The Department of Defense’s Cybersecurity Maturity Model Certification (CMMC) and NIST Special Publication 800‑171 share the same goal: protect Controlled Unclassified Information (CUI) handled by contractors. NIST 800‑171 defines the 110 security requirements organizations must implement. CMMC builds on this foundation by verifying that contractors actually meet those requirements through an independent assessment and, at higher levels, by introducing additional controls. CMMC Level 2 aligns with all 110 controls in NIST SP 800‑171 Rev. 2, while Level 3 adds selected requirements from NIST 800‑172.
In an interview for StrikeGraph’s article “CMMC vs. NIST 800‑171: Similarities, Differences & Mappings”, Jerome Weston—Founder and Principal Consultant at Resilience Cyber Group—highlighted three areas where organizations often struggle when moving from NIST 800‑171 compliance to CMMC certification:
- Scope and boundary clarity: Many firms that have self‑attested to NIST 800‑171 have not gone through the rigorous scoping required by CMMC. Assessors expect a clear definition of the CUI environment, supporting assets, and cloud/inherited controls—supported by diagrams and responsibility matrices.
- Objective evidence: Under CMMC it’s not enough to claim a control is implemented; organizations must produce repeatable proof (such as system configurations, log exports, ticket history and standard operating procedures) that aligns with their System Security Plan.
- POA&M restrictions and minimum score: CMMC 2.0 allows only limited Plans of Action and Milestones and requires a minimum score to achieve certification. Companies accustomed to “paper compliance” under NIST 800‑171 often discover gaps late in the process.
Weston also noted that NIST 800‑171 Revision 3 introduces new control families and more prescriptive assessment guidance. Organizations will need to budget time and resources to stand up these new domains and produce additional artifacts. While CMMC currently evaluates against Revision 2, contractors should begin preparing for the future transition.
At Resilience Cyber Group, we guide clients through this evolving landscape. Our CMMC Level 2 readiness program provides a control‑by‑control gap analysis, remediation plan, and executive roadmap. We build audit‑ready SSPs and POA&Ms aligned with current and emerging requirements and deploy secure PreVeil enclaves to protect CUI. Our 24/7 managed security operations center collects continuous evidence to prove ongoing control performance.
Need help navigating CMMC and NIST 800‑171? Contact us to request a consultation.