Watch

NIST, DFARS and the new CMMC 2.0

Defense Compliance

NIST and DFARS Compliance

Achieve NIST SP 800-171 and DFARS 252.204-7012 compliance to protect Controlled Unclassified Information and maintain your DoD contract eligibility.

Understanding NIST and DFARS Together

NIST SP 800-171 and DFARS 252.204-7012 work together as the foundation of cybersecurity compliance for defense contractors. DFARS is the contractual clause that mandates compliance; NIST SP 800-171 provides the 110 specific security requirements that must be implemented.

Since December 31, 2017, every DoD contractor and subcontractor handling Controlled Unclassified Information (CUI) has been required to implement NIST SP 800-171 under DFARS 252.204-7012. Since November 2020, the DFARS Interim Rule (clauses 7019 and 7020) requires contractors to self-assess, score their implementation, and submit results to the Supplier Performance Risk System (SPRS).

With CMMC 2.0 now being phased into contracts, NIST and DFARS compliance is more critical than ever. CMMC Level 2 maps directly to NIST SP 800-171, meaning your NIST implementation is the foundation of your CMMC certification.

What DFARS Requires

  • Implement NIST SP 800-171: Deploy all 110 security requirements across 14 families to protect CUI in your information systems
  • 72-Hour Incident Reporting: Report cyber incidents to the DoD Cyber Crime Center (DC3) within 72 hours of discovery via the DIBNet portal
  • System Preservation: Preserve images of affected systems and monitoring data for at least 90 days after an incident
  • Self-Assessment and SPRS: Conduct a NIST SP 800-171 DoD Assessment and submit your score (-203 to 110) to SPRS
  • Flow-Down: Include DFARS 252.204-7012 in subcontracts where the subcontractor will handle CUI

The 110 NIST SP 800-171 Requirements

NIST SP 800-171 organizes its 110 security requirements into 14 families:

  • Access Control (22 requirements): Limit system access, enforce least privilege, control remote access, and manage wireless access
  • Awareness and Training (3): Provide security awareness training to all users and specialized training to those with security responsibilities
  • Audit and Accountability (9): Create, retain, and protect audit records; review and report audit findings
  • Configuration Management (9): Establish baselines, track and control changes, enforce security settings, and manage software use
  • Identification and Authentication (11): Identify and authenticate users and devices; implement multi-factor authentication
  • Incident Response (3): Establish incident handling procedures, track and report incidents, and test response capabilities
  • Maintenance (6): Perform and control system maintenance, manage maintenance tools, and supervise remote maintenance
  • Media Protection (9): Protect, sanitize, and control media containing CUI
  • Personnel Security (2): Screen personnel and protect CUI during personnel actions
  • Physical Protection (6): Limit physical access, protect and monitor facilities
  • Risk Assessment (3): Assess risk, scan for vulnerabilities, and remediate findings
  • Security Assessment (4): Assess controls, monitor continuously, and develop corrective action plans
  • System and Communications Protection (16): Monitor and protect communications, implement encryption, and establish system boundaries
  • System and Information Integrity (7): Identify and correct system flaws, protect against malicious code, and monitor security alerts

SPRS Score: What You Need to Know

Your SPRS score is your compliance scorecard. Calculated using the DoD Assessment Methodology, it ranges from -203 (no controls implemented) to 110 (full implementation). Each unimplemented requirement reduces your score by 1, 3, or 5 points depending on the control's weighted value. Contracting officers use SPRS scores in source selection decisions.

PTG helps you conduct an accurate assessment, develop realistic Plans of Action and Milestones (POA&Ms) for unimplemented controls, and systematically close gaps to raise your score toward 110.

How PTG Helps

As a CMMC Registered Practitioner Organization (RPO) headquartered in Raleigh, NC, PTG provides comprehensive NIST and DFARS compliance services to defense contractors throughout the Research Triangle:

  • Gap Analysis: Detailed assessment against all 110 NIST SP 800-171 requirements with accurate SPRS scoring
  • SSP Development: System Security Plan creation documenting your system boundary, CUI flows, and control implementations
  • Technical Implementation: Deployment of MFA, encryption, SIEM, endpoint protection, access controls, and other technical safeguards
  • Policy and Procedure Development: Creation of security policies aligned with all 14 requirement families
  • Incident Response Planning: Development of 72-hour incident reporting procedures per DFARS 252.204-7012
  • CMMC Preparation: Your NIST/DFARS compliance directly prepares you for CMMC Level 2 certification

NIST and DFARS FAQ

Is NIST SP 800-171 compliance the same as CMMC Level 2?

CMMC Level 2 maps one-to-one with NIST SP 800-171 Rev 2's 110 requirements. The key difference is that CMMC adds third-party assessment verification. If you are fully NIST 800-171 compliant, you have the technical foundation for CMMC Level 2.

What is the DFARS 72-hour reporting requirement?

Under DFARS 252.204-7012, contractors must report cyber incidents affecting covered contractor information systems or CUI to DC3 within 72 hours of discovery. Reports are submitted through the DIBNet portal.

What is a System Security Plan?

An SSP documents how your organization implements each of the 110 NIST SP 800-171 requirements. It describes your system boundary, CUI data flows, network architecture, and the specific methods used to satisfy each requirement. It is a required document under both DFARS and CMMC.

What are POA&Ms?

Plans of Action and Milestones document security requirements not yet fully implemented, along with specific timelines and milestones for completion. Under CMMC 2.0, POA&M items must be closed within 180 days of conditional certification.

Do subcontractors need to comply?

Yes. DFARS 252.204-7012 must be flowed down to subcontractors who handle CUI. Subcontractors have the same implementation and incident reporting obligations as prime contractors.

What is the False Claims Act risk?

Claiming DFARS/NIST compliance without actually implementing required controls can result in False Claims Act liability, including treble damages and per-claim penalties. Several enforcement actions have specifically targeted inaccurate cybersecurity self-assessments.

How long does compliance take?

Organizations starting from scratch typically need 12 to 18 months. Those with partial implementations may need 6 to 12 months. PTG tailors the timeline to your current posture and contract deadlines.

Does PTG serve contractors outside the Triangle?

While headquartered in Raleigh, PTG serves defense contractors throughout North Carolina and across the eastern United States through both in-person and remote engagement models.

Achieve NIST and DFARS Compliance

Protect your DoD contracts with expert compliance services from PTG's CMMC Registered Practitioners.

Schedule a Free Consultation 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, a Licensed Digital Forensic Examiner, CMMC Certified Registered Practitioner, 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

Related Compliance Frameworks

NIST and DFARS compliance requirements are evolving toward CMMC, with connections to broader security frameworks.