NIST Compliance

NIST SP 800-171 Compliance for Federal Contractors

Implement the 110 security requirements that protect Controlled Unclassified Information and form the foundation of CMMC Level 2 certification.

What Is NIST SP 800-171?

NIST Special Publication 800-171, "Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations," defines 110 security requirements organized across 14 families. Published by the National Institute of Standards and Technology, this standard is the cornerstone of federal contractor cybersecurity compliance.

For DoD contractors, NIST SP 800-171 compliance is mandated by DFARS 252.204-7012. This clause requires any contractor or subcontractor that handles Controlled Unclassified Information (CUI) to implement adequate security controls as defined in NIST SP 800-171. The requirement has been in effect since December 31, 2017.

Under the CMMC 2.0 framework, NIST SP 800-171 compliance is equivalent to CMMC Level 2. The 110 practices in Level 2 map one-to-one with the 110 requirements in NIST SP 800-171 Rev 2.

Who Must Comply with NIST SP 800-171?

NIST SP 800-171 compliance is required for any organization that processes, stores, or transmits CUI on behalf of the federal government. This includes:

  • DoD prime contractors with contracts containing DFARS 252.204-7012
  • Subcontractors at all tiers who receive or generate CUI as part of contract performance
  • Cloud service providers hosting CUI for federal contractors (must also meet FedRAMP Moderate equivalency)
  • Managed service providers and IT vendors with access to contractor systems that process CUI
  • Non-DoD federal contractors subject to FAR 52.204-21 and agency-specific CUI requirements

In the Raleigh-Durham Research Triangle area, this encompasses a wide range of organizations -- from large defense primes in RTP to small engineering firms and IT service providers supporting military installations like Fort Liberty.

The 14 NIST SP 800-171 Security Families

3.1 Access Control

22 requirements for limiting system access

3.2 Awareness & Training

3 requirements for security education

3.3 Audit & Accountability

9 requirements for audit trails

3.4 Configuration Management

9 requirements for system baselines

3.5 Identification & Authentication

11 requirements for identity verification

3.6 Incident Response

3 requirements for incident handling

3.7 Maintenance

6 requirements for system upkeep

3.8 Media Protection

9 requirements for media controls

3.9 Personnel Security

2 requirements for personnel screening

3.10 Physical Protection

6 requirements for physical access

3.11 Risk Assessment

3 requirements for risk identification

3.12 Security Assessment

4 requirements for security evaluation

3.13 System & Comm. Protection

16 requirements for data in transit

3.14 System & Info. Integrity

7 requirements for system monitoring

DFARS Interim Rule and SPRS

The DFARS Interim Rule, effective November 30, 2020, introduced two additional clauses that strengthened NIST SP 800-171 enforcement:

  • DFARS 252.204-7019 requires contractors to conduct a NIST SP 800-171 self-assessment using the DoD Assessment Methodology and achieve a score between -203 and 110.
  • DFARS 252.204-7020 requires contractors to submit their assessment results to the Supplier Performance Risk System (SPRS) and allow the DoD to conduct higher-level assessments (Medium or High confidence).

SPRS Scoring: A score of 110 means all 110 requirements are fully implemented. Each unimplemented requirement reduces the score by 1, 3, or 5 points depending on its weighted value. A score of -203 indicates no requirements are implemented. All contractors handling CUI must have a current SPRS score to be eligible for contract awards.

Common NIST SP 800-171 Compliance Gaps

Based on our experience working with defense contractors in the Triangle area, the most common compliance gaps include:

  • Multi-Factor Authentication (3.5.3): Not implemented for all remote and privileged access sessions
  • Audit Log Review (3.3.1, 3.3.2): Logs are collected but not regularly reviewed or correlated
  • FIPS-Validated Encryption (3.13.11): Using non-FIPS encryption for CUI at rest and in transit
  • Incident Response Plan (3.6.1): No documented and tested incident response procedures
  • Security Awareness Training (3.2.1, 3.2.2): Training not conducted or not documented
  • System Security Plan (3.12.4): SSP is incomplete, outdated, or does not accurately describe the system boundary
  • Risk Assessment (3.11.1): No periodic risk assessments conducted and documented
  • Configuration Baselines (3.4.1, 3.4.2): No documented baseline configurations for systems processing CUI

How PTG Helps with NIST Compliance

Petronella Technology Group is a CMMC Registered Practitioner Organization (RPO) with extensive experience implementing NIST SP 800-171 for defense contractors. Our approach includes:

  • Comprehensive Gap Analysis: Detailed assessment of your current implementation status across all 110 requirements, resulting in an accurate SPRS score and prioritized remediation plan
  • System Security Plan (SSP): Development of a thorough SSP documenting your system boundary, CUI data flows, interconnections, and security control implementation details
  • Technical Control Implementation: Deployment and configuration of security tools including SIEM, endpoint detection and response, multi-factor authentication, FIPS-validated encryption, and access controls
  • Policy Development: Creation of security policies and procedures aligned with all 14 requirement families
  • POA&M Management: Development and tracking of Plans of Action and Milestones for requirements that cannot be immediately implemented
  • Continuous Monitoring: Ongoing security monitoring and compliance maintenance to ensure sustained NIST SP 800-171 implementation

NIST Compliance FAQ

What is the relationship between NIST SP 800-171 and CMMC?

