The National Institute of Standards and Technology (NIST), a non-regulatory government agency within the U.S. Department of Commerce provides guidelines for various industries including cybersecurity. The NIST Special Publication 800 series provides guidelines for computer systems and focuses on the security and privacy needs of the U.S. federal government’s information and information system. The Federal Information Security Modernization Act (FISMA), a federal law defining security requirements for federal agencies relies on NIST Special Publication 800 series to enforce its mandate, which includes IT inventory, asset management, risk assessments, system security plan and continuous monitoring. Non-federal organizations who do not contract with the federal government and do not handle such information can also benefit from implementing these frameworks to improve the company’s cybersecurity posture, protect data and network security and enhance the organization’s reputation.
Key differences and compliance requirements
The primary difference between the two frameworks is the scope they cover and the organizations that they are designated for. It is important to understand your government contract to assure compliance.
NIST 800-53 is applicable to federal agencies and organizations that handle or process federal information or operate information systems on behalf of a federal agency. This includes vendors, suppliers and contractors that access federal information and state and local governments that manage federal programs such as student loans. It provides security and privacy controls covering areas such as access control, audit and accountability, contingency planning and supply chain management. NIST 800-53 is tied to Federal Risk and Authorization Management Program (FedRAMP) for cloud computing service providers. Cloud Service Providers are required to assess their compliance with these controls and obtain their authorization to operate (ATO) from designated officials. NIST 800-53 includes about 1000 controls which are organized into 20 families. Non-compliance with NIST 800-53 for companies processing federal information can result in heavy penalties and reputation damage.
NIST 800-171, a subset of requirements from NIST 800-53, is designed for non-federal systems and organizations that store, process, or transmit Controlled Unclassified Information (CUI). This includes universities supported by federal grants, manufacturers supplying products to federal agencies and service providers. CUI is defined as information that is unclassified but requires protection and dissemination controls under U.S. law, regulations, or government-wide policies. It needs to be protected because of its potential impact on national security and government operations. CUI must be safeguarded according to specific handling and protection requirements set by the government. Companies that are Department of Defense (DoD) contractors or within the supply chain are expected to meet these controls. The Cybersecurity Maturity Model (CMMC) was developed by the DoD to enhance and assess the cybersecurity posture of organizations within the Defense Industrial Base (DIB). CMMC incorporates the controls from NIST 800-171 for DIB certification. The CMMC final rule (32 CFR part 170) went into effect on December 16, 2024 and CMMC requirements are appearing in contracts. NIST 800-171 includes 110 controls which are organized into 14 families. DIBs that do not handle CUI, need to meet the basic 17 of these controls to protect federal Contract Information (FCI) at level 1. DIBs that do handle CUI need to meet all 110 controls at CMMC level 2 and depending on the type of information handled, may require an annual self-assessment or a triennial assessment by a C3PAO (CMMC Third Party Assessment Organization). CMMC level 3 assessment, intended for organizations with higher risk related to national security and critical infrastructure, includes additional controls beyond the 110 and will be done by government officials after the organization has received a level 2 C3PAO assessment. To be prepared for the assessment, a comprehensive and detailed System Security Plan (SSP) must be prepared identifying how each objective is implemented, and a Plan of Actions and Milestones (POA&M) for deficiencies must be developed. Non-compliance with NIST 800-171 can result in loss of government contracts or legal actions.
Recommendations
To properly test a system against these controls and meet the requirements, organizations need to adhere to all the specific objectives for each control and not just the control descriptions. The extensive number of objectives and limited resources can make the process challenging for small to medium size businesses. An organization trained to interpret the rules in a variety of environments and conditions can accelerate and streamline your path to compliance. Contact Digital Beachhead to start a conversation.
