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NIST 800-171 Compliance Program (NCP): CMMC Level 2

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  UPDATED FOR CMMC 2.0   NIST SP 800-171 & CMMC "Easy Button" Solution - Editable & Affordable Cybersecurity Documentation

We listened to our customers and created the NIST SP 800-171 Compliance Program (NCP), based on the growing demand from small and medium businesses that want a simplified approach to NIST SP 800-171 & CMMC compliance. The NCP is a streamlined product that is made up of other tailored ComplianceForge products to specifically address NIST SP 800-171 & CMMC compliance needs. If you are looking for straightforward, editable documentation templates to just address CMMC v2.0 Level 2 (Advanced) and NIST SP 800-171, then the NCP is the best solution. The NCP is a bundle of editable compliance documentation that is specifically-tailored for NIST SP 800-171 R2 & Cybersecurity Maturity Model Certification (CMMC 2.0) Levels 1 & 2. 


The NCP documentation addresses CMMC 2.0 Level 2 and also covers the Controlled Unclassified Information (CUI) and Non-Federal Organization (NFO) controls of NIST SP 800-171. The NCP contains the following editable templates:

  • NIST SP 800-171 / CMMC Policies 
  • NIST SP 800-171 / CMMC Standards
  • NIST SP 800-171 / CMMC Procedures (these procedures map directly to NIST SP 800-171A assessment criteria)
  • System Security Plan (SSP) Template To Document Your CUI Environment
  • Plan of Action & Milestones (POA&M) Template To Document Any Control Deficiencies
  • Third-Party / Supply Chain Risk Management Guidance
  • 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)
    • Mobile device usage guidelines
    • Risk management guidelines
    • System hardening guidelines
    • and more templates

“DIBCAC Battle Tested” Policies, Standards & Procedures - NIST 800-171, NIST 800-171A & CMMC 2.0 Compliance

ComplianceForge’s NIST 800-171 / CMMC documentation has been used successfully by multiple companies during DIBCAC assessments to efficiently and effectively generate the necessary artifact documentation to demonstrate compliance with NIST SP 800-171 controls and NIST SP 800-171A control objectives. This battle tested documentation includes the necessary policies, standards, procedures, SSP, POA&M, Incident Response Plan (IRP) and other documentation that are expected to exist to successfully pass a third-party assessment, be it DIBCAC or a C3PAO.

The NCP covers 20 domains that equates to 20 policies with 188 standards that support those policies. The reason there are 20 policies and 188 standards is to address the actual requirements in NIST SP 800-171 and CMMC 2.0. "CMMC compliance" is more than just 110 requirements - those are just the CUI controls. When you take into account the Non-Federal Organization (NFO) controls from Appendix E of NIST SP 800-171 and the Assessment Objectives (AOs) from NIST SP 800-171A (equivalent to CMMC 2.0 AOs), there are more than just 110 requirements. The Excel crosswalk spreadsheet that comes with the NCP maps the standards to the requirements, so it is straightforward to understand why a requirement in the NCP exists. 


NIST SP 800-171 & CMMC 2.0 Level 2 (Advanced) Policies, Standards, Procedures, SSP & POA&M Templates and More!

In simple terms, the NCP gives you everything you need to comply with NIST SP 800-171 & CMMC v2.0 - cybersecurity policies, standards, procedures, a System Security Plan (SSP) and a Plan of Action & Milestones (POA&M). As depicted in the graphic below, the NCP is its own bundle of products that makes up the documentation you need to demonstrate compliance with NIST SP 800-171 and CMMC:


Frequently Asked Questions (FAQ) On The NCP

Below are some common questions that we receive about the NCP so we decided to help provide further transparency to help with your purchasing decision:

