Editable NIST 800-171 R2/R3 & CMMC Compliance Documentation

ComplianceForge has been on the forefront of developing editable policies, standards, procedures and other templates to address NIST 800-171 compliance since 2016 when it was first released. As Department of Defense (DoD) requirements evolved to include third-party attestation through the Cybersecurity Maturity Model Certification (CMMC), so did ComplianceForge’s solutions, where we offer affordable, editable cybersecurity policies, standards, procedures and other templates to address both NIST 800-171 R2 / R3 and CMMC 2.0 Levels 1, 2 and 3.  

When it comes to NIST 800-171 & CMMC compliance, ComplianceForge's editable policies, standards, procedures and other templates are a business accelerator - our products can save you time and significantly reduce the labor costs that are traditionally associated with researching and developing NIST 800-171 & CMMC policies, standards and procedures on your own or by hiring a consultant to do it for you. These are not "fill in the blanks" templates - while they are expected to be edited for your specific needs, these policies, standards and procedures templates are written to address leading secure practices. ComplianceForge documentation can be scoped to address multiple environments (e.g., on-premises and/or in a hosted environment).

This free resource is an Assessment Objective (AO)-level analysis for a NIST 800-171 R2 to R3 transition. Eventually, the US Government's global supply chain will have to transition to NIST 800-171 R3 and this guide offers an AO-level analysis to address differences:

• Over 1/3 are minimal effort (clear, direct mapping)
• Approximately 1/5 are moderate effort (indirect mapping)
• Approximately 1/2 are significant effort (no clear mapping or new AOs)

This guide also addresses the logical dependencies that exist from "orphaned AOs" that are not in NIST 800-171A R3, but a requirement to demonstrate evidence of due diligence and due care still exists for specific functions (e.g., maintenance operations, roles & responsibilities, inventories, physical security, etc.).

In November 2023, NIST released NIST SP 800-171 R3 Final Public Draft (FPD) and NIST SP 800-171A R3 Initial Public Draft (IPD). From a documentation expectation perspective, the two of the biggest changes with NIST 800-171 R3 will be:

• Incident Response – Control 3.6.1 - Develop an Incident Response Plan (IRP) that provides the organization with a roadmap for implementing its incident response capability. The incident-handling capability for incidents must be consistent with the IRP and includes preparation, detection and analysis, containment, eradication and recovery.  
• Supply Chain Risk Management – Control 3.17.1 - Develop a plan for managing supply chain risks associated with the research, development, design, manufacturing, acquisition, delivery, integration, operations, maintenance, and disposal of the system, system components, or system services. This is a Supply Chain Risk Management (SCRM) plan.

The good news is that ComplianceForge has documentation solutions to address both incident response and supply chain risk management. This can save your organization hundreds of hours of work!

ComplianceForge sells editable NIST 800-171 & CMMC policies, standards, procedures, incident response plans, SCRM plans and other documentation templates. This allows you to quickly obtain professionally-written cybersecurity & data protection documentation that is editable for your specific needs, since it comes in Microsoft Office formats. This is beyond simply buying an "IT security policy template" online - these products allow you to have the same level of professional quality documentation that you would expect from hiring a cybersecurity consultant to write it for you. Please take a few minutes and look at the examples to see the high level of quality and professionalism for yourself!

Our NIST 800-171 & CMMC solutions are comprehensive and span the policies, standards, procedures, System Security Plan (SSP), Plan of Action & Milestones (POA&M), third-party risk management and other documentation that businesses need demonstrate compliance. The documentation is written with no blanks to fill out and is ready for your organization-specific customization:

• The policy statements are ready to be adopted, requiring little to no editing.
• The standards are targeted at approximately 90-95% complete, since it is expected that there will be some customization (e.g., unique password strength requirements or organization-specific Bring Your Own Device (BYOD) requirements).
• The procedures are targeted at approximately 75-80% complete, since there is such a variety of technologies and resources. We’ve done the heavy lifting and your subject matter experts just have to fill in the details.

We have quite a few options for NIST 800-171 & CMMC compliance efforts. It really depends on the focus of your compliance efforts, if you just need to comply with NIST 800-171 & CMMC or if you have other compliance obligations that you need to address.

