible.
- CMM Bundle #1 is aligned with NIST 800-53 (low & moderate baseline coverage) so that is ideal for an organization that wants to align its policies and standards directly with NIST 800-53.
- The NCP is a better option for companies that only need to address NIST 800-171 and CMMC - it is as close to the "easy button" as we have for NIST 800-171 & CMMC, but it is specific to just NIST 800-171 & CMMC.
- CMMC Bundle #1 is a better option for companies that “speak NIST 800-53” for other compliance requirements (e.g., FedRAMP, HIPAA, RMF, etc.) but need specific coverage for NIST 800-171 and CMMC.
The NCP is a bundle of editable compliance documentation that is specifically-tailored for NIST 800-171 R2 & the Cybersecurity Maturity Model Certification (CMMC) Levels 1, 2 & 3:
- NIST 800-171 / CMMC Policies
- NIST 800-171 / CMMC Standards
- NIST 800-171 / CMMC Procedures
- System Security Plan (SSP) Template To Document Your CUI Environment
- Plan of Action & Milestones (POA&M) Template To Document Any Control Deficiencies
- Many useful supplemental documentation templates:
- Incident Response Plan (IRP) template
- Business Impact Analysis (BIA) template
- Business Continuity / Disaster Recovery (BC/DR) template
- Data classification & handling guidelines
- Data retention guidelines
- Rules of behavior (acceptable use)
- Bring Your Own Device (BYOD) usage guidelines
- Risk management guidelines
- System hardening guidelines
- and more templates
We listened to our customers and created the NIST 800-171 Compliance Program (NCP), based on the growing demand from small and medium businesses that want a simplified approach to NIST 800-171 & CMMC compliance. The NCP is a streamlined product that is made up of other tailored ComplianceForge products to specifically address NIST 800-171 & CMMC compliance needs.
NIST 800-171 & CMMC Levels 1-3 Policies, Standards, Procedures, SSP & POA&M Templates and More!
In simple terms, the NCP gives you everything you need to comply with NIST 800-171 & CMMC v1.0 - cybersecurity policies, standards, procedures, a System Security Plan (SSP) and a Plan of Action & Milestones (POA&M). We also provide a pared-down version of our NIST 800-171 Compliance Criteria (NCC) product to provide simplified compliance guidance.
Product Example - NIST 800-171 Compliance Criteria (NCP)
Our customers choose the NIST 800-171 Compliance Program (NCP) because they:
Don't take our word for it - take a look at the examples below to see for yourself the level of professionalism and detail that went into making these products:
Cost Savings Estimate - NIST 800-171 Compliance Program (NCP)
When you look at the costs associated with either (1) hiring an external consultant to write cybersecurity documentation for you or (2) tasking your internal staff to write it, the cost comparisons paint a clear picture that buying from ComplianceForge is the logical option. Compared to hiring a consultant, you can save months of wait time and tens of thousands of dollars. Whereas, compared to writing your own documentation, you can potentially save hundreds of work hours and the associated cost of lost productivity. Purchasing the NCP from ComplianceForge offers these fundamental advantages when compared to the other options for obtaining quality cybersecurity documentation:
- For your internal staff to generate comparable documentation, it would take them an estimated 750 internal staff work hours, which equates to a cost of approximately $56,000 in staff-related expenses. This is about 9-12 months of development time where your staff would be diverted from other work.
- If you hire a consultant to generate this documentation, it would take them an 425 consultant work hours, which equates to a cost of approximately $127,000. This is about 4-8 months of development time for a contractor to provide you with the deliverable.
- The NCP is approximately 3% of the cost for a consultant or 8% of the cost of your internal staff to generate equivalent documentation.
- We process most orders the same business day so you can potentially start working with the NCP the same day you place your order.
The process of writing cybersecurity documentation can take an internal team many months and it involves pulling your most senior and experienced cybersecurity experts away from operational duties to assist in the process, which is generally not the most efficient use of their time. In addition to the immense cost of hiring a cybersecurity consultant at $300/hr+ to write this documentation for you, the time to schedule a consultant, provide guidance and get the deliverable product can take months. Even when you bring in a consultant, this also requires involvement from your internal team for quality control and answering questions, so the impact is not limited to just the consultant's time being consumed.
What Does The NIST 800-171 Compliance Program (NCP) Contain?
The NIST 800-171 Compliance Program (NCP) is a compilation of editable Microsoft Word, Excel and PowerPoint templates. There is no software to install and it is a one-time purchase. You get the following material as part of the NCP:
- Cybersecurity Policies (20 policies specific to NIST 800-171 and CMMC)
- Cybersecurity Standards (197 standards that are specific to NIST 800-171 and CMMC)
- Cybersecurity Standardized Operating Procedures (SOP) (197 procedures that are specific to NIST 800-171 and CMMC)
- System Security Plan (SSP) Template
- Plan of Action & Milestones (POA&M) Template
- Several Reference Documents
Included Policy Sections:
These are the policy sections that address the 14 sections of CUI from NIST 800-171 (as well as Non-Federal Organization (NFO) controls from Appendix E) and the 17 sections of CMMC that overlap what is in NIST 800-171. Most people forget or ignore the NFO controls component, which is a basic expectation of being compliant with NIST 800-171 but we include NFO, CUI and CMMC requirements in the NCP. Each of these policies are supported by standards that directly map to NIST 800-171 & CMMC requirements:
- Access Control (AC) Policy
- Asset Management (AM) Policy
- Audit & Accountability (AU) Policy
- Awareness & Training (AT) Policy
- Configuration Management (CM) Policy
- Cybersecurity Governance (CG) Policy
- Identification & Authentication (IA) Policy
- Incident Response (IR) Policy
- Maintenance (MA) Policy
- Media Protection (MP) Policy
- Personnel Security (PS) Policy
- Physical Protection (PE) Policy
- Recovery (RE) Policy
- Risk Management (RM) Policy
- Security Assessment (CA) Policy
- Service Provider (SP) Policy
- Situational Awareness (SA) Policy
- System & Communications Protection (SC) Policy
- System & Information Integrity (SI) Policy
- System Development (SD) Policy
Supplemental Documentation - Annexes, Templates & References
The NCP also contains the following in the “supplemental documentation” attachment that we provide as part of the NCP:
- Annex 1: Data Classification & Handling Guidelines
- Annex 2: Data Classification Examples
- Annex 3: Data Retention Periods
- Annex 4: Baseline Security Categorization Guidelines
- Annex 5: Rules of Behavior (Acceptable & Unacceptable Use)
- Annex 6: Guidelines for Personal Use of Organizational IT Resources
- Annex 7: Risk Management Framework (RMF)
- Annex 8: System Hardening
- Annex 9: Safety Considerations With Embedded Technology
- Annex 10: Indicators of Compromise (IoC)
- Template 1: Management Directive (Policy Authorization)
- Template 2: User Acknowledgement Form
- Template 3: User Equipment Receipt of Issue
- Template 4: Service Provider Non-Disclosure Agreement (NDA)
- Template 5: Incident Response Plan (IRP)
- Template 6: Incident Response Form
- Template 7: Appointment Orders (Information Security Officer)
- Template 8: Privileged User Account Request Form
- Template 9: Change Management Request Form
- Template 10: Change Control Board (CCB) Meeting Minutes
- Template 11: Plan of Action & Milestones (POA&M) / Risk Register
- Template 12: Ports, Protocols & Services (PPS)
- Template 13: Business Impact Analysis (BIA)
- Template 14: Disaster Recovery Plan (DRP) & Business Continuity Plan (BCP)
- Template 15: Privacy Impact Assessment (PIA)
- Reference 1: WISP Exception Request Process
- Reference 2: Electronic Discovery (eDiscovery) Guidelines
- Reference 3: Types of Security Controls
- Reference 4: Information Security Management System (ISMS)
In addition to that, we include the following documentation to aide in your implementation of the NCP:
- NIST NICE Cybersecurity Workforce-based Cybersecurity Roles & Responsibilities
- Cybersecurity Awareness Training (PowerPoint slideshow template)
- Data Classification Icons (PowerPoint template)
- Example - Memorandum for Record (MFR) to Define CUI
- Guide to Writing Procedures
- NIST 800-171 Scoping Guide
- Educational Posters - How To GRC (Governance, Risk & Compliance)
Affordable NIST 800-171 Compliance Documentation
The NCP is comparable to the NIST 800-171 Compliance Bundle #1 that provides the NIST 800-53 based version of these products, but offers a price break of over $700!
ComplianceForge took existing documentation and pared it down for smaller organizations that do not need or want the complexity of NIST 800-53 when complying with NIST 800-171. The NCP includes the following documents as part of its own unique bundle:
- NIST 800-171 Compliance Program - Microsoft Word document that addresses NIST 800-171 policies and standards.
- Cybersecurity Standardized Operating Procedures (CSOP) - Microsoft Word document that contains cybersecurity procedures that correspond to the policies and standards.
- System Security Plan (SSP) - Microsoft Word document that is a simplified version of our SSP product.
- NIST 800-171 Cybersecurity Program Mapping - Microsoft Excel document that contains several components:
- Plan of Action & Milestones (POA&M) template.
- Mapping from the NCP to NIST 800-171, NIST 800-53, NIST 800-160, ISO 27002 and NIST CSF.
- Methods to comply with NIST 800-171 (essentially a pared down NIST 800-171 Compliance Criteria (NCC) spreadsheet)
- Roles and responsibilities (corresponds to the Cybersecurity Standardized Operating Procedures)
- Cybersecurity Awareness Training - Microsoft PowerPoint template to provide cybersecurity awareness training.
Passing A CMMC Audit By Itself Does Not Mean NIST 800-171 Compliance
The Cybersecurity Maturity Model Certification (CMMC) does not address all requirements of NIST 800-171. While there are an additional 20 controls on top of the 110 CUI controls required by NIST 800-171, CMMC neglects the Non-Federal Organization (NFO) controls required in Appendix E of NIST 800-171. The good news is the NCP provides documentation to cover CUI, NFO and CMMC requirements for CMMC Level 1, CMMC Level 2 and CMMC Level 3 organizations.
The NCP is designed for companies that do not need or want to use the NIST 800-53 framework to manage NIST 800-171 compliance needs. This can significantly reduce complexity for companies that need to comply with NIST 800-171.
What Problem Does The NCP Solve?
- Lack of In House Security Experience - Most smaller contractors lack expertise in NIST 800-171. Tasking your managers, IT personnel or security staff to research and write comprehensive documentation is not a wise use of their time. The NCP is an efficient method to obtain comprehensive compliance documentation that can be implemented by either your in-house staff or outsourced IT vendor. Most small contractors cannot afford tens of thousands of dollars in consultant fees to help become compliant with NIST 800-171, so the NCP is designed with affordable compliance in mind to give your business the NIST 800-171 compliance documentation it needs.
- Compliance Requirements - NIST 800-171 is a reality for companies in scope for DFARS and FAR. The NCP is designed with compliance in mind, since it focuses on reasonably-expected security requirements to address the NIST 800-171 controls. The documentation contained in the NCP gives you everything you need to comply with NIST 800-171 from policies to standards to procedures to templates for your System Security Plan (SSP) and Plan of Action & Milestones (POA&M).
- Audit Failures - Without being able to demonstrate compliance with NIST 800-171, your organization will likely lose government contracts - it is as simple as that. The NCP is a tool that can jump start your organization towards being compliant with NIST 800-171 requirements.
- Vendor Requirements - It is very common for clients and partners to request evidence of a security program and this includes policies and standards. The NCP can provide this evidence!
How Does The NCP Solve It?
- Clear Documentation - The NCP comes in editable Microsoft Office format (e.g., Word, Excel and PowerPoint), so it is customizable for your needs.
- Time Savings - The time savings are immense, as compared to writing something equivalent of the NCP yourself or hiring a consultant to write it for you!
- Alignment With Leading Practices - The NCP has direct mapping to several leading cybersecurity frameworks, including:
- NIST 800-53
- ISO 27002
- NIST Cybersecurity Framework (CSF)
- NIST 800-160
- Secure Controls Framework (SCF)
FAR vs DFARS Implications for NIST 800-171
NIST 800-171 isn’t just for Department of Defense (DoD) contractors.
In addition to DoD contractors that had to comply with NIST 800-171 by the end of 2017, US Federal contractors are increasingly being required to comply with NIST 800-171. We often hear from DoD and US Government contractors that they do not know where to start, but they just know that NIST 800-171 is a requirement they cannot run from. Both DFARS and FAR point to NIST 800-171 as the expectation for contractors to implement a minimum set of cybersecurity capabilities.
The NCP addresses both Controlled Unclassified Information (CUI) and Non-Federal Organization (NFO) requirements. Many people overlook the NFO requirements that are listed in Appendix E of NIST 800-171, but the NCP includes both CUI and NFO controls so that you have complete coverage for NIST 800-171 compliance documentation.
Work Smarter and Not Harder - NIST 800-171 Scoping Considerations
NIST 800-171 allows contractors to limit the scope of the CUI security requirements to those particular systems or components that store, process or transmit CUI. Isolating CUI into its own security domain by applying architectural design principles or concepts (e.g., implementing subnetworks with firewalls or other boundary protection devices) may be the most cost-effective and efficient approach for non-federal organizations to satisfy the requirements and protect the confidentiality of CUI. Security domains may employ physical separation, logical separation, or a combination of both.
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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.
When you look at NIST 800-171 compliance, it has some similarities to the Payment Card Industry Data Security Standard (PCI DSS). If scoping is done poorly, a company's Cardholder Data Environment (CDE) can encompass the enterprise's entire network, which means PCI DSS requirements would apply uniformly throughout the entire organization. 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. NIST 800-171 should be viewed in the very same manner.
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.
Consulting Services Are Available
If you need consulting services, ComplianceForge does have experts available to consult with you on your specific NIST 800-171 compliance needs.