  • How does the NCP address CMMC v2.0 Level 2 (Advanced)?
    • The NCP was specifically written to address all NFO & CUI controls in NIST SP 800-171 R2, as well as CMMC v2.0 Level 2 (Advanced) controls. The NCP is our "easy button" solution for CMMC 2.0 L2.
    • The NCP contains editable policies, standards, procedures, SSP & POA&M templates, and much more. Continue reading to the "What Does The NIST SP 800-171 Compliance Program (NCP) Contain?" section about all that the NCP contains.
  • How is the NCP different from CMMC Bundle #2? 
    • CMMC Bundle #2 is similar to the NIST SP 800-171 Compliance Program (NCP), in that both products cover CMMC 2.0 levels 1-2. Both equally cover CMMC 2.0 1-2 and NIST SP 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), our flagship product. The NCP is tailored to be a "square peg for a square hole" to address only CMMC 2.0 L1-2 and NIST SP 800-171 requirements in the most efficient manner we can provide.
    • CMMC Bundle #2 is based on the NIST SP 800-53 R5 framework, so it is great if you need to "speak NIST SP 800-53" or have other US government-based requirements (e.g., FISMA, RMF, HIPAA, etc.) that are based on NIST SP 800-53. This bundle is aligned with NIST SP 800-53 (low & moderate baseline coverage) so that is ideal for an organization that wants to align its policies and standards directly with NIST SP 800-53. 
    • If you are just looking for CMMC & NIST SP 800-171 coverage, then the NCP is a better fit.
  • How does the NCP apply to ISO 27001/27002? 
    • The NCP provides mapping to applicable ISO 27002 controls, as well as NIST CSF & NIST SP 800-53.
    • If you look at mapping out requirements, ISO 27002 provides about 2/3 coverage for NIST SP 800-171/CMMC, so it is not enough to get you to CMMC 2.0 L2.
    • The Excel spreadsheet that is included in the NCP includes mapping to ISO 27002 controls.
  • Can you provide us with examples of the documentation & templates that are part of the NCP?
  • What are the gaps in the NCP for CMMC 2.0 Level 2 once we purchase this?
    • The NCP provides fully-mapped requirements within the policies, standards, procedures, etc. Therefore, any "gaps" in coverage are specific to your implementation of the requirements to become compliant with NIST SP 800-171 & CMMC.
    • We are "tool makers" that provide you with templates that identify the Minimum Security Requirements (MSR) in an editable, efficient template format. You have to implement those requirements to be considered compliant with NIST SP 800-171 & CMMC.
    • There are no professional service hours included in the purchase of the NCP, but we do have consultants that are available for customization/consulting via a separate Statement of Work (SOW).
  • How often is the NCP updated?
    • As NIST SP 800-171 & CMMC change, we update the NCP. There is no set schedule for updates, since we update products based on new guidance from the DoD, NIST and CMMC-AB.
    • The NCP comes with one-year of updates, so as long as you have an active subscription you will receive updated versions of the documentation, along with errata that identifies what changed.
    • After the first year, you can purchase updates for $800/yr, as described on our updates page
  • Is the NCP a subscription? How long does a license last?
    • The NCP is perpetual and a single-site license. However, if you want to keep getting updates, you just have to pay for updates after the first year.
    • NIST SP 800-171 & CMMC evolve, so that is why we offer updates. It takes considerable effort for us to develop and maintain this documentation, so that is why we charge for updates.
  • Can I upgrade to a different bundle if my needs change?
    • Yes! We can credit your purchase towards an upgraded bundle if your business needs change and you have to address CMMC 2.0 L3 requirements.

Product Example - NIST SP 800-171 Compliance Program (NCP)

Our customers choose the NIST SP 800-171 Compliance Program (NCP) because they:

  • Need an efficient way to comply with NIST SP 800-171 / CMMC and make the process as simple as possible
  • Need to be able to edit the document to their specific needs
  • Need an affordable solution

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:


2020.2-download-example-nist-800-171-cmmc-compliance-program-cybersecurity-policies-standards.jpg    2020.2-download-example-nist-800-171-cmmc-cybersecurity-procedures.jpg   2020.2-download-example-nist-800-171-cmmc-system-security-plan-ssp-template.jpg   




Cost Savings Estimate - NIST SP 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 1,000 internal staff work hours, which equates to a cost of approximately $76,000 in staff-related expenses. This is about 9-18 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 estimated 700 consultant work hours, which equates to a cost of approximately $210,000. This is about 4-12 months of development time for a contractor to provide you with the deliverable.
  • The NCP is approximately 2% of the cost for a consultant or 6% 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. 


