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Defense Federal Acquisition Regulation Supplement (DFARS) and NIST 800-171 800-172
Continuum GRC is completely committed to you and your business’ Defense Federal Acquisition Regulation Supplement (DFARS) and NIST 800-171 & 800-172 audit success. Regardless of whether you represent the private sector or the public sector, we stand ready to partner with your organizations.
Modules include:
- DFARS NIST 800-171 System Security Plan (SSP)
- DFARS NIST 800-171 Security Assessment Report (SAR)
- DFARS NIST 800-172 System Security Plan (SSP)
- DFARS NIST 800-172 Security Assessment Report (SAR)
- Federal Information Processing Standard (FIPS) 199 Categorization
- Plan of Action and Milestones (POA&M)
The NIST Compliance Audit Process
NIST compliance involves protecting controlled unclassified information within a cybersecurity environment. The audit looks at the specific systems, processes, and kinds of data the organization is involved with, and whether its framework is maintaining compliance with those precise security regulations and guidelines.
This all begins with a review of the current security practices as well as risk assessment and analysis. Security controls around your networks, like access control and incident response measures, are evaluated. All of this is gathered as evidence and thoroughly documented.
Recommendations are then made for improvements or remediation to achieve NIST 800 171 compliance.
Benefits of Being NIST Compliant
Compliance offers a clear, structured approach to managing your cybersecurity and related threats in a much more efficient manner. Your cybersecurity posture is greatly strengthened, and you’ll have a much more proactive way to prevent potential threats (and recover if they happen).
Achieving this level of regulatory compliance aligns you with the security needs of various organizations around HIPAA and FISMA, opening new opportunities and providing a competitive advantage. You and your staff will have a better way to communicate clearly around these important cybersecurity measures, build trust with your clients, and manage risks more effectively.
Audit and Accountability
Undergoing a NIST audit provides a comprehensive look at the elements surrounding your cybersecurity posture. It reviews systems and processes for communications protection, beginning with a thorough risk assessment solution. How are you set up to monitor potential threats? What are the procedures to address them? What’s the plan to recover from a data breach, and who’s in charge? Who has access to this most sensitive data, and what is their authorization?
An audit to achieve compliance with NIST standards is meant to streamline your security process and ensure that it’s as up-to-date as possible to avoid (or recover from) cyber attacks.
Identification and Authentication
The process for becoming NIST 800-171 compliant offers an opportunity to clearly identify key systems, processes, and personnel as a way to better manage security. Everything from monitoring and reporting to how threats are identified and remediated is methodically documented. That kind of precise communication ensures a seamless process for handling and maintaining sensitive information. It prevents gaps in the organization’s operation and builds trust among all stakeholders.
Implementing the guidelines and standards to achieve NIST compliance makes handling complex cyberthreats much simpler and efficient. It improves your security posture with clearly identified roles and responsibilities.
FAQ
Who does NIST 800-171 apply to?
NIST SP 800-171 cybersecurity requirements apply to any contractors or non-federal organizations that handle Controlled Unclassified Information, or CUI. This means processing, storing, transmitting, or protecting this kind of information. This can include cloud providers who work with federal agencies or universities that receive grants or contracts that include CUI.
What is included in a DFARS/NIST compliance audit?
Defense Federal Acquisition Regulation Supplement (DFARS) applies the cybersecurity standards determined by NIST to any of the goods and services used by the Department of Defense. These products must be able to securely handle sensitive information. The audit review security controls and compliance standards in equipment, media, and the like.
How does DFARS relate to NIST 800-171?
DFARS and NIST are both related to cybersecurity around the handling of Controlled Unclassified Information (CUI). Both require contractors with the Department of Defense to utilize specific standards and practices; DFARS relates more to the acquisition of equipment and other physical products. Those must meet the security standards.
What is a Plan of Action and Milestones (POA&M)?
This document identifies any weaknesses and vulnerabilities in an organization’s security posture, and then prioritizes how each should be addressed and mitigated through specific steps. The milestones are part of this timeline, working through the most important security gaps first in a structured, methodical way.
