August 17, 2023

CMMC vs NIST 800-171: Key Similarities and Differences

In the world of compliance and regulatory requirements, there are many acronyms and standards being used. These acronyms and standards help businesses define who they are, what they do, and how to manage their processes to be compliant. In this blog post we will cover some common acronyms in information security compliance as well as discuss the similarities between CMMC & NIST 800-171.

What is CMMC?

Cybersecurity Maturity Model Certification (CMMC) is a certification used to assess the maturity of an organization's cybersecurity program. It was developed by the Department of Defense (DoD) to assist the nearly 400,000 Defense Industrial Base (DIB) contractors in protecting the supply chain from cyber threats. CMMC, when published, will be considered the required framework for private contractors to adhere to in order to do business with the government. NIST 800-171, NIST 800-172, and CSF are all included in CMMC because it focuses on more than just meeting regulatory requirements -- it's taking the best practices to help you assess how well you are implementing necessary controls in your organization's cybersecurity program while protecting the supply chain. There are 3 CMMC 2.0 compliance certification levels. When it appears in government-awarded contracts in the future, it will be referred to as DFARS 242.204-7021.

What is NIST 800-171?

NIST 800-171 is a specific set of cybersecurity guidelines for federal agencies with revision 2 currently published, and revision 3 in a "draft" state. Many of the controls in NIST 800-171 are present in CMMC. The initial framework, released in May 2018, outlines a framework for risk management that can be used to help organizations assess their current cybersecurity posture and develop an action plan to address any weaknesses or gaps in their security controls. In January 2021 NIST released a second revision. On May 10, 2023, NIST published a draft of the third revision of the NIST 800-171 cybersecurity framework standards. And earlier today, NIST issued a summary of comments and analysis related to NIST 800-171 revision 3, and how they will move forward.

The NIST 800-171 standard was developed based on input from industry experts and government officials under the direction of the National Institute of Standards and Technology (NIST). It is intended to be used by all federal agencies as well as state and local governments that receive federal funding; however, other organizations may also find it useful if they have similar needs -- such as protecting sensitive information stored in electronic systems or networks.

What are the Similarities between NIST 800-171 and CMMC?

In the realm of cybersecurity compliance, both the Cybersecurity Maturity Model Certification (CMMC) and the National Institute of Standards and Technology (NIST) Special Publication 800-171 bear resemblance as pivotal frameworks aimed at fortifying the information security landscape of organizations. Noteworthy parallels between these frameworks underscore their shared commitment to heightening the protection of sensitive data and ensuring the triumvirate of confidentiality, integrity, and availability.

A common unifying thread lies in their pertinence to entities engaged with the U.S. Department of Defense (DoD) and the stewardship of Controlled Unclassified Information (CUI) within the defense supply chain. These frameworks stand as cardinal prerequisites for entailing eligibility to vie for, and secure, coveted government contracts.

Converging on a risk-centric approach, both frameworks compel organizations to conduct introspective assessments of their security vulnerabilities. This introspection forms the bedrock upon which organizations orchestrate judicious implementation of controls and safeguards in accordance with the commensurate level of risk they are exposed to. Here's a short breakdown of the similarities between the two:

CMMC 2.0 Level 2 for the sharing of Controlled Unclassified Information (CUI) lines up directly with NIST 800-171’s 110 controls (Level 3 goes beyond NIST 800-171)
The security requirements of each framework are aligned. Both focus on protecting the confidentiality, integrity, and availability of organizational information assets (including data), including CUI.
They both describe the roles that different individuals play in an organization's cybersecurity program as well as how these roles interact with one another.
Both require organizations to identify their assets and vulnerabilities before creating a plan for risk management.
They both require organizations to develop a cybersecurity program that includes policies, procedures, and standards.
The frameworks also have similar requirements for risk management. CMMC compliance requires organizations to identify, assess, prioritize, and respond to risks while NIST 800-171 focuses on identifying and assessing risks and then developing mitigation strategies.

What are the Differences between NIST 800-171 and CMMC?

Let's explore the differences between two important frameworks: the Cybersecurity Maturity Model Certification (CMMC) 2.0 and the National Institute of Standards and Technology (NIST) Special Publication 800-171. While both aim to boost cybersecurity, they have distinct features that we'll break down for you. So, let's dive into this comparison to shed light on what sets these frameworks apart:

Aspect	CMMC 2.0	NIST 800-171
Framework Purpose	Comprehensive framework assessing and certifying cybersecurity maturity, with focus on safeguarding Controlled Unclassified Information (CUI) in defense supply chain.	Set of security controls for safeguarding CUI within non-federal systems and organizations.

Certification Approach	Tiered model with 3 levels Higher levels encompass lower levels, and build on each other	Guidelines without formal certification Organizations self-assess compliance

Maturity Levels	3 levels, increase cybersecurity practices	No maturity levels, 14 families of controls
Process Emphasis	Establish documented processes Foster proactive cybersecurity culture	Detailed security controls, but less emphasis on process documentation

Coverage of Practices and Controls	Expands NIST 800-171 with additional practices Includes domains like incident response, awareness	110 security controls within 14 families

Third-Party Assessment	Requires certified C3PAOs for compliance	No third-party assessments, self-assess
Risk Management Approach	Risk-based approach Controls are based on data sensitivity	Risk management emphasized Controls categorized as "basic" or "derived"

Conformance Scope	Broader scope, includes cybersecurity maturity beyond CUI protection	Focus on CUI protection, narrower scope

Inclusion of Domains	Additional domains included like Asset Management, Recovery, Governance	Primarily centered on CUI protection

Control and Practice Documentation	Detailed documentation at different maturity levels, compliance roadmap	Detailed control requirements, varying level of specificity for implementation

Both frameworks can be used to improve your organization's cybersecurity posture

Both CMMC and NIST 800-171 can be used to assess your organization's cybersecurity posture. Each framework has its strengths and weaknesses, so it's important to choose the one that best fits your needs. If you need to meet regulatory requirements, use CMMC; if not, use NIST 800-171.

Both frameworks are good for assessing maturity in five key areas:

governance
risk management
incident response
data protection (including privacy)
technology assurance (which includes risk assessment)

By using either of these frameworks as part of an overall process for improving your organization's cybersecurity posture--and by continuously improving upon it over time--you'll be well on your way toward making sure that it stays ahead of evolving threats while meeting compliance requirements as they change over time as well

Does passing the CMMC certification mean that an organization has passed NIST 800-171?

The CMMC certification is a good way to demonstrate compliance with NIST 800-171 and other standards and will be required for Defense Industrial Base contractors soon (we estimate by the end of 2024). To really stand out from the crowd, defense and aerospace organizations that want to show their commitment to security may find it more beneficial to pursue multiple certifications that dovetail nicely (such as both CMMC and ISO/IEC 27001, or CMMC and SOC 2 Type II) instead of focusing solely on one standard or regulation. By pursuing multiple certifications, you can demonstrate your commitment to different aspects of information security management:

The CMMC certification demonstrates that your organization has implemented controls over its software development lifecycle processes--a key part of achieving compliance with NIST 800-171.
The ISO/IEC 27001 standard helps ensure that your organization's data protection policies are up-to-date and effective at protecting sensitive customer information from unauthorized access by employees or third parties who have legitimate access rights within the company but lack authorization outside those boundaries (e.g., contractors).
SOC 2 Type II is a prominent cybersecurity framework with shared objectives. Both CMMC and SOC 2 emphasize robust controls and practices to safeguard sensitive data and systems. While CMMC 2.0 targets government DoD contractors and suppliers, SOC 2 Type II caters to service organizations. The former assesses maturity across diverse cybersecurity domains, while the latter evaluates security, availability, processing integrity, confidentiality, and privacy. Although their scopes differ, both frameworks underline continuous improvement, risk assessment, and comprehensive compliance. Discover how these frameworks fortify cybersecurity and foster stakeholder trust. the cybersecurity game tight to build confidence with everyone in the loop.