Unauthorized access and disclosure of government information has become all too common in these times of frequent cyber-attacks. As a result, the government has extended mandatory safeguards - found in NIST SP 800-171 - to non-federal organizations that process, store or transmit Controlled Unclassified Information (CUI) or Covered Defense Information in non-federal information systems.
These non-federal organizations may include prime contractors, subcontractors, suppliers, distributors, and other service providers. Additionally, CUI is often provided to, or shared with, state and local governments, colleges and universities, and independent research organizations.
If you are interested in learning more about NIST SP 800-171 and DFARS 252.204-7012 requirements, look no further! We will be covering the following in this article:
What Does NIST SP 800-171 Compliance Require?
To comply with CUI safeguarding requirements, government contractors and other organizations processing CUI must fully understand what information they store, process, or transmit in the course of doing business with the federal government.
Defense industrial base contractors and suppliers must be prepared to provide adequate documentation describing their technical solutions, policies, and evidence of being able to detect and respond to incidents. safeguards, as defined by National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations, which currently includes fourteen families of security requirements and a total of 109 individual controls.
The CUI requirements within NIST SP 800-171 are directly related to the baseline controls described in NIST SP 800-53, Security and Privacy Controls for Federal Information Systems and Organizations, and are intended for use by federal agencies in contracts or other agreements established between those agencies and non-federal organizations.
TestPros provides a full range of NIST Compliance Services to help you establish the necessary controls, and build the documentation the Government requires.
When will NIST 800-171 Compliance Be Required?
If you are a contractor providing services to the U.S. federal government, your organization is responsible for protecting CUI. For Department of Defense contractors, DFARS 252.204-7012 & 252.204-7008 require that you implement the safeguards defined by NIST SP 800-171 over these materials by December 31, 2017. Prior to the deadline, DoD contractors must report any NIST SP 800-171 requirements not implemented, within 30 days of contract award.
While no equivalent FAR regulations are currently in place that map to the DFAR requirements, there are Executive Orders that mandate compliance for all government agencies.
CUI requirements are based on Executive Order (EO) 13556 of November 4, 2010 as well as 32 CFR Part 2002, Controlled Unclassified Information (CUI) in effect November 14, 2017, and supported by “CUI Notice 2016-01: Implementation Guidance for the CUI Program,” which was issued by NARA September 14, 2016 (“Day-0”).
Per that guidance, agencies must be at an Initial Operating Capability (IOC) one year after Day-0 to be compliant, and be at Full Operating Capability (FOC) three years after Day-0 (September 14, 2019) to be compliant. It is only a matter of time before non-DoD agencies pass along the same CUI handling requirements to their contractors.
Regardless of the legal or statutory requirement, it makes good business sense to implement the security steps defined by NIST SP 800-171!
Approach to NIST SP 800-171 / DFARS Compliance
TestPros provides independent assessment and advisory consultation services to meet your NIST SP 800-171 Compliance needs, addressing the current 14 families of security requirements and total of 109 controls.
As illustrated in the figure above, our Assessment Services include audits and compliance assessments against the NIST 800-171 standard, after which we advise on security program enhancements and control implementation where gaps are identified.
Our approach is pragmatic – where possible, we identify ways to reduce the scope of our client’s effort. For example, in lieu of hardening client-hosted servers and networks, it is often more expeditious and cost effective to isolate CUI data on FedRAMP-certified, cloud-based servers.
NIST 800-171 / DFARS Assessment Services
For each of the NIST 800-171 control objectives, TestPros delivers the following audit / assessment services and documentation:
- Identify applicable compliance guidance
- Determine if Group Policies (Active Directory or other LDAP), other Policies and Standards, Documented Processes and SOPs are in place
- Identify related technology considerations
- Document compliance status
- Justify any deviation from standard (pre-implementation only)
- Note any clarifying information, for example, reference to duplicate controls
NIST 800-171 / DFARS Advisory/Remediation Services
Once we have helped our client identify their requirements, TestPros is available to help you create NIST 800-171 required documentation sets, including a System Security Plan (SSP) that documents how you protect and ensure control of CUI and any additional guidance based on client or agency requirements.
We develop supporting compliance programs, including cost-effective alternative approaches, to implement and maintain (continuous monitoring) the required controls for transmitting or storing this data in non-federal information systems. We work from either existing client or TestPros-provided templates to accelerate the process.
How can TestPros help?
TestPros understands that NIST 800-171 compliance is based on the premise that Software, Hardware and Document accessibility is part of each IT requirement and should be addressed up front as part of the system development life cycle.
TestPros offers NIST 800-171 gap analysis, compliance support, program support, and training services to assist your organization safeguard it's networks and become compliant!