How does CMMC relate to NIST 800-171 and DFARS?
Cybersecurity Maturity Model Certification (CMMC) is connected to NIST 800-171 and DFARS as a program that ensures that defense contractors comply with the specific security controls outlined by NIST and DFARS publications. It’s a set of unified standards that makes it clear what’s expected in cybersecurity protection.
What’s the difference between NIST 800-171 and 800-172?
Think of NIST 800-171 as the baseline cybersecurity requirements for protecting Controlled Unclassified Information (CUI) in non-federal systems. NIST 800-172 takes it up a notch, adding another layer of protection (like penetration-resistant architecture and cyber resiliency) to counter more advanced security threats against high-value assets or critical programs.
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About this standard
The Defense Federal Acquisition Regulation Supplement (DFARS) and NIST Special Publications 800-171 and 800-172 are critical frameworks for ensuring cybersecurity and compliance for organizations handling sensitive information in contracts with the U.S. Department of Defense (DoD). Below is a concise compliance overview of each, including its purpose, scope, and key requirements.
DFARS (Defense Federal Acquisition Regulation Supplement)
Purpose: DFARS is a set of regulations that supplements the Federal Acquisition Regulation (FAR) to address specific DoD procurement requirements. It includes cybersecurity clauses to protect Controlled Unclassified Information (CUI) and ensure the security of defense contractors' information systems.
Key Clause for Cybersecurity:
- DFARS 252.204-7012: "Safeguarding Covered Defense Information and Cyber Incident Reporting" mandates that contractors handling CUI implement cybersecurity measures aligned with NIST SP 800-171. It requires:
- Implementation of NIST 800-171 security controls to protect CUI.
- Rapid reporting of cyber incidents (within 72 hours) to the DoD.
- Preservation of system images and data for incident analysis.
- Flow-down of requirements to subcontractors handling CUI.
Scope:
- Applies to all DoD contractors and subcontractors that process, store, or transmit Covered Defense Information (CDI), including CUI, on non-federal systems.
- Enforced through contract clauses in DoD solicitations and contracts.
Compliance Requirements:
- Implement all 110 security controls from NIST SP 800-171 (or provide a System Security Plan (SSP) and Plan of Action and Milestones (POA&M) for gaps).
- Submit compliance status to the DoD’s Supplier Performance Risk System (SPRS).
- Ensure supply chain compliance by enforcing DFARS clauses on subcontractors.
- For certain contracts, compliance with the Cybersecurity Maturity Model Certification (CMMC) may also be required, which builds on DFARS and NIST 800-171.
Penalties for Non-Compliance:
- Loss of contracts, financial penalties, or legal repercussions.
- Potential exclusion from future DoD contracts.
NIST SP 800-171: Protecting Controlled Unclassified Information in Nonfederal Systems
Purpose: NIST SP 800-171 provides a standardized set of cybersecurity requirements to protect CUI in non-federal systems and organizations, particularly for DoD contractors under DFARS 252.204-7012.
Scope:
- Applies to non-federal organizations (e.g., contractors, universities, research institutions) that process or store CUI as part of federal contracts.
- Focuses on safeguarding CUI in information systems outside direct federal control.
Key Requirements:
- Consists of 110 security controls organized into 14 control families, including:
- Access Control: Limit system access to authorized users (e.g., multi-factor authentication).
- Awareness and Training: Train personnel on security policies and procedures.
- Incident Response: Establish processes to detect, report, and respond to security incidents.
- Media Protection: Securely handle and dispose of media containing CUI.
- System and Communications Protection: Implement encryption and secure communication protocols.
- Organizations must assess their systems against these controls, document compliance in an SSP, and address gaps through a POA&M.
- Regular monitoring and updates to maintain compliance.
Compliance Process:
- Conduct a gap analysis to identify deficiencies.
- Develop and implement an SSP to document how controls are met.
- Create a POA&M for any unimplemented controls with a timeline for remediation.
- Self-assess or engage third-party assessors (required for CMMC in some cases).
Relation to DFARS:
- DFARS 252.204-7012 mandates NIST 800-171 compliance for handling CUI.