CMMC Level 2 is directly aligned with NIST SP 800-171 Rev 2. The 110 CMMC Level 2 practices correspond one-to-one with the 110 NIST SP 800-171 requirements. CMMC adds the assessment and certification framework to what was previously a self-assessed standard.

What is the difference between NIST SP 800-171 and NIST SP 800-53?

NIST SP 800-53 is a comprehensive catalog of security controls designed primarily for federal information systems. NIST SP 800-171 is a subset of those controls tailored for nonfederal organizations that handle CUI. The 110 requirements in 800-171 are derived from the broader 800-53 control set.

How often must I update my SPRS score?

Your SPRS score should be updated whenever there are significant changes to your security posture, such as implementing new controls or identifying new deficiencies. The DoD Assessment Methodology does not specify a fixed update frequency, but maintaining an accurate score is required for contract eligibility.

What is NIST SP 800-171 Rev 3?

NIST published Revision 3 of SP 800-171 in May 2024. However, CMMC 2.0 is currently aligned with Revision 2. The DoD has not yet updated CMMC requirements to reference Rev 3, so contractors should continue implementing Rev 2 requirements for CMMC purposes.

Do I need to be compliant with every requirement?

Ideally, yes. Full implementation of all 110 requirements yields the maximum SPRS score of 110. However, requirements that are not yet implemented can be documented in a Plan of Action and Milestones (POA&M) with specific timelines for completion. Under CMMC 2.0, POA&M items must be closed within 180 days.

What is CUI and how do I identify it?

Controlled Unclassified Information is information that requires safeguarding per law, regulation, or government policy but is not classified. CUI categories are defined in the CUI Registry maintained by the National Archives. In defense contracts, CUI is typically identified through contract markings, DD Form 254, or explicit communication from the contracting officer.

Can PTG help with both NIST 800-171 and NIST 800-53?

Yes. PTG has experience implementing both NIST SP 800-171 for defense contractors handling CUI and NIST SP 800-53 for organizations requiring the full federal security control framework, such as those processing classified information or supporting federal agencies directly.

How long does NIST SP 800-171 implementation take?

Timeline depends on your current security posture. Organizations with minimal existing controls typically need 12 to 18 months. Those with partial implementations may achieve full compliance in 6 to 12 months. PTG begins every engagement with a gap analysis to establish a realistic timeline.

Achieve NIST SP 800-171 Compliance

Our CMMC Registered Practitioners will assess your current implementation and build a clear path to full compliance.

Schedule a Free Assessment Call us: 919-348-4912

5540 Centerview Dr., Suite 200, Raleigh, NC 27606

Why Choose Petronella Technology Group

Petronella Technology Group has been a trusted IT and cybersecurity partner for businesses across Raleigh, Durham, Chapel Hill, Cary, Apex, and the Research Triangle since 2002. Led by CEO Craig Petronella, an NC Licensed Digital Forensics Examiner (License# 604180-DFE), CMMC Certified Registered Practitioner, Cybersecurity Expert Witness, Hyperledger Certified, and MIT-certified professional in cybersecurity, AI, blockchain, and compliance, PTG brings deep expertise to every engagement.

With BBB accreditation since 2003 and more than 2,500 businesses served, PTG has the experience and track record to deliver results. Craig Petronella is an Amazon number-one best-selling author of books including "How HIPAA Can Crush Your Medical Practice," "How Hackers Can Crush Your Law Firm," and "The Ultimate Guide To CMMC." He has been featured on ABC, CBS, NBC, FOX, and WRAL, and serves as an expert witness for law firms in cybercrime and compliance cases.

PTG holds certifications including CCNA, MCNS, Microsoft Cloud Essentials, and specializes in CMMC 2.0, NIST 800-171/172/173, HIPAA, FTC Safeguards, SOC 2 Type II, PCI DSS, GDPR, CCPA, and ISO 27001 compliance. Our forensic specialties include endpoint and networking cybercrime investigation, data breach forensics, ransomware analysis, data exfiltration investigation, cryptocurrency and blockchain analysis, and SIM swap fraud investigation.

Frequently Asked Questions

What compliance frameworks does PTG help businesses implement?
PTG helps businesses implement and maintain compliance with a wide range of frameworks including CMMC 2.0, NIST 800-171 and 800-172, HIPAA, FTC Safeguards Rule, SOC 2 Type II, PCI DSS, GDPR, CCPA, and ISO 27001. Our compliance consultants work with organizations in Raleigh, Durham, and the Research Triangle to assess current gaps, develop remediation roadmaps, implement required controls, create policy documentation, and prepare for third-party audits or assessments. We take a unified approach that addresses multiple frameworks simultaneously to reduce duplication of effort.
How long does it take to achieve compliance certification?
The timeline varies significantly depending on the framework, organization size, and current security maturity. HIPAA compliance can often be achieved in three to six months with dedicated effort. CMMC Level 2 certification typically requires six to twelve months of preparation. SOC 2 Type II requires a minimum audit observation period of six months. ISO 27001 implementation generally takes six to twelve months. PTG helps organizations develop realistic timelines and prioritize the most critical controls to achieve compliance as efficiently as possible while building a sustainable long-term security program.
What happens if a business fails a compliance audit?
Failing a compliance audit can result in financial penalties, loss of business contracts, reputational damage, and in some cases, legal liability. HIPAA violations can result in fines ranging from one hundred dollars to fifty thousand dollars per violation, up to one and a half million dollars annually per violation category. CMMC non-compliance means losing eligibility for Department of Defense contracts. PCI DSS non-compliance can result in increased transaction fees and loss of payment processing capabilities. PTG helps businesses avoid these consequences through thorough pre-audit preparation, gap assessments, and continuous compliance monitoring.
What is the difference between SOC 2 Type I and Type II?
SOC 2 Type I evaluates the design of your security controls at a specific point in time, providing a snapshot of your security posture. SOC 2 Type II evaluates both the design and operating effectiveness of your controls over a period of time, typically six to twelve months. Type II is considered more rigorous and valuable because it demonstrates that your controls consistently work as intended over an extended period. Most enterprise clients and partners require SOC 2 Type II reports when evaluating vendors. PTG helps organizations prepare for and maintain both types of SOC 2 compliance.
Can one compliance framework satisfy multiple regulatory requirements?
Yes, many compliance frameworks share overlapping controls and requirements. Implementing NIST 800-171 provides a strong foundation for CMMC 2.0 compliance. ISO 27001 maps to many SOC 2 and HIPAA requirements. The NIST Cybersecurity Framework aligns with virtually all other frameworks. PTG takes a unified compliance approach, helping organizations implement controls that satisfy multiple frameworks simultaneously. This integrated strategy reduces duplication of effort, lowers costs, and creates a more cohesive security program that addresses all applicable regulatory requirements without redundant processes or documentation.

The PTG Compliance Process

Achieving and maintaining regulatory compliance requires a structured, repeatable process. PTG has developed a proven compliance methodology refined over more than two decades of helping businesses navigate complex regulatory requirements. Our process begins with a comprehensive gap assessment that evaluates your current policies, procedures, and technical controls against the specific requirements of your target framework. This assessment identifies exactly where your organization stands and what needs to be done to achieve compliance.

Following the gap assessment, PTG develops a prioritized remediation roadmap that outlines every action item needed to close identified gaps. We categorize items by risk level and effort required, allowing organizations to address the most critical deficiencies first while planning for longer-term improvements. Our consultants work alongside your team to implement technical controls, develop required policies and procedures, create employee training programs, and establish the documentation and evidence collection processes needed to demonstrate compliance during audits and assessments.

Compliance is not a one-time project but an ongoing commitment. Regulations evolve, threats change, and business environments shift. PTG provides continuous compliance monitoring services that track your compliance status in real time, alert you to emerging gaps, and ensure that your security controls remain effective. We conduct regular internal audits, update policies as regulations change, and prepare your organization for external audits or assessments. Our goal is to make compliance a natural part of your business operations rather than a periodic scramble to meet audit deadlines.

For organizations subject to multiple compliance frameworks, PTG takes a unified approach that maps overlapping requirements across frameworks. Rather than implementing separate programs for each regulation, we build a comprehensive security and compliance program that satisfies multiple requirements simultaneously. This integrated approach reduces costs, eliminates redundant processes, and provides a clearer picture of your overall security and compliance posture, making it easier to manage ongoing obligations and demonstrate compliance to auditors, clients, and business partners.

Ready to Get Started?

Contact Petronella Technology Group today for a free consultation. Serving Raleigh, Durham, Chapel Hill, and the Research Triangle since 2002.

919-348-4912 Schedule a Free Consultation

5540 Centerview Dr., Suite 200, Raleigh, NC 27606