As cybersecurity continues to grow in importance, organizations working with the U.S. Department of Defense (DoD) must comply with specific cybersecurity frameworks. Two of the most significant standards in this space are the Cybersecurity Maturity Model Certification (CMMC) and the National Institute of Standards and Technology (NIST) Special Publication 800-171. While both are critical to securing sensitive data, there are key differences between CMMC and NIST that organizations must understand to achieve compliance.
This blog will provide an overview of the differences between CMMC and NIST, focusing on their unique structures, requirements, and how they impact contractors working with the federal government.
Understanding the Basics of CMMC
CMMC is a comprehensive framework developed by the DoD to ensure that all contractors and subcontractors working with the department implement proper cybersecurity measures. Unlike NIST, which has traditionally relied on self-attestation, CMMC introduces a formal certification process requiring third-party assessments to validate compliance.
The CMMC framework consists of multiple levels, known as CMMC levels, which represent increasing levels of cybersecurity maturity. Each level builds upon the one before it, with higher levels requiring more advanced security controls.
CMMC 2.0, the most recent version of the framework, reduced the number of levels from five to three:
- Level 1 (Foundational): Basic cyber hygiene, focused on protecting Federal Contract Information (FCI).
- Level 2 (Advanced): Aligned with NIST SP 800-171, focusing on protecting Controlled Unclassified Information (CUI).
- Level 3 (Expert): The highest level, focused on advanced protection against threats targeting critical national security information.
One of the major differences between CMMC and NIST is the need for third-party certification. CMMC requires organizations to undergo a formal CMMC assessment by an accredited third-party assessor to achieve compliance. This ensures that contractors are meeting the necessary cybersecurity maturity model certification requirements based on the sensitivity of the information they handle.
Overview of NIST SP 800-171
NIST SP 800-171 is a set of cybersecurity standards created by the National Institute of Standards and Technology (NIST). It is primarily aimed at organizations that handle Controlled Unclassified Information (CUI) and provides guidelines for protecting this data from unauthorized access and disclosure.
Unlike CMMC, which includes multiple levels of maturity, NIST SP 800-171 is a single set of 110 security requirements grouped into 14 categories, including:
- Access Control
- Awareness and Training
- Configuration Management
- Incident Response
- Risk Assessment
- System and Information Integrity
These controls help organizations safeguard CUI, ensuring that sensitive data is handled securely. NIST SP 800-171 does not require a formal certification process, relying instead on self-attestation. Contractors working with the DoD are expected to implement the necessary security controls and report their compliance status, though there is no mandatory third-party validation as required by CMMC.
Key Differences Between CMMC and NIST
Although both CMMC and NIST SP 800-171 share the goal of improving cybersecurity for defense contractors, there are several key differences between the two frameworks. These differences have implications for how organizations approach cybersecurity and achieve compliance.
Certification vs. Self-Attestation
One of the most notable differences between CMMC and NIST is the approach to certification. NIST SP 800-171 relies on self-assessment, meaning that contractors are responsible for reviewing their own security practices and attesting to their compliance. There is no mandatory third-party evaluation.
In contrast, CMMC compliance requires organizations to undergo a formal assessment conducted by an accredited third-party assessor. This ensures a more rigorous validation of an organization’s security practices. For contractors handling more sensitive information, this formal CMMC assessment is a critical step in securing DoD contracts.
Multiple Levels of Security Maturity
Another significant difference lies in the structure of the two frameworks. NIST SP 800-171 is a single set of 110 controls, providing a uniform standard for protecting CUI. There are no varying levels of maturity or security, and all organizations handling CUI are expected to meet the same requirements.
CMMC, on the other hand, introduces a tiered model with multiple CMMC levels. These levels range from basic cyber hygiene at Level 1 to advanced protection at Level 3. This tiered structure allows for greater flexibility, as organizations can achieve the level of cybersecurity maturity that aligns with the sensitivity of the data they handle.
Focus on Protecting FCI and CUI
NIST SP 800-171 is solely focused on protecting CUI, which is unclassified information that requires protection due to its sensitivity. All 110 controls within NIST SP 800-171 are designed to safeguard this specific type of data.
CMMC addresses both FCI and CUI. FCI, or Federal Contract Information, is any information generated or provided under a contract with the government that is not intended for public release. CMMC Level 1 specifically addresses the protection of FCI, while CMMC Level 2 and Level 3 focus on CUI.
This distinction makes CMMC a more comprehensive framework for defense contractors, as it covers a broader range of sensitive information.
Compliance and Enforcement
NIST SP 800-171 has historically relied on trust-based compliance, with contractors expected to self-report their adherence to the guidelines. However, enforcement has been inconsistent, leading to gaps in security across the defense industrial base.
CMMC was created to address this gap by introducing a formal certification process that is enforced by the DoD. Contractors are required to achieve CMMC certification based on the level appropriate for the data they handle. Without this certification, organizations will be ineligible to bid on or maintain DoD contracts.
This shift from self-attestation to mandatory certification adds greater accountability and ensures that contractors are meeting the cybersecurity maturity model certification standards required for their work with the government.
Role of a CMMC Consultant
Given the complexity of CMMC, many organizations choose to engage a CMMC consultant to help them achieve compliance. A CMMC consultant provides expert guidance on CMMC requirements, helping businesses identify gaps in their cybersecurity practices and implement the necessary controls to meet the desired CMMC level.
While organizations may also seek consultants for help with NIST SP 800-171, the mandatory third-party certification aspect of CMMC increases the need for professional assistance. A CMMC consultant ensures that all aspects of the cybersecurity maturity model certification are addressed, from initial preparation to the formal assessment process.
Importance of CMMC 2.0 in the Defense Industry
The introduction of CMMC 2.0 marks an important evolution in the DoD’s approach to cybersecurity. While NIST SP 800-171 remains a foundational standard, CMMC 2.0 builds on this by requiring third-party assessments and providing a more structured, multi-level framework for compliance.
CMMC 2.0 allows for greater flexibility in certification, reducing the burden for small and medium-sized businesses while still ensuring that the necessary protections are in place. By creating multiple CMMC levels and offering a more streamlined certification process, CMMC 2.0 makes it easier for contractors to achieve compliance while maintaining a high standard of security.
Final Thoughts on CMMC and NIST
While both CMMC and NIST SP 800-171 play vital roles in securing the defense supply chain, their differences in structure, certification, and focus are important for contractors to understand. Organizations working with the DoD must carefully assess their cybersecurity needs and determine which framework applies to their operations.