CMMC Center of Awesomeness (CMMC-COA) Mappings

The NIST 800-171 Compliance Program (NCP) has mappings into and supports the use of CMMC Center of Awesomeness (CMMC-COA) spreadsheets.


What Does The NIST SP 800-171 Compliance Program (NCP) Contain?

The NIST SP 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 (policies specific to NIST SP 800-171 and CMMC 2.0 L2)
  • Cybersecurity Standards (standards that are specific to NIST SP 800-171 and CMMC 2.0 L2)
  • Cybersecurity Standardized Operating Procedures (SOP) (procedures that are specific to NIST SP 800-171 and CMMC 2.0 L2)
  • System Security Plan (SSP) Template  
  • Plan of Action & Milestones (POA&M) Template
  • Several Reference Documents   

The NCP comes with the following policies and standards, including procedures that map directly to the standards:

Policy Domain Standard # CMMC 2.0 / NIST SP 800-171 Standard
Access Control (AC) Policy AC-01 Account Management 
AC-02 Access Enforcement 
AC-03 Data Flow Enforcement – Access Control Lists (ACLs)
AC-04 Least Privilege 
AC-05 Authorize Access to Security Functions 
AC-06 Privileged Accounts 
AC-07 Non-Privileged Access for Non-Security Functions 
AC-08 Auditing Use of Privileged Functions 
AC-09 Prohibit Non-Privileged Users from Executing Privileged Functions 
AC-10 Account Lockout 
AC-11 System Use Notification (Logon Banner)
AC-12 Session Lock 
AC-13 Pattern-Hiding Displays 
AC-14 Session Termination 
AC-15 Automated Monitoring & Control 
AC-16 Protection of Confidentiality / Integrity Using Encryption
AC-17 Managed Access Control Points
AC-18 Privileged Commands & Access
AC-19 Wireless Networking 
AC-20 Authentication & Encryption
AC-21 Access Control For Mobile Devices
AC-22 Full Device & Container-Based Encryption 
AC-23 Use of External Information Systems 
AC-24 Limits of Authorized Use 
AC-25 Portable Storage Devices
AC-26 Publicly Accessible Content
Asset Management (AM) Policy AM-01 Asset Governance 
AM-02 Security of Assets & Media
AM-03 Asset Inventories 
AM-04 Updates During Installations / Removals
AM-05 Component Duplication Avoidance 
Awareness & Training (AT) Policy AT-01 Security & Privacy-Minded Workforce 
AT-02 Security & Privacy Awareness 
AT-03 Role-Based Security & Privacy Training 
AT-04 Training Records 
AT-05 Insider Threat Awareness
Audit & Accountability (AU) Policy AU-01 Continuous Monitoring
AU-02 Inbound & Outbound Communications Traffic 
AU-03 Centralized Collection of Security Event Logs
AU-04 System Generated Alerts 
AU-05 Content of Audit Records 
AU-06 Monitoring Reporting 
AU-07 Sensitive Audit Information
AU-08 Audit Record Retention
AU-09 Reviews & Updates 
AU-10 Response To Audit Processing Failures
AU-11 Correlate Monitoring Information
AU-12 Time Stamps 
AU-13 Synchronization With Authoritative Time Source
AU-14 Protection of Audit Information 
AU-15 Access by Subset of Privileged Users 
Security Assessment (CA) Policy CA-01 Information Assurance (IA) Operations
CA-02 Security Assessments 
CA-03 Assessor Independence
CA-04 System Security Plans (SSP)
CA-05 Plan of Action & Milestones (POA&M)
CA-06 Plan / Coordinate with Other Organizational Entities
Cybersecurity Governance (CG) Policy CG-01 Statutory, Regulatory & Contractual Compliance 
CG-02 Security Portfolio Management
CG-03 Allocation of Resources 
CG-04 Secure Development Life Cycle (SDLC) Management
CG-05 Security Controls Oversight 
CG-06 Internal Audit Function
Configuration Management (CM) Policy CM-01 Configuration Management Program
CM-02 System Hardening Through Baseline Configurations 
CM-03 Reviews & Updates
CM-04 Configure Systems, Components or Services for High-Risk Areas 
CM-05 Configuration Change Control 
CM-06 Test, Validate & Document Changes 
CM-07 Security Representative for Change
CM-08 Security Impact Analysis for Changes 
CM-09 Access Restriction For Change
CM-10 Stakeholder Notification of Changes 
CM-11 Least Functionality
CM-12 Periodic Review
CM-13 Prevent Program Execution
CM-14 Unauthorized or Authorized Software (Blacklisting or Whitelisting)
CM-15 User-Installed Software
Identification & Authentication (IA) Policy IA-01 Identity & Access Management (IAM) 
IA-02 Identification & Authentication for Organizational Users 
IA-03 Identification & Authentication for Devices
IA-04 Authenticator Management (Passwords)
IA-05 Network Access to Privileged Accounts
IA-06 Network Access to Non-Privileged Accounts 
IA-07 Local Access to Privileged Accounts 
IA-08 Network Access to Privileged Accounts - Replay Resistant
IA-09 Identifier Management (User Names)
IA-10 Password-Based Authentication 
IA-11 Protection of Authenticators
IA-12 Authenticator Feedback
Incident Response (IR) Policy IR-01 Incident Response Operations
IR-02 Incident Handling 
IR-03 Incident Response Plan (IRP) 
IR-04 IRP Update
IR-05 Incident Reporting Assistance 
IR-06 Incident Response Training 
IR-07 Incident Stakeholder Reporting 
IR-08 Incident Response Testing
IR-09 Root Cause Analysis (RCA) & Lessons Learned
Maintenance (MA) Policy MA-01 Maintenance Operations 
MA-02 Controlled Maintenance 
MA-03 Maintenance Tools
MA-04 Inspect Tools 
MA-05 Inspect Media 
MA-06 Non-Local Maintenance
MA-07 Notification of Non-Local Maintenance
MA-08 Authorized Maintenance Personnel
Media Protection (MP) Policy MP-01 Data Protection 
MP-02 Media Access 
MP-03 Media Storage
MP-04 Digital Media Sanitization
MP-05 Media Marking 
MP-06 Media Transportation 
MP-07 Transmission Integrity 
MP-08 Media Use
Physical Protection (PE) Policy PE-01 Physical & Environmental Protections
PE-02 Physical Access Authorizations 
PE-03 Physical Access Logs 
PE-04 Monitoring Physical Access
PE-05 Intrusion Alarms / Surveillance Equipment 
PE-06 Access Control for Output Devices
PE-07 Access Control for Transmission Medium
PE-08 Physical Access Control 
PE-09 Alternate Work Site
PE-10 Delivery & Removal 
Personnel Security (PS) Policy PS-01 Human Resources Security Management
PS-02 Access Agreements 
PS-03 Separation of Duties
PS-04 Personnel Screening 
PS-05 Personnel Transfer
PS-06 Personnel Sanctions
PS-07 Personnel Termination 
PS-08 Rules of Behavior
PS-09 Social Media & Social Networking Restrictions
PS-10 Third-Party Personnel Security
Recovery (RE) Policy RE-01 Business Continuity Management System (BCMS)
RE-02 Data Backups
Risk Management (RM) Policy RM-01 Risk Management Program 
RM-02 Risk Assessment 
RM-03 Risk Remediation 
RM-04 Privileged Access
RM-05 Vulnerability Scanning 
RM-06 Update Tool Capability
Situational Awareness (SA) Policy SA-01 Threat Intelligence Feeds
System & Communications Protection (SC) Policy SC-01 Network Security Management 
SC-02 Boundary Protection 
SC-03 Remote Access 
SC-04 Network Access Points
SC-05 External Telecommunications Services 
SC-06 Information In Shared Resources 
SC-07 Deny Traffic by Default & Allow Traffic by Exception
SC-08 System Interconnections
SC-09 Internal System Connections
SC-10 Split Tunneling
SC-11 Network Disconnect
SC-12 Public Key Infrastructure (PKI) 
SC-13 Use of Cryptographic Controls 
SC-14 Electronic Messaging
SC-15 Session Authenticity 
SC-16 Domain Name Service (DNS) Resolution 
SC-17 Architecture & Provisioning for Name / Address Resolution Service
SC-18 Secure Name / Address Resolution Service (Recursive or Caching Resolver)
SC-19 Network Segmentation
System Development (SD) Policy SD-01 Technology Development & Acquisition
SD-02 Security Requirements 
SD-03 Ports, Protocols & Services In Use
SD-04 Use of Approved PIV Products
SD-05 Documentation Requirements
SD-06 Functional Properties 
SD-07 Secure Coding 
SD-08 Security & Privacy Testing Throughout Development 
SD-09 Developer Configuration Management 
System & Information Integrity (SI) Policy SI-01 Secure Engineering Principles 
SI-02 Alignment With Enterprise Architecture 
SI-03 Technology Lifecycle Management
SI-04 Software Patching
SI-05 Endpoint Protection Measures 
SI-06 Malicious Code Protection (Anti-Malware) 
SI-07 Mobile Code
SI-08 Process Isolation 
SI-09 Application Partitioning
SI-10 Memory Protection 
SI-11 Collaborative Computing Devices 
SI-12 Alternate Physical Protection 
Service Provider (SP) Policy SP-01 Third-Party Management 
SP-02 Third-Party Services 
SP-03 Identification of Functions, Ports, Protocols & Services
SP-04 Managing Changes To Third-Party Services