- Compliance is a prerequisite for DoD contracts and may feed into CMMC assessments.
- NIST SP 800-172: Enhanced Security Requirements for Protecting CUI
Purpose: NIST SP 800-172 provides enhanced security requirements for protecting CUI in environments facing Advanced Persistent Threats (APTs). It builds on NIST 800-171 by adding more stringent controls for high-risk scenarios.
Scope:
- Applies to organizations handling CUI in critical programs or high-value assets where advanced cyber threats are a concern (e.g., DoD’s most sensitive programs).
- Typically required for contracts involving heightened security needs, as specified by the DoD.
Key Requirements:
- Includes 35 enhanced security controls across 10 control families, focusing on:
- Penetration Resistance: Implement advanced measures like red teaming to testទ- test system vulnerabilities.
- Zero Trust Architecture: Assume all users and devices are untrusted until verified.
- Advanced Threat Detection: Deploy proactive monitoring and response to sophisticated threats.
- Resilience: Enhance system recovery and continuity in the face of attacks.
- Controls are more rigorous and tailored to counter APTs, such as nation-state actors.
- Examples include advanced encryption, continuous monitoring, and supply chain risk management.
Compliance Process:
- Conduct a risk assessment to determine if 800-172 controls are necessary (often specified in contracts).
- Integrate enhanced controls into existing NIST 800-171 frameworks.
- Provide detailed documentation and evidence of compliance to the DoD or auditors.
Relation to DFARS and NIST 800-171:
- NIST 800-172 supplements NIST 800-171 for specific high-risk contracts.
- DFARS may require 800-172 compliance for critical systems or programs, in addition to 800-171.
Key Differences and Relationships
| Aspect | DFARS 252.204-7012 | NIST SP 800-171 | NIST SP 800-172 |
|---|---|---|---|
| Purpose | DoD contract clause for cybersecurity | Protects CUI in non-federal systems | Enhanced protection against APTs |
| Scope | DoD contractors handling CDI/CUI | Non-federal systems handling CUI | High-risk systems with CUI |
| Controls | References NIST 800-171; incident reporting | 110 controls in 14 families | 35 enhanced controls in 10 families |
| Compliance | SSP, POA&M, SPRS reporting | SSP, POA&M, self-assessment | Advanced risk assessment, documentation |
| Relation | Mandates NIST 800-171; may include 800-172 | Foundational cybersecurity standard | Supplemental for advanced threats |
| Penalties | Loss of contracts, penalties | Contract ineligibility | Stricter oversight, contract-specific |
Compliance Challenges
- Complexity: Implementing 110 controls (NIST 800-171) or additional enhanced controls (NIST 800-172) requires significant resources and expertise.
- Supply Chain: Ensuring subcontractors comply with DFARS and NIST standards is challenging.
- Evolving Requirements: Transition to CMMC (for NIST 800-171) and emerging threats may require ongoing updates.
- Cost: Small businesses may struggle with the cost of compliance, including assessments and remediation.
Practical Steps for Compliance
- Conduct a Gap Analysis: Assess current systems against NIST 800-171/800-172 controls.
- Develop an SSP: Document how each control is implemented or planned.
- Create a POA&M: Address gaps with a clear remediation plan.
- Engage Experts: Use cybersecurity consultants or Certified Third-Party Assessment Organizations (C3PAOs) for audits.
- Monitor and Update: Regularly review and update security practices to maintain compliance.
- Train Staff: Ensure employees understand security policies and procedures.
- Report to SPRS: Submit NIST 800-171 compliance scores to the DoD’s SPRS for DFARS compliance.
Additional Notes
- CMMC Integration: The DoD’s Cybersecurity Maturity Model Certification (CMMC) builds on NIST 800-171, adding maturity levels and third-party assessments. CMMC 2.0 aligns closely with NIST 800-171 for most contractors.
- Resources: Refer to NIST’s official guidelines (csrc.nist.gov) and DoD’s cybersecurity resources (www.acq.osd.mil) for detailed control lists and templates.