Cybersecurity Desk: CMMC vs. NIST SP 800-171: Understanding the Differences
In Department of Defense (DoD) compliance, many acronyms and standards define how businesses manage processes to stay compliant. In this Cybersecurity Desk column, which was first released in Heat Treat Today’s September 2024 People of Heat Treat print edition. In it, Joe Coleman, cybersecurity officer at Bluestreak Compliance, a division of Bluestreak | Bright AM™, discusses the similarities and differences between the Cybersecurity Maturity Model Certification (CMMC) 2.0 and NIST Special Publication 800-171 Rev. 2.
What Is CMMC?
The Cybersecurity Maturity Model Certification (CMMC) evaluates the maturity of an organization’s cybersecurity program. Developed by the DoD, it aims to equip over 300,000 Defense Industrial Base (DIB) contractors with robust defenses against cyber threats. Once formally published, CMMC 2.0 will be a mandated framework for private contractors and subcontractors seeking government contracts.
CMMC’s comprehensive approach includes NIST SP 800-171, NIST SP 800-172, and the Cybersecurity Framework (CSF), incorporating industry-leading practices. It ensures the effective implementation of critical controls and safeguards the integrity of the supply chain. CMMC 2.0 compliance certification has three levels:
- Level 1: Foundational: For companies handling Federal Contract Information (FCI) but not Controlled Unclassified Information (CUI).
- Level 2: Advanced: For companies that store, process, or transmit CUI.
- Level 3: Expert: For companies implementing highly advanced cybersecurity practices.
It will be referred to as DFARS 242.204-7021 when integrated into government-awarded contracts.
What Is NIST SP 800-171?
NIST SP 800-171 is the National Institute of Standards and Technology Special Publication 800-171 Rev. 2. It outlines security standards for non-federal organizations that handle CUI, ensuring they maintain strong cybersecurity practices. Compliance is mandatory for DoD primes, contractors, and supply chain service providers.
NIST 800-171 specifies five core cybersecurity areas: identify, protect, detect, respond, and recover. These areas serve as a framework to protect CUI and mitigate cyber risks. The standard comprises 110 security controls within 14 control families, leading to 320 control or assessment objectives. Compliance is measured on a 110-point scale, with a possible range from -203 to 110. An initial negative score is not uncommon.
Even for organizations with some cyber/IT security measures, retaining a qualified DFARS/NIST 800-171 consultant or a CMMC Registered Practitioner (RP) or CMMC Registered Practitioner Advanced (RPA) is highly recommended to guide you through the process.
Similarities Between NIST SP 800-171 and CMMC
Both CMMC and NIST SP 800-171 aim to strengthen information security and protect sensitive data, ensuring the confidentiality, integrity, and availability of organizational information assets. Here are some of the key similarities:
- Control Alignment: CMMC 2.0 Level 2 aligns with NIST SP 800-171 Rev. 2’s 110 controls.
- Focus: Both frameworks emphasize protecting data confidentiality, integrity, and availability.
- Role Definitions: They describe roles within an organization’s cybersecurity program and interactions among those roles.
- Asset Identification: Both require identifying assets and vulnerabilities and creating a risk management plan.
- Cybersecurity Program Development: Organizations must develop a program with policies, procedures, and standards.
- Risk Management: Both require identifying, assessing, prioritizing, and responding to risks, though CMMC is more comprehensive.
Differences Between NIST SP 800-171 and CMMC
While both frameworks enhance cybersecurity, they have distinct features:
- Compliance Requirement: DFARS 252.204-7012 mandates NIST SP 800-171 compliance; DFARS 252.204-7021 mandates CMMC certification for handling CUI.
- Assessment: NIST SP 800-171 compliance is self-assessed, while CMMC requires an independent third-party assessment.
- Levels: CMMC has three certification levels, each more stringent than NIST SP 800-171 alone.
- Scope: CMMC integrates additional NIST SP 800-172 practices and industry standards beyond NIST SP 800-171.
Conclusion
Understanding the differences between CMMC 2.0 and NIST SP 800-171 Rev. 2 is crucial for organizations enhancing their cybersecurity posture. Both frameworks are essential for assessing maturity in governance, risk management, incident response, data protection, and technology assurance. Adopting these frameworks ensures proactive adaptation to evolving threats and compliance with regulatory standards.
About the Author:
Joe Coleman is the cybersecurity officer at Bluestreak Compliance, which is a division of Bluestreak | Bright AM™. Joe has over 35 years of diverse manufacturing and engineering experience. His background includes extensive training in cybersecurity, a career as a machinist, machining manager, and an early additive manufacturing (AM) pioneer. Joe presented at the Furnaces North America (FNA 2024) convention on DFARS, NIST 800-171, and CMMC 2.0.
For more information: Contact Joe at joe.coleman@go-throughput.com.
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