NIST SP 800-171

Contracting with the Department of Defense and other government agencies can be very lucrative for companies in electronics and other industries. However, securing and maintaining these contracts requires strict compliance with cybersecurity regulations, including the Federal Acquisition Regulation (FAR) and the Defense Federal Acquisition Regulation Supplement (DFARS). A key component of these requirements is adherence to NIST Special Publication (SP) 800-0171, which outlines cybersecurity measures for handling Controlled Unclassified Information (CUI). This post explores NIST SP 800-171, its background, purpose, which businesses it affects, the risks and penalties for failing to comply, and more.

To understand the NIST SP 800-171 DoD assessment, it’s worth exploring some background and its purpose. However, let’s begin with a general explanation. NIST SP 800-171 is a set of cybersecurity guidelines developed by the National Institute of Standards and Technology (NIST) to protect CUI in non-federal or federally regulated systems and organizations. These guidelines are essential for government contractors, subcontractors, and any other entity that handles sensitive information that is not classified as government data, such as technical drawings and blueprints for defense-related components. 

This NIST framework was created to establish a standardized approach for safeguarding data that, if compromised, could be valuable to US adversaries. It defines 14 security ‘families,’ covering access control, incident response, system integrity, and other critical areas. Families refer to the range of controls relating to their specific area. For example, the ‘Access Control’ family contains security and privacy controls relating to device and user access to the system.

The NIST SP 800-171 requirements arose in response to cybersecurity, which the US government has increasingly recognized as a national security risk, particularly in the defense industrial base (DIB). Before the NIST SP 800-171 standards existed, security requirements for contractors were inconsistent, leading to vulnerabilities in the supply chain. To address this gap, the Cybersecurity Enhancement Act of 2014 directed NIST to develop a framework for standards that ensures uniform cybersecurity practices for non-federal entities handling CUI, including contractors for the Department of Defense, universities and research institutions that receive federal grants, organizations providing services to government agencies, etc.

The purpose of NIST SP 800-171 requirements is to protect sensitive government data from cyber threats, such as espionage and data breaches; ensure contractors maintain strong security practices to prevent unauthorized access to CUI; and standardize cybersecurity expectations across industries working with government agencies.

Any company or entity that processes, stores, or transmits CUI as part of a government contract is required to comply with the standards outlined within the NIST SP 800-171 framework. Therefore, compliance is not a recommendation; it’s a legal and contractual obligation under the Defense Federal Acquisition Regulation Supplements (DFARS) 252.204-7012. It is required for contract eligibility, and not complying has legal implications.

Industries and organizations involved in government contracts, defense, or critical infrastructure must comply with NIST SP 800-171 requirements. This includes Department of Defense contractors and subcontractors engaged in military contracts or supplying materials, software, or logistics to the DoD. It also encompasses electronics distributors and suppliers, aerospace and defense companies, technology and IT services providers, manufacturing and engineering firms, and educational and research institutions.

Failure to adhere to NIST SP 800-171 standards for organizations handling CUI on their networks can result in significant business and reputational risks, including breach-of-contract penalties and contract loss. Non-compliance can also lead to fines and legal action under DFARS regulations and potential False Claims Act (FCA) violations. Legal and financial risk aside, non-compliance also leaves companies vulnerable to cyber attacks, such as data breaches or IP theft, as well as operational disruptions.

The NIST SP 800-171 DoD assessment consists of 110 security requirements organized into 14 security families that address critical aspects of CUI protections. These families include access control, awareness and training, audit and accountability, configuration management, identification and authentication, incident response, maintenance, media protection, personnel security, physical protection, risk assessment, security assessment, system and communications protection, and system and information integrity.

Achieving NIST SP 800-171 compliance can be complex, especially for businesses unfamiliar with cybersecurity regulations. Companies must address challenges such as determining the scope of employee involvement, preparing the necessary documentation, keeping up with evolving requirements, and managing compliance resources efficiently. However, the process can become more manageable with proactive planning, resource allocation, employee engagement, and proper documentation. 

Fortunately, businesses have access to plenty of resources, including official guidance from  NIST and the DoD, as well as third-party cybersecurity consultants and managed security providers. By leveraging these tools, businesses can navigate compliance efficiently while protecting CUI and maintaining eligibility for government contracts.

As a leading stocking distributor for components used in the military, defense, and aerospace sectors, Peerless Electronics works diligently to uphold the cybersecurity standards set by the Department of Defense (DoD). Our perfect score of 110 in the Joint Surveillance Voluntary Assessment (JSVA) demonstrates our unwavering commitment to safeguarding Controlled Unclassified Information (CUI) and maintaining strict NIST SP 800-171 compliance. Furthermore, our JSVA assessment seamlessly transitioned into a CMMC (Cybersecurity Maturity Model Certification) Level 2 certification. The CMMC rule became effective December 16, 2024 with the DoD planning to include CMMC requirements in select contracts in 2025.

However, these security practices aren’t just limited to our defense contracts - they are applied to all aspects of our operations, illustrating our commitment to excellence in our industry and, most importantly, our customers. From our supply chain management to customer interactions and internal systems, we enforce robust cybersecurity measures to protect sensitive data and ensure operational integrity.

What Are NIST SP 800-171 DOD Assessment Requirements?

To protect Controlled Unclassified Information (CUI), the Department of Defense (DoD) established an assessment methodology to evaluate contractors' compliance with NIST SP 800-171. This framework assesses adherence to the 110 security requirements and helps determine whether a company meets the cybersecurity standards for handling sensitive government data. The assessments are conducted at three levels: basic self-assessment, medium assessment (conducted onsite by DIBAC, alongside a CMMC Certified 3rd Party Assessment Organization (C3PAO) for the CMMC program), and high assessment (conducted onsite by DIBAC).

What Is the NIST SP 800 171 Deadline?

Contractors handling CUI under DoD contracts are already required to comply. The 110 security requirements outlined in NIST SP 800-171 have been in effect since 2017.

What Is the NIST SP 800-171 Assessment Methodology?

This is a scoring system used to evaluate a contractor’s implementation of 110 security requirements for handling Controlled Unclassified Information (CUI). Scores range from -203 to 110, with 110 indicating full compliance. Suppliers must submit their scores to the Supplier Performance Risk System (SPRS) before being awarded Department of Defense (DoD) contracts.