Included Policy Sections:

These are the policy sections that address the 14 sections of CUI from NIST SP 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 SP 800-171. Most people forget or ignore the NFO controls component, which is a basic expectation of being compliant with NIST SP 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 SP 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:

  • Artifact 1: Data Classification & Handling Guidelines
  • Artifact 2: Data Classification Examples
  • Artifact 3: Data Retention Periods
  • Artifact 4: Baseline Security Categorization Guidelines
  • Artifact 5: Rules of Behavior (Acceptable & Unacceptable Use)
  • Artifact 6: Guidelines for Personal Use of Organizational IT Resources
  • Artifact 7: Risk Management Framework (RMF)
  • Artifact 8: System Hardening
  • Artifact 9: Safety Considerations With Embedded Technology
  • Artifact 10: Indicators of Compromise (IoC)
  • Artifact 11: Management Directive (Policy Authorization)
  • Artifact 12: User Acknowledgement Form
  • Artifact 13: User Equipment Receipt of Issue
  • Artifact 14: Service Provider Non-Disclosure Agreement (NDA)
  • Artifact 15: Incident Response Plan (IRP)
  • Artifact 16: Incident Response Form
  • Artifact 17: Appointment Orders (Information Security Officer)
  • Artifact 18: Privileged User Account Request Form
  • Artifact 19: Change Management Request Form
  • Artifact 20: Change Control Board (CCB) Meeting Minutes
  • Artifact 21: Plan of Action & Milestones (POA&M) / Risk Register
  • Artifact 22: Ports, Protocols & Services (PPS)
  • Artifact 23: Business Impact Analysis (BIA)
  • Artifact 24: Privacy Impact Assessment (PIA)
  • Artifact 25: Disaster Recovery Plan (DRP) & Business Continuity Plan (BCP)
  • Artifact 26: Exception Request Form
  • Artifact 27: Electronic Discovery (eDiscovery) Guidelines
  • Artifact 28: Types of Security Controls
  • Artifact 29: Cybersecurity Mission, Vision & Strategy
  • Artifact 30: Memorandum for Record (MFR) to Define CUI
  • Artifact 31: Cybersecurity Roles & Responsibilities Overview

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)
  • Guide to Writing Procedures
  • NIST SP 800-171 Scoping Guide

Affordable NIST SP 800-171 & CMMC 2.0 Compliance Documentation

The NCP is comparable to the NIST SP 800-171 Compliance Bundle #2 that provides the NIST SP 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 SP 800-53 when complying with NIST SP 800-171. The NCP includes the following documents as part of its own unique bundle:

  • NIST SP 800-171 Compliance Program - Microsoft Word document that addresses NIST SP 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 SP 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 SP 800-171, NIST SP 800-53, NIST SP 800-160, ISO 27002 and NIST CSF.
    • Methods to comply with NIST SP 800-171 (essentially a pared down NIST SP 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.

The official overview of CMMC 2.0 can be read at https://dodcio.defense.gov/CMMC/. As you can see from the infographic show below, CMMC evolved from 5 levels to 3 levels. If you store, transmit or process Controlled Unclassified Information (CUI) then you are CMMC v2.0 Level 2 (Advanced). ComplianceForge's NIST 800-171 Compliance Program (NCP) is specifically designed as the "easy button" for CMMC v2.0 Level 2 (Advanced). CMMC v2.0 Level 2 (Advanced) removes the CMMC v1.02 practices and processes. The focus is on NIST SP 800-171 R2 CUI and NFO controls. 


From a practical perspective, to comply with Level 2 for CMMC 2.0, an Organization Seeking Certification (OSC) is going to need to address 171 controls. These 171 controls are made up of 110 Controlled Unclassified Information (CUI) controls and 61 Non-Federal Organization (NFO) controls. If you are unfamiliar with NFO controlsplease read this to familiarize yourself with these fundamental requirements that are expected to exist for a cybersecurity program to exist. 


Passing A CMMC Assessment By Itself Does Not Mean NIST SP 800-171 Compliance

The Cybersecurity Maturity Model Certification (CMMC) framework does not  address all requirements of NIST SP 800-171 R2. CMMC neglects the Non-Federal Organization (NFO) controls required in Appendix E of NIST SP 800-171. The good news is the NCP provides documentation to cover CUI, NFO and CMMC requirements for CMMC Level 1 & CMMC Level 2.


The NCP is designed for companies that do not need or want to use the NIST SP 800-53 framework to manage NIST SP 800-171 compliance needs. This can significantly reduce complexity for companies that need to comply with NIST SP 800-171. 


What Problem Does The NCP Solve?

  • Lack of In House Security Experience - Most smaller contractors lack expertise in NIST SP 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 SP 800-171, so the NCP is designed with affordable compliance in mind to give your business the NIST SP 800-171 compliance documentation it needs. 
  • Compliance Requirements - NIST SP 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 SP 800-171 controls. The documentation contained in the NCP gives you everything you need to comply with NIST SP 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 SP 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 SP 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 SP 800-53
    • ISO 27002
    • NIST Cybersecurity Framework (CSF)
    • NIST SP 800-160
    • Secure Controls Framework (SCF)  

There is no getting around the necessity to read and be familiar with NIST 800-171 and CMMC - that can’t be avoided. One of the best things you can to start off is make yourself a pot of coffee and familiarize yourself with the CMMC Kill Chain since you really need to have a prioritized plan to address NIST 800-171 / CMMC requirements. This is the process we recommend for using the NCP:

  1. Familiarize yourself with all the documents that come as part of the NCP. At least read through the table of contents and appendices to see what is contained so you understand where to find things.
  2. Start with the policies & standards – that is a relatively easy win and establishes requirements that other practices will be expected to meet.
  3. Understand the scope of your CUI environment:
  4. Based on finalizing your policies and standards, start working through the “low hanging fruit” in the SSP since those are the items already known and can be documented. The SSP is a living document so add to it as you work through requirements.
  5. From a procedural perspective, you have to identify the stakeholders and work with them to document their procedures.
  6. The CSOP serves as the “buffet table” for those stakeholders to cut & paste procedure templates for the controls they are responsible for so they have a defined starting point to document how they implement control.
  7. Stakeholders are the subject matter experts and only they know how the processes function and they are the ones who need to document the procedures. 

FAR vs DFARS Implications for NIST SP 800-171

NIST SP 800-171 isn’t just for Department of Defense (DoD) contractors. In addition to DoD contractors that had to comply with NIST SP 800-171 by the end of 2017, US Federal contractors are increasingly being required to comply with NIST SP 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 SP 800-171 is a requirement they cannot run from. Both DFARS and FAR point to NIST SP 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 SP 800-171, but the NCP includes both CUI and NFO controls so that you have complete coverage for NIST SP 800-171 compliance documentation.

Work Smarter and Not Harder - NIST SP 800-171 Scoping Considerations

NIST SP 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 SP 800-171 and was falls outside of scope.

When you look at NIST SP 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 SP 800-171 should be viewed in the very same manner.

We feel that NIST SP 800-171 should be viewed in the very same manner. This guide is meant to help companies identify assets within scope for NIST SP 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 SP 800-171 compliance needs.

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    - LT on Aug 16th 2018

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