• If you are looking for the “easy button” from a documentation perspective to just focus on CMMC Level 2 / NIST 800-171 then the NIST 800-171 Compliance Program (NCP) is the most cost-effective and efficient solution. This is the most common solution we sell for smaller organizations that just need to address NIST 800-171 & CMMC.
• If you need to “speak NIST 800-53” for other contracts (e.g., FedRAMP, RMF, FISMA, etc.) then CMMC bundle #2 is a great option. This version is straight NIST 800-53 documentation terminology/taxonomy and might be overkill for companies that just need to comply with CMMC / NIST 800-171 without having to align with broader NIST 800-53 moderate requirements. If you have to use the high baseline for NIST 800-53, as also have an option for that with CMMC bundle #3.
• If you need “the whole enchilada” with robust compliance for far more than just CMMC / NIST 800-171, then CMMC bundle #4 is the best option for an enterprise-class environment, especially one that is going to leverage a GRC platform to help manage documentation. This is really meant for complex compliance requirements.

Editable cybersecurity documentation is all that we do, so we focus on doing it better than anyone else. We've been doing this since 2005, so we have a long track record of successfully writing cybersecurity & data protection documentation. We know that not all documentation is the same and quality documentation can pay for itself.

ComplianceForge documentation has clients that range from micro-small defense contractors with just a few employees, all the way to Fortune 100 multinational organizations, US Federal government agencies, major US military commands, and even foreign governments. Our documentation solutions are able to scale, since we develop documentation that concisely addresses specific requirements. Everything we do centers around providing our clients with a solid set of cybersecurity & data protection policies and standards to use as a foundation to build from to be both secure and compliant.

• We embrace logic when evaluating laws, regulations and frameworks and strongly focus on industry-recognized & secure practices.
• ComplianceForge documentation is built based on industry-recognized definitions of what policies, standards and procedures are meant to be. This is based on definitions from NIST, ISO, AICPA and ISACA, which define "what right looks like" and helps make the documentation defendable to assessor scrutiny.
• ComplianceForge’s NIST 800-171 & CMMC documentation is “DIBCAC battle tested” so we know it sufficiently addresses the compliance requirements.
• Our documentation is cross-referenced, where you can see the footnotes for all the NIST 800-171 and CMMC controls, as well as footnotes for each of the Assessment Objectives (AOs) from NIST 800-171A.
• We leverage the NIST NICE Cybersecurity Workforce Framework in our procedures statements to align roles & responsibilities with an industry standard. This makes managing roles more efficient for procedures.
• Procedures are designed to split up the work across the year. This is important to avoid the pitfall of dozens of controls coming due at the end of the calendar year when key stakeholders are unavailable. We help avoid those issues.

ComplianceForge is unique from its competition due to our adherence to industry-recognized practices for how cybersecurity documentation is meant to be structured. Being designed in a hierarchical manner, our approach makes the documentation scalable and logically arranged. That is important, since when it comes to a CMMC assessment, time is money! The longer it takes your C3PAO to read through your documentation to find answers, the more it will cost you in labor-related expenses. ComplianceForge documentation can pay for itself through the efficiency it offers in a CMMC assessment!

We appreciate that a standard is a standard for a reason, so we developed our documentation based on the ComplianceForge Reference Model that leverages industry-recognized definitions from NIST, ISO, ISACA and AICPA to establish what a hierarchical cybersecurity documentation stack is meant to be:

The concept of a "best" cybersecurity framework is misguided, since the most appropriate framework to align with is entirely dependent upon your business model. The applicable laws, regulations and contractual obligations that your organization must comply with will most often point you to one of four (4) starting points to kick off the discussion about "Which framework is most appropriate for our needs?":

• NIST Cybersecurity Framework (NIST CSF);
• ISO 27001/27002;
• NIST SP 800-53 (moderate or high baselines); or
• Secure Controls Framework (SCF) (or a similar metaframework).

However, when it comes to NIST 800-171 & CMMC, it is important to understand the basis of the controls since NIST CSF and ISO 27001/27002 are not comprehensive enough to address those requirements without significant modifications:

NIST 800-171 is based on the moderate baseline from NIST 800-53, which means that NIST CSF and ISO 27001/27002 alignment is not the most efficient approach – it can be done, but you are going to build your own “Frankenstein framework” in the process. Therefore, for NIST 800-171 & CMMC the most appropriate starting point is to align with either:

• NIST SP 800-53 (moderate or high baselines); or
• Secure Controls Framework (SCF) (or a similar metaframework).

The following video walks you